ML23321A047
| ML23321A047 | |
| Person / Time | |
|---|---|
| Site: | Perry  |
| Issue date: | 12/20/2023 |
| From: | Lance Rakovan NRC/NMSS/DREFS/ELRB |
| To: | Penfield R Energy Harbor Nuclear Corp |
| References | |
| EPID L-2021-SLE-0002 | |
| Download: ML23321A047 (37) | |
Text
Rod L. Penfield Site Vice President Energy Harbor Nuclear Corp.
Perry Nuclear Power Plant P.O. Box 97, Mail Stop A-PY-A290 Perry, Ohio 44081-0097
SUBJECT:
PERRY NUCLEAR POWER PLANT, UNIT 1 - LICENSE RENEWAL REGULATORY AUDIT REGARDING THE ENVIRONMENTAL REVIEW OF THE LICENSE RENEWAL APPLICATION (EPID NUMBER: L-2021-SLE-0002)
Dear Rod L. Penfield:
By letter dated July 3, 2023 (Agencywide Documents Access and Management System Package No. ML23184A081), Energy Harbor Nuclear Corp. (Energy Harbor or the applicant),
doing business as Energy Harbor Nuclear Generation LLC., submitted to the U.S. Nuclear Regulatory Commission (NRC) an application for license renewal of Renewed Facility Operating License No. DPF-58, Perry Nuclear Power Plant, Unit 1 (Perry) 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.
The NRC staff has initiated the environmental review for the application. A virtual environmental audit will be conducted the week of January 22, 2024 by NRC staff (see Enclosure 1). In addition, NRC staff will conduct a site-visit the week of January 29, 2024.
To the extent possible, the NRC staff requests the information identified in the Environmental Audit Needs List (Enclosure 2) be made available on the Perry online reference portal prior to the audit. A draft schedule of tours and meetings is provided in Enclosure 3.
December 20, 2023
R. Penfield If you have any questions, please contact me via email at Lance.Rakovan@nrc.gov.
Sincerely, Lance J. Rakovan Senior Environmental Project Manager Environmental Project Management Branch 1 Division of Rulemaking, Environmental, and Financial Support Office of Nuclear Material Safety and Safeguards Docket Nos. 50-440
Enclosures:
As stated cc w/encls: Listserv Signed by Rakovan, Lance on 12/20/23
ML23321A047 OFFICE NE/PM:EPMB1 LA:REFS BC:EPMB1 NE/PM:EPMB1 NAME LRakovan AWalker-Smith SKoenick LRakovan DATE 11/20/2023 11/21/2023 12/13/2023 12/14/2023 Audit Plan License Renewal Environmental Review Perry Nuclear Power Plant Unit 1 January 2024 Division of Materials and License Renewal Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission
1 License Renewal Environmental Review Perry Nuclear Power Plant Unit 1
1. Background
By letter dated July 3, 2023 (Agencywide Documents Access and Management System Package Number ML23184A081), Energy Harbor Nuclear Corp. (Energy Harbor or the applicant), doing business as Energy Harbor Nuclear Generation LLC., submitted to the U.S. Nuclear Regulatory Commission (NRC) an application for license renewal of Renewed Facility Operating License No.
DPF-58, Perry Nuclear Power Plant, Unit 1 (Perry) pursuant to Section 103 of the Atomic Energy Act of 1954, as amended. A Federal Register (FR) Notice (88 FR 53933) dated August 9, 2022, noted the receipt and availability of the application, including the environmental report (ER).
The NRC staff is conducting an environmental audit of the Perry site to improve understanding, to verify information, and to identify information for docketing to support the preparation of an environmental impact statement. Specifically, the NRC staff will be identifying pertinent environmental data, reviewing the facility, and seeking clarifications regarding information provided in the ER.
2.
Environmental Audit Bases License renewal requirements for environmental reports are specified in Title 10 of the Code of Federal Regulations (10 CFR) Part 51, Postconstruction environmental reports. As specified by 10 CFR 51.53(c): Operating license renewal stage, (1) Each applicant for renewal of a license to operate a nuclear power plant under Part 54 of this chapter shall submit with its application a separate document entitled "Applicant's Environmental ReportOperating License Renewal Stage." 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.
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 is to identify new and significant issues and issues which can be eliminated from further study. The NRC staff will also identify environmental resources that must be described and evaluated in the Supplemental Environmental Impact Statement.
Audit team members will review the documents and other requested information made available on the Perry online reference portal Identified on the environmental audit needs list (Enclosure 2) and discuss any questions and additional information needs with the applicants subject matter experts.
4.
Information and Other Material Necessary for the Environmental Audit As identified on the environmental audit needs list (Enclosure 2).
2 5.
Environmental Audit Team Members and Resource Assignments The environmental audit team members and their assignments are shown in the table below.
Discipline Team Members Environmental Review Supervisor Steve Koenick Environmental Project Manager Lance Rakovan Air Quality Nancy Martinez Aquatic Resources Briana Arlene Cumulative Impacts Jeff Rikhoff Environmental Justice Caroline Hsu Federally Protected Ecological Resources Briana Arlene Geologic Environment Gerry Stirewalt Greenhouse Gases/Climate Change Nancy Martinez Groundwater (Hydrology and Hydrogeology)
Gerry Stirewalt Historic and Cultural Resources Jean Trefethen Human Health Beth Alferink Land Use and Visual Resources Caroline Hsu Meteorology and Climatology Nancy Martinez Noise Nancy Martinez Postulated Accidents Elijah Dickson w/Jerry Dozier Replacement Power Alternatives Jeff Rikhoff Severe Accident Mitigation Alternatives Elijah Dickson w/Jerry Dozier Socioeconomics Leah Parks w/Jeff Rikhoff Spent Nuclear Fuel Beth Alferink w/Leah Parks Surface Water Lloyd Desotell Termination of Operations and Decommissioning Beth Alferink Terrestrial (Land Cover and Habitat)
Caroline Hsu Uranium Fuel Cycle Beth Alferink Waste Management (rad and non-rad)
Leah Parks 6.
Logistics An environmental audit will be conducted by NRC staff virtually the week of January 22, 2024, followed by a site-visit the week of January 29, 2024. An entrance meeting will be held with plant management at the beginning of the audit and an exit meeting will be held following the site visit.
7.
Special Requests Energy Harbor staff and contractors who are subject matter experts in the disciplines identified on the environmental audit needs list should be available for interviews and tours.
8.
Deliverables An audit summary report will be issued by the NRC staff within 90 days from the end of the environmental audit.
3 Perry Nuclear Power Plant Audit and Information Needs Described below in three categories (i.e., tours, meetings, and information needs) are the information needs of the U.S. Nuclear Regulatory Commission (NRC) staff, supported by Pacific Northwest National Laboratory (PNNL), Perry Nuclear Power Plant Unit 1 (Perry Plant).
Information needs are identified as either resource-specific questions or document requests.
Please arrange for the tours and meetings specified below to occur during either the virtual environmental audit or site visit as noted. Additionally, we ask that you provide responses to the information needs on the electronic portal and make subject matter experts available to discuss these items with the NRC staff.
Virtual Tours Please arrange for, and provide appropriate subject matter experts to contribute to, the following virtual tours. For the virtual tours, please provide photographs, diagrams, location maps, and/or callouts for specific components that would be of interest for the features noted.
Title or Number Features Observed NRC Participants PNNL Participants
- 1. General site tour Virtual walk-through of the following via photographs and/or diagrams:
Exterior grounds Transmission lines Historic and cultural sites Possible alternative power generation locations Independent Spent Fuel Storage Installation (ISFSI)
Plant views from publicly accessible areas All All Available
- 2. Plant intake and discharge tour Virtual walk-through of the following via photographs and/or diagrams:
Submerged multi-port intake and intake tunnel, including depiction of location of intake within Lake Erie Traveling screens Service water pumphouse Emergency service water forebay Cooling towers and cooling tower basin Discharge tunnel and discharge outfall within Lake Eerie Chemical cleaning lagoon Lloyd Desotell Nancy Martinez Leah Parks Beth Alferink Briana Arlene Gerry Stirewalt Philip Meyer Ann Miracle Patrick Mirick Rebecka Bence
4
- 3. Radwaste tour Virtual walk-through of the following via photographs and/or diagrams:
Liquid radwaste system - discharge locations Gaseous radwaste system -
discharge locations Low-Level Radioactive Waste (LLW) Storage Area (Radwaste Building)
Unit 2 Cooling Tower Basin Lloyd Desotell Leah Parks Beth Alferink Gerry Stirewalt Philip Meyer Rebecka Bence
- 4. Groundwater tour Virtual walk-through of the following via photographs and/or diagrams:
Monitoring wells Underdrain system relevant manholes and piezometers Lloyd Desotell Gerry Stirewalt Philip Meyer Rebecka Bence
- 5. Visual resources tour Virtual walk-through of the following via photographs:
Perry Plant structures visible from public roads (for example US 20, Antioch Road, Lockwood Road, Parmly Center Rd)
Perry Plant structures taken from publicly accessible areas of Lake Erie.
Perry Plant structures taken from any other publicly accessible area where plant structures or operations are visible, (e.g., Perry Township Park, Village of North Perry, the nearest residence).
5 In-person Tours Please arrange for, and provide appropriate subject matter experts to contribute to, the following in-person tours as part of the NRCs site visit.
Title or Number Features Observed NRC Participants PNNL Participants
- 1. General site tour Exterior grounds In-scope transmission lines Historic and cultural sites Possible alternative power generation locations ISFSI Plant views from publicly accessible areas All Rebecka Bence
- 2. Plant intake and discharge tour Submerged multi-port intake and intake tunnel, including depiction of location of intake within Lake Erie Traveling screens Service water pumphouse Emergency service water forebay Cooling towers and cooling tower basin Discharge tunnel and discharge outfall within Lake Eerie Chemical cleaning lagoon Nancy Martinez Beth Alferink Gerry Stirewalt Rebecka Bence
- 3. Radwaste tour Liquid radwaste system - discharge locations Gaseous radwaste system - discharge locations LLW Storage Area (Radwaste Building)
Unit 2 Cooling Tower Basin Beth Alferink Gerry Stirewalt Rebecka Bence
- 4. Groundwater tour Monitoring wells Underdrain system relevant manholes and piezometers Gerry Stirewalt Rebecka Bence
- 5. Historic and Cultural Tour grounds and facilities, specifically where any cultural/historic artifacts have been identified Lindsey Renaud
6 Meetings Please be prepared to schedule breakout meetings with the appropriate subject matter expert(s) and/or contractor(s) concerning the following topics. Those in attendance should be prepared to discuss the corresponding questions as described in the Information Needs and Document Requests section below. The staff intends to use these breakout meetings, as needed, to resolve or clarify any outstanding data needs or questions arising from the environmental audit. NRC intends to leverage virtual breakouts to the extent possible. Any in-person breakouts are specified.
Air Quality and Noise Ecological Resources (Aquatic, Terrestrial, Federally Protected)
Environmental Justice Geologic Environment Groundwater and Surface Water Resources Historic and Cultural Resources Human Health (virtual with any necessary follow-up onsite)
Land Use and Visual Resources Postulated Accidents/Severe Accident Mitigation Analysis (SAMA) analysis and results Replacement Energy Alternatives (and Cumulative Effects - reasonably foreseeable future actions, if necessary)
Socioeconomics Terrestrial Resources Waste Management (including Termination of Operations & Decommissioning) (virtual with any necessary follow-up onsite along with walk-downs of the areas noted above)
Information Needs and Document Requests Information needs and document requests are identified below by resource area.
General (All)
The following requests are generic to more than one environmental review area. Issues applicable to these questions are provided below along with the responsible NRC subject matter expert, as appropriate.
GEN-1 Please provide any relevant updates to table 9.1-1 in appendix E of the Environmental Report (ER). If any permits have expired since Energy Harbor's License Renewal Application for the Perry Plant, dated July 3, 2023 (Agencywide Documents Access and Management System ML123184A081), please provide the status of those permits and/or renewals.
Topic-specific The following requests are specific to a single environmental review area. If a topic is not provided below, the discussions held in response to the generic requests above are expected to fully cover that topic.
Air Quality and Noise (Nancy Martinez)
Audit Needs
7 AQN-1 Section 3.3.3.2 of the ER states that a permit to install cooling towers on the site was in place during construction and currently, emissions from the cooling towers are being evaluated by the Ohio Environmental Protection Agency (OEPA). The OEPA will evaluate the need to include the Unit 1 cooling tower in a future permit.
a.
Please clarify, if OEPA is evaluating both hyperbolic cooling towers on site, or just the Unit 1 cooling tower.
b.
Please provide an update regarding this evaluation. As part of this response discuss if OEPA has decided if the Unit 1 cooling tower needs to be included in a permit.
c.
Please provide quantified particulate matter emissions for the Unit 1 cooling tower.
AQN-2 Section 3.3.3.2 of the ER states that Perry Plant holds a conditional operating permit to operate two auxiliary boilers. Section 3.3.3.2 of the ER states [t]he emissions reports submitted to the OEPA each year contain summary information related to the summed emissions from each permitted emissions unit and the emissions from other Perry Plant emission sources. Table 3.3-10 of the ER presents Perry Plant report annual air emissions for 2017-2021. Section 4.12.2.1 of the ER goes on to say that Perry Plant air pollutant emissions are minimal and stem from intermittent use, maintenance and testing of stationary generators and miscellaneous equipment.
a.
Please clarify if annual air emissions in table 3.3-10 accounts only for the two onsite auxiliary boilers or permitted sources (two onsite auxiliary boilers) and additional onsite emission sources.
b.
If air emissions in table 3.3-10 account for permitted sources (two onsite auxiliary boilers) and additional onsite emission sources, please identify the additional onsite emission sources accounted for in table 3.3-10 c.
Please provide a list of onsite equipment that contribute to air emissions (e.g.,
diesel generators, diesel pumps), but are not included in Perry Plants conditional operating permit.
AQN-3 Section 9.5.2.1 of the ER states that Perry Plant submits emission reports to the OEPA annually. Please provide a copy of the last 3 years emission reports.
AQN-4 Section 3.3.3.2 of the ER states that there have been no notices of violation or non-compliances associated with Perry Plant air emissions from 2017-2021. Has Perry Plant received any notices of violation or non-compliances associated with Perry Plant air emissions since 2021? If so, please provide details.
AQN-5 Table 3.3-11 of the ER presents Perry Plant annual greenhouse gas emissions. ER Section 3.3.4 of the ER states that table 3.3-11 includes direct emissions, which includes stationary and portable combustion sources in table 3.3-10 of the ER.
a.
Please clarify if annual greenhouse gas emissions in table 3.3-11 accounts only for the two onsite auxiliary boilers or permitted sources (two onsite auxiliary boilers) and additional onsite emission sources.
b.
If table 3.3-11 only accounts for the two onsite auxiliary boilers, please provide annual direct greenhouse gas (GHG) emission from additional onsite stationary and portable combustion (e.g., diesel generators) for 2017-2021.
c.
Does Perry Plant use sulfur hexafluoride in equipment onsite? If so, please provide an estimate of annual GHG emissions for 2017-2021.
8 AQN-6 Have field tests concerning ozone or nitrogen oxide emissions generated by Perry Plants in-scope transmission lines been conducted? If so, please provide a copy of these tests.
AQN-7 Section 3.4 of the ER states that beyond the general noise from operations, periodic use of the firing range is another onsite activity that creates occasional noise. Please identify primary noise-generating sources that contribute to general noise from operations.
AQN-8 Section 3.4 of the ER states that no noise complaints have been received related to Perry Plant activities between 2017-2021. Have any noise complaints been received since 2021? If so, please provide details.
Document Needs AQN-9 9.5.2.1 of the ER states that Pery Plant submits emission reports to the OEPA annually. Please provide emission reports for the last 3 years.
Aquatic Resources (Briana Arlene, Ann Miracle, Patrick Mirick)
Audit Needs AQ-1 Please describe if the cooling water intake system includes a fish return system, and if so, provide details on its operations. If there is no fish return system, please explain what happens to fish that are impinged on the intake screens.
AQ-2 The Environmental Protection Plan (Section 4.1 of appendix B to the Perry Operating License) states that Energy Harbor is required to report significant fish kills or mortality of federally protected species. Please provide any information on fish kills and their causes during the past 5-year period.
Document Needs AQ-3 The National Pollutant Discharge Elimination System (NPDES) permit (contained in appendix B of the ER) states that the OEPA has determined that the cooling water intake structure represents the best technology available to minimize impingement mortality and entrainment in accordance with Section 316(b) of the Clean Water Act.
Please provide copies of any reports, studies, and other documents that Energy Harbor submitted to the OEPA to support this 316(b) determination.
AQ-4 Please provide copies of reports, NPDES permit application supplements, or other submittals that Energy Harbor has submitted to the OEPA pursuant to requirements of Clean Water Act Section 316(a) and its implementing regulations.
AQ-5 Appendix E of the ER describes that a thermal plume analysis predicted a small surface plume within a 1F isotherm. Please provide a copy of this thermal plume analysis.
AQ-6 Section 3.7.7.1 of the ER states that Energy Harbor conducts periodic surveys to monitor mussel settlement in plant systems during the spawning season in Lake Erie.
Please provide copies of such reports from the past 5 years.
AQ-7 Section 3.7.5.2 of the ER describes several invasive aquatic species. Does Energy
9 Harbor manage any of these species on the Perry Plant site? If so, please provide copies of relevant site management plans and procedures.
Cumulative Impacts (Jeff Rikhoff, Dave Goodman)
Audit Needs CI-1 Per Title 10 of the Code of Federal Regulation (10 CFR) Section 51.53(c)(3)(ii)(O),
please provide information about other past, present, and reasonably foreseeable future actions occurring in the vicinity of the nuclear plant that may result in a cumulative effect that may have occurred since the ER was submitted.
Document Needs None Environmental Justice (Caroline Hsu, Dave Anderson, Lin Zeng)
Audit Needs EJ-1 Has the applicant done any community engagement to learn about the potential impacts and concerns that the local communities might have about the continued operation of Perry Plant? If so, please provide information.
EJ-2 Section 3.11.3.1 of the ER states that theres no subsistence population identified in the vicinity of Perry Plant. Meanwhile, the ER states that the second largest Amish community is located approximately 25 miles south-southeast of the site in Mesopotamia Township, OH and may engage in a subsistence-like lifestyle. Please confirm whether or not the subsistence population is identified in the vicinity of the plant.
Document Needs None Federally Protected Ecological Resources (Briana Arlene, Ann Miracle, Tracy Fuentes)
Audit Needs FPE-1 Section 3.7.8.1.6. of the ER describes that there have been no recent observations of the ESA [endangered species act]-listed snuffbox mussel in the vicinity of the PNPP
[Perry Plant]. Is Energy Harbor aware of the occurrence of this species near Perry Plant at any point during construction or operation of the plant?
FPE-2 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 range includes Lake County. Please provide an analysis of the potential impacts of the proposed license renewal on tricolored bat.
10 FPE-3 Sections 3.7.8.1 and 3.7.8.1.2 of the ER state that the Perry Plant site contains suitable roosting and maternity habitat for the northern long-eared bat (Myotis septentrionalis) and Indiana bat (M. sodalis).
a.
Please provide a map or illustration depicting the location of this habitat.
- b. Does Energy Harbor plan to undertake tree removal or conduct any other activities during the subsequent license renewal period that would disturb this habitat?
c.
Describe Energy Harbors best management practices (BMPs) and procedures to ensure that actions, such as removing hazard trees, would not adversely affect bats, if present.
FPE-4 Sections 3.7.8.1.3 and 3.7.8.1.4 state that no records of piping plover (Charadrius melodus) or red knot (Calidris canutus) occur within one mile of the Perry Plant site.
Please provide the source of this information. Has Energy Harbor conducted any avian surveys for this species or other federally protected birds?
FPE-5 Section 3.7.8.1.7 of the ER states that suitable habitat for the monarch butterfly is likely present in undeveloped portions of the Perry Plant site. Monarch butterflies rely on milkweeds (Asclepias spp.) for ovipositing and for larval food. Adults rely on a variety of plants for nectar sources. Does Energy Harbor have any records of milkweed occurring on the Perry Plant site? If so, when was the last time milkweed was documented on site. Does Energy Harbor have a list of vascular plants occurring on the site? If so, when was the plant list collected?
FPE-6 Section 3.7.2.6 of the ER states that the in-scope transmission lines overlap with critical habitat for the Federally listed piping plover (Charadrius melodus). However, figure 2.2-2 identifies the in-scope transmission lines as two small portions of transmission line that connect the Unit 1 and Unit 2 turbine buildings to the adjacent switchyard. In its initial review of the ER, the NRC staff have not identified designated piping plover critical habitat to occur along the in-scope transmission lines or within any other areas of the Perry Plant site. Can you please further explain this statement concerning piping plover critical habitat in the ER and confirm whether Energy Harbor has identified that critical habitat has been designated within the Perry Plant site boundaries?
FPE-7 Section 3.7.8 of the ER states: Compliance with all regulatory requirements associated with protected species will continue to be an administrative control practiced by Energy Harbor for the licensed life of the Perry Plant facility. Adherence to these controls, as well as compliance with applicable laws and regulations, should prevent potentially negative impacts to any special status and protected species.
Please describe these administrative control practices in more detail as they concern Federally protected ecological resources and provide copies of relevant site plans and procedures for NRC staff review.
Document Needs FPE-8 USFWS. 2022b. IPac Resource List. Accessed February 24, 2022, from:
https://ecos.fws.gov/ipac/location/GIYNBWMLQZCHTM76AMX4LXSQCI/resources.
11 Geologic Environment (Gerry Stirewalt, Becka Bence, Phil Meyer)
Audit Needs GE-1 Section 2.4.5.5.1.1 of the Perry Plant Updated Safety Analysis Report (ML21307A174) summarizes shoreline recession at the site and states an annual survey will be conducted through the life of the plant to monitor the combined effect of shoreline recession and bluff erosion. Please provide a description characterizing erosion observed at the site using survey results and other evidence as needed. Provide most recent survey documentation to support the description.
GE-2 Section 3.1.4 of the ER briefly describes a potential shoreline erosion protection project along the northeast shoreline of Lake Erie within the site boundary. Potential project options are listed, including use of sheet piling and/or armor stone revetment. Please describe any updates on design and permitting of this project, including final design plans (provide maps or schematics if available), Ohio Department of Natural Resources (DNR) shore structure permit number (if available, if not, please describe any intentions to apply for a shore structure permit), and expected lifetime of erosion control measures.
GE-3 ER Figure 3.5-3 (Geologic Cross-Section and Location at Perry Plant) is partially illegible. Please provide a higher resolution image or annotate the figure to make all numbers and labels legible. Additionally, please explain what the blue lines on the index map inset represent. Confirm that the blue arrow symbols shown in the figure show the direction of groundwater flow in the cross-section line.
Document Needs None Groundwater Resources (Gerry Stirewalt, Becka Bence, Phil Meyer)
Audit Needs GW-1 Section 3.6.2.4 of the ER states the first periodic review of the Groundwater Protection Program at Perry Plant was conducted in 2015. Please provide documentation of the review and describe any updates or changes to the site hydrogeological characterization (and therefore site conceptual model) and site risk assessment related to plant systems, structures and components and work practices that may have potential for the licensed material to release and impact groundwater.
GW-2 Please have subject matter experts available during the audit to discuss the underdrain system and its operation. Discussion points will include the radioactivity level at which the radiation monitors located in the gravity discharge manholes will stop the pumping of the pressure relief underdrain system, in addition to ultimate effluent storage and discharge for each operational mode.
GW-3 Section 3.6.4.2 of the ER describes the detection of tritium in manhole MH-20 in December 2021 above 2000 pCi/L. Please provide documentation detailing the investigation, chemistry sampling plan, and tritium action plan implemented as a result of the elevated tritium concentrations. Include sampling results with location ID
12 sampled, date sampled, and tritium concentration in pCi/L. Describe the three potential sources that were identified during the investigation and a description and timeline of any remedial actions completed in response to the identified sources.
GW-4 The 2023 Annual Radioactive Effluent Release Report (ARERR) (ML23117A196) reports a tritium activity of 5.52E-05 uCi/mL (55,200 pCi/L) for manhole MH-20 sampled in Q1 of 2022 (table 14 on page 29 or 32). The remaining 2022 samples for MH-20 exceed 2.00E-06 uCi/mL (2,000 pCi/L) according to the report. Please confirm the accuracy of these results and provide a description of the actions taken in response to these monitoring results. Following table 14, the ARERR states that, Tritium activity has returned to background levels. Explain how this statement is consistent with the Table 14 monitoring results.
GW-5 Please confirm that tritium, gamma or difficult to detect radionuclides were not identified in manhole, piezometer, and well samples between January 2022 and October 2023.
GW-6 On July 19th 2023, Perry Plant submitted a voluntary 30-day report in accordance with NEI 07-07 relating to elevated tritium (40,200 pCi/L) in a sample obtained from underdrain piezometer 21 in June 2023. The voluntary report and subsequent integrated inspection report described the response to this release. Actions included tritium sampling in an expanded number of piezometers and manholes, assessment of three failure modes, related infrastructure assessment, and low volume continuous pumping (4 gallons per day) from piezometer 21 to assess whether the observed tritium was an active leak or a cyclic leak from the previous refueling outage. The inspectors concluded that the data indicated no active leak in the underdrain system nor migration of tritium outside the underdrain system. Please provide documentation detailing the investigation of the June 2023 tritium release, including any ongoing response actions, samples collected, and monitoring results for tritium and other radionuclide activities detected since June 2023. Verify if pumping at piezometer 21 is ongoing and state any updated conclusions or findings related to the source of the elevated tritium and the potential for ongoing or future releases.
Document Needs GW-7 As stated in Section 3.6.2.4 of the ER, Perry Plant implemented a groundwater protection program in 2006 in accordance with the Nuclear Energy Institutes (NEI) NEI 07-07. Please provide a copy of the Groundwater Protection Plan for review.
Historic and Cultural Resources (Jean Trefethen)
Audit Needs HCR-1 Section 2.2.2 describes maintenance, inspection, and refueling activities. Please elaborate on what is considered maintenance and confirm that there will be no ground disturbing activities associated with the proposed action. Often, operations and maintenance activities include ground disturbing activities. For example, construction of new parking lots or buildings, activities associated with transmission line maintenance (e.g., maintenance of access roads or removal of trees), or if an underground pipe were to break or leak. What procedures are in place to guarantee historic and cultural resources may not be impacted by ground disturbing activities? Are there inadvertent
13 discovery procedures or monitoring procedures in place?
HCR-2 Section 3.8.3 states that no cultural resources have been found within the 1,030-acre archaeological (APE) and does not mention any recent field surveys to identify historic properties. Please identify steps that were taken to identify any historic properties within the archaeological APE.
HCR-3 An October 13, 2022, email from the Ohio History Connection indicated they received additional information from a discussion earlier that day with Energy Harbor. Please provide a summary of the information communicated to the Ohio History Connection reviewer that led to the revising of their recommendation that an architectural evaluation be done as stated in their September 28, 2022, letter. The summary should include all the names of all parties involved in the discussion.
HCR-4 Please confirm when the power plant completed construction as the images and dates in the ER provide conflicting timelines. Section 3.8.1 indicates that construction was completed in 1984, however, a completion date of 1985 was communicated to the State Historic Preservation Officer when they inquired about this (appendix D-email dated October 13, 2022). While the construction permit was issued in 1977, figure 3.8-5 shows early stages of construction in 1975. At least several buildings and one of the units appeared to be completed in the 1982 and 1983 images (figure 3.8-8, figure 3.8-9). Please provide all documentation confirming the final date of construction.
Document Needs HCR-5 Please provide copies of letters and other communication documents Energy Harbor has received from consulting Tribes since May 17, 2022, the date when the letters were sent. Additionally, if any State recognized/non-Federally recognized Tribes were contacted, provide copies of these letters as well.
HCR-6 Section 3.8.6 indicates Energy Harbor has two procedures which aim to identify, protect, and minimize the potential of impact to cultural resources within the Perry Plant facility. Please provide copies of those procedures.
Human Health (Beth Alferink)
Audit Needs HH-1 Ohio Department of Health suggested an update to the modeling impacts from thermal effluents into Lake Erie in their response regarding potential public health risks from thermophilic organisms in Attachment E. Has consideration been given by Perry Plant to update this modeling for a single unit and any updated temperature profiles since the original model was developed?
HH-2 The analysis for Microbiological Hazards to the Public in Section 4.12.8 doesn't mention algal blooms even though they are mentioned in the description of the environment in 3.10.1. Please confirm that the plants thermal discharges do not contribute to algal blooms in Lake Erie.
HH-3 Please provide any updates concerning waterborne diseases in the vicinity of the plant
14 discussed in 3.10.1 since the submission of the license renewal environmental report.
HH-4 Please have subject matter experts available to discuss the electrical safety program along with related Occupational Safety and Health Administration regulations as implemented at the site under the industrial safety program. Plan to discuss the safety specific policies for work conducted at electrical transmission locations as noted in 2.2.5 and 3.10.2 and a walk-through of the workplace hazards identification process and jobsite analysis noting how change evaluations would identify electric shock hazards or potential human error to eliminate risk during work on the in-scope transmission lines. In addition, Section 3.10.2 discusses the in-scope transmission lines and points to figure 2.2-2. Figure 2.2-2 appears to show two highlighted transmission lines lining up with the discussion in Section 2.2.5 but the text in 3.10.2 states that in-scope lines include lines to the Perry Plant Unit 1 and Unit 2 Startup transformers and the line to the main transformer. Please clarify the number of in-scope transmission lines.
HH-5 Please provide an overview of the radiation control program with emphasis on the as low as reasonably achievable (ALARA) program to control worker radiation exposure (annual dose goals and status). In particular, please discuss the annual variations in total personnel with measurable dose and the average total effective dose equivalent (TEDE) per worker noting that the average TEDE per worker at Perry tends to be higher than the boiling water reactor (BWR) industry average over the rolling three-year periods summarized in NUREG-0713. Are there any proposed changes or upgrades to the program being considered during the license renewal term?
Document Needs HH-6 Section 3.10.2 discusses a 2022 study performed for Perry Plant to determine compliance with the 2017 National Electric Safety Code (NESC) clearance standards.
Please provide a copy of the study and analysis findings to include the conclusion of no clearance issues and that NESC clearance requirements are met as stated in the ER.
Land Use and Visual Resources (Caroline Hsu)
Audit Needs LU-1 Please provide details involving the closest port to the Perry Plant site on Lake Erie.
Document Needs None Postulated Accidents/SAMA (Elijah Dickson, Jerry Dozier)
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
15 Regulations for Domestic Licensing and Related Regulatory Functions, as part of the license renewal application. Review guidance for the NRC 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. The staff is utilizing NEI 05-01, Severe Accident Mitigation Alternatives (SAMA) Analysis guidance document which provides a template for completing the SAMA analysis in support of license renewal. Its purpose is to identify the information that should be included in the SAMA portion of a license renewal application environmental report to reduce the necessity for NRC requests for additional information.
As part of the license renewal review, the NRC staff will conduct a remote audit of the SAMA analysis included in the Perry Plant ER. This audit is conducted with the intent to gain understanding, verify information, and identify information that will require docketing to support the basis of the licensing or regulatory decision. Specifically, the NRC staff will identify pertinent data and obtain clarifications regarding information provided in the ER.
The NRC staff requests the applicant make available the information identified on the audit needs list prior to the audit. Plant staff who are subject matter experts in the disciplines listed on the audit needs list should be available for discussions.
Audit Needs SAMA-1 Provide the following information regarding the Level 1 Probabilistic Risk Assessment (PRA) used for the SAMA analysis. The basis for this request is as follows: applicants for license renewal are required by 10 CFR 51.53(c)(3)(ii)(L) to consider SAMAs if not previously considered in an environmental impact assessment, related supplement, or environmental assessment for the plant. As part of its review of the Perry Plant SAMA analysis, NRC staff evaluates the applicants treatment of internal events and calculation of core damage frequency in the Level 1 PRA model. The requested information is needed in order for the NRC staff to reach a conclusion on the sufficiency of the applicants Level 1 PRA model for supporting the SAMA evaluation.
a.
It is stated in Section G.1.3.8 that the PRA model used in the SAMA analysis is considered to be fundamentally compliant with Regulatory Guide (RG) 1.200, Revision 2. Table G1.3-2 shows that a peer review certification of the PRA model was performed in May 1997 by the Boiling Water Reactor Owners Group (BWROG), which was several years prior to the issuance of NRC RG 1.200, Revision 0. Table G1.3-2 also shows that a Gap Analysis self-assessment was performed in May 2008 to the American Society of Mechanical Engineers (ASME)
RA-Sb-2005 PRA standard. Additionally, table G1.3-2 shows that the seismic PRA peer review and the PRA modeling of offsite power recovery were performed to the ASME/American Nuclear Society (ANS) PRA Standard RA-Sb-2013. Address the following with respect to the peer review certification, Gap Analysis, and use of the ASME/ANS PRA Standard RA-Sb-2013:
i.
Provide a summary of the 1997 BWROG peer review certification scope, identify or summarize the guidance used to conduct this certification, and provide a characterization of the findings of the BWROG peer review certification (e.g., by PRA element). Include in the response a description/definition of the grading system used for findings and observations.
16 ii.
Discuss the scope of the Gap Assessment, the process used to address the findings from the BWROG peer review certification, and how the guidance in NRC RG 1.200, Revision 1 (including NRC staff clarifications and qualifications, NRC staff position on NEI 00-02 self-assessment process),
was used.
iii.
It does not appear that a gap assessment was performed of the PRA model to NRCs RG 1.200, Revision 2. Clarify why Energy Harbor feels its approach is fundamentally compliant with RG 1.200.
iv.
The ASME/ANS PRA Standard RA-Sb-2013 has not been endorsed by the NRC in Regulatory Guide 1.200. Discuss any differences between this standard and the ASME/ANS PRA Standard RA-Sa-2009 endorsed in RG 1.200, Revision 2, or other applicable NRC-endorsed standard. Discuss the guidance used to conduct this peer review and justify that the peer review is reasonable for the SAMA analysis.
b.
Section G.1.3 summarizes the PRA model development and peer review process. It is indicated that in October 2017 a focused-scope peer review was conducted on the resolutions to all Facts and Observations (F&Os) determined to be PRA upgrades concurrently with an F&O closure review conducted on all F&O resolutions determined to be PRA updates. Address the following with respect to the F&O closure process:
i.
Clarify that the F&O closure review was conducted in accordance with NRC letter dated May 1, 2017, U.S. Nuclear Regulatory Commission Staff Expectations for an Industry Facts and Observations Independent Assessment Process [ML17121A271], and NRC letter dated May 3, 2017, U.S. Nuclear Regulatory Commission Acceptance on Nuclear Energy Institute Appendix X to Guidance 05-04, 07-12, and 12-13, Close-Out of Facts and Observations (F&Os) [ML17079A427]. If the F&O closure review was not conducted in accordance with this guidance, assess the impact of any deviations from this guidance on the SAMA analysis.
ii.
Discuss whether the F&O closure review scope included all finding-level F&Os (for the internal events, internal flooding, and seismic PRAs),
including those finding-level F&Os that are associated with Met Supporting Requirements (SRs). If not, identify and provide the original peer review findings and recommendations for any F&Os that were excluded from the F&O closure review scope, and their associated disposition for the SAMA analysis.
iii.
Confirm that the closure review team was provided with a written assessment and justification of whether the resolution of each F&O, within the scope of the independent assessment, constitutes a PRA upgrade or maintenance update, as defined in ASME/ANS RA-Sa-2009, Addenda to ASME/ANS RA-S-2008, Standard for Level 1/Large Early Release Frequency Probabilistic Risk Assessment for Nuclear Power Plant Applications, as qualified by RG 1.200, Revision 2, An Approach for Determining the Technical Adequacy of Probabilistic Risk Assessment Results for Risk-Informed Activities, (ML090410014). If the written assessment and justification for the determination of each F&O was not performed and reviewed by the F&O closure review team, discuss how this
17 aspect of the F&O closure process was met consistent with the staffs acceptance as discussed in the May 3, 2017, letter.
c.
Summarize the scope, guidance used, and results of the focused-scope peer review that was held concurrently with the F&O closure review addressed in part b.
above, including whether new finding-level F&Os were generated from this peer review. If any new F&Os generated from this peer review have not been closed in accordance with the NRC-accepted process addressed in part a above, identify and provide the original peer review findings and recommendations, and their associated disposition for the SAMA analysis.
d.
Section G.1.3 indicates that Diverse and Flexible Mitigation Capability (FLEX) strategies are credited in the PRA, utilizing guidance from NEI 12-06. In NRC memorandum dated May 30, 2017 [ML17031A269], the NRC staffs positions and conclusions are provided regarding use of guidance in NEI 16-06, Crediting Mitigating Strategies in Risk-Informed Decision Making. In NRC memorandum dated May 6, 2022 [ML22014A084], Updated Assessment of Industry Guidance for Crediting Mitigating Strategies in Probabilistic Risk Assessments, the NRC staff identified challenges and strategies for incorporating FLEX equipment into a PRA model in support of risk-informed decisionmaking when using additional industry guidance issued after NEI 16-06. The NRC staff concern is that over-crediting FLEX in the PRA model could underestimate the potential benefit of SAMAs.
Address the following:
i.
Describe the FLEX strategies that were credited in the PRA models (internal events, including internal flooding, and seismic). Include identification of discussion of the FLEX equipment that was credited and whether that equipment is portable or permanently installed and identification of the operator actions that are credited.
ii.
Identify the NRC memorandum that are applicable to the modeling of FLEX in the Perry Plant PRA model and explain how each of the 13 NRC staff conclusions are addressed in the PRA.
iii.
If the FLEX modeling is not in accordance with the applicable NRC memorandum, describe and provide the results of a sensitivity study that assesses the impact on the SAMA analysis of not crediting FLEX strategies.
e.
Provide a breakdown of the contribution to internal events, including internal flooding, core damage frequency (CDF) by initiating events. Confirm that the total CDF is the same as that reported in the ER. Additionally, provide the contribution to CDF from station blackout events and anticipated transients without scram (ATWS) events.
f.
Identify any changes that have been made to the Perry Plant model used in the SAMA analysis (Model PRA-PY1-AL-R01) since the F&O closure review that would constitute an upgrade as defined by ASME/ANS RA-Sa-2009, as endorsed by RG 1.200, Revision 2. If there are any identified upgrades, discuss the significance of these changes to the SAMA analysis.
g.
Discuss if there have been any major plant modifications or plant changes since the release of the PRA model of record PRA-PY1-AL-R01 used in the SAMA analysis and the impact of these modifications/changes on the SAMA analysis. Also discuss
18 if there are any planned major plant modifications or changes that could adversely impact the SAMA analysis and assess the impact of these modification/changes on the SAMA analysis.
SAMA-2 Provide the following information relative to the Level 2 PRA analysis. The basis for this request is as follows: applicants for license renewal are required by 10 CFR 51.53(c)(3)(ii)(L) to consider SAMAs if not previously considered in an environmental impact assessment, related supplement, or environmental assessment for the plant. As part of its review of the Perry Plant SAMA analysis, the NRC staff evaluates the applicants treatment of accident propagation and radionuclide release in the Level 2 PRA model. The requested information is needed in order for the NRC staff to reach a conclusion on the adequacy of the applicants Level 2 PRA model for supporting the SAMA evaluation.
a.
Section G.1.3 summarizes the PRA model development and peer review process, which for the Level 2 analysis only addresses (partially) large early release. The ER provides no description of the Level 2 analysis that was developed and applied to produce the results for the containment event tree (CET) end points or source term categories and release categories reported in the ER. Address the following:
i.
Explain how the Level 2 post-core damage accident response analysis is linked to the Level 1 PRA model, including addressing how the Level 1 core damage sequences were binned into plant damage states (PDSs),
describing each of the PDSs, and providing the results of this binning process.
ii.
Summarize the CET(s) developed to produce results for each of the CET end states or source term categories (STCs) reported in the ER and the process for progressing each PDS through the CET(s). Include in the response a description of the modeled branch points (both system failures and phenomenological).
iii.
Provide the modular accident analysis program (MAAP) radioisotope groupings, MACCSs radioisotope groupings, and the mapping of the MAAP groupings to the MACCS groupings. In the response, identify the version of MAAP used in the Level 2 analysis and, if an outdated version, discuss the impact on the SAMA analysis of software revisions.
iv.
Table G1.4-9 identifies 10 release categories and the source term categories binned into each. Define each of the release categories in terms of the characteristics (e.g., timing and magnitude of release) that are used to perform the binning and justify that the binning is reasonable. In the response, provide the basis for why three of the release categories are not used.
v.
Describe the logic used in the selection of the representative MAAP case for each release category, or source term category, and provide justification that the selected cases are reasonable for the SAMA analysis (e.g., does not underestimate the estimated benefits of SAMAs).
vi.
Summarize the independent and/or peer reviews performed to provide confidence in the Level 2 analysis, summarize the results of these reviews, and summarize any unresolved independent/peer review comments and
19 their impact on the SAMA analysis.
vii.
Table G1.3-1 reports a total large early release frequency (LERF) of 9.73E-06 per year for the PRA-PY1-AL-R01 PRA model used in the SAMA analysis, which includes internal events, including internal flooding, and seismic events. As a comparison, table G2-2 reports a total LERF of 5.38E-06 per year from the Level 2 analysis developed for the SAMA analysis.
Explain the reasons for this difference and provide an assessment of the impact of this difference on the SAMA analysis.
b.
STCs 3, 7, 8, 19, 20, and 29 are for gross failures of containment at the anchor bolts while STCs 5, 6, 14, 15, 16, 17, 18, 21, 22, 23, 24, 30, 31, and 32 are for gross failures at either a penetration or at the containment dome. Briefly discuss the analysis of containment integrity that led to these STC assignments and how this was modeled in the Level 2 PRA. Include in the discussion how it is determined if there was a containment penetration failure or a containment dome failure and the basis for this determination.
c.
Page G-48 states that population dose risk and offsite economic risk were calculated by summing the products of population dose and frequency, and offsite economic cost and frequency, respectively, for STCs 1 through 32. Provide the frequencies for each STC or CET end point. If the sum of the frequencies for all source term categories does not equal the total CDF reported in table G2-2, provide an explanation for this difference and justification that it does not impact the SAMA analysis.
d.
Table G1.4-6 explains that STC-4 is for intact containment scenarios and that fission product release is from normal containment leakage. Table G1.4-5 shows that 100 percent of the nobble gases (Kr/Xe) are released for STC-4, which implies no mitigation or fission product scrubbing is credited. Table G1.4-6 identifies STC-6 and STC-32 as having unmitigated releases, yet Table G1.4-5 shows that the nobble gas release fractions are less than 100 percent and that the release fractions for other fission products (e.g., Cs) are less than for STC-4. Discuss the modeling of these cases and explain these results. Provide an assessment of the impact on the SAMA analysis if this modeling cannot be justified.
e.
Table G1.4-7 states that the MAAP runs were limited to a maximum plume duration of one day (88,400 seconds). Identify the source term categories in which the release fractions have not plateaued and are still increasing by the end of the MAAP run time. For each of these source term categories, identify those in which the MAAP run times are less than 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> after the time of declaration of general emergency. For each of the identified source term categories, provide an assessment of the impact on the SAMA analysis from extending the run time to 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> after declaration of a general emergency.
f.
Page G-47 states: Qualitative means were used for assessing PDS 4, as MAAP calculations are not available for this PDS, since MAAP has inadequacies with simulating these ATWS scenarios. Note 1 to table G1.4-5 explains that the ATWS scenarios STC-29, STC-30, STC-31, and STC-32 are modeled using the surrogate MAAP cases for STC-3, STC-5, STC-5, and STC-6, respectively. Discuss the qualitative assessment that was performed and the basis for the selection of the surrogate STCs and provide justification that the assigned surrogates are reasonable for the SAMA analysis (e.g., does not underestimate the estimated
20 benefits of SAMAs).
g.
Tables G1.4-10 and G1.4-11 provide the MACCS2 results for each of the release categories. Address the following with respect to the results in this table:
i.
The break outside containment release category shows zero population dose risk and zero economic cost risk because the internal events, including internal flooding, and seismic CDFs are zero. However, estimates of population dose (person rem) and offsite economic cost are provided for both hazards. Explain why there are no CDFs for this release category.
ii.
Estimates of population dose (person rem) and offsite economic cost are provided for both hazards for the M/L release category, yet the estimates of population dose risk and economic cost risk are zero because the CDFs are zero. However, Table G1.4-9 explains that the M/L release category is not used. Clarify this anomaly between the two tables and, if this release category is used, explain why there are no CDFs for this release category.
SAMA-3 Provide the following information with regard to the treatment and inclusion of external events in the SAMA analysis. The basis for this request is as follows: Applicants for license renewal are required by 10 CFR 51.53(c)(3)(ii)(L) to consider SAMAs if not previously considered in an environmental impact assessment, related supplement, or environmental assessment for the plant. As part of its review of the Perry Plant SAMA analysis, the NRC staff evaluates the applicants treatment of external events in the PRA models. The requested information is needed in order for the NRC staff to reach a conclusion on the sufficiency of the applicants PRA models for supporting the SAMA evaluation.
a.
Section G.1.2 explains that the Perry Plant PRA Level 1 and Level 2 model includes seismic events. Address the following with respect to the seismic analysis:
i.
In response to NRC information requests to address near-term task force recommendations following the accident at the Fukushima Daiichi Nuclear Power Plant, and in response to Generic Issue (GI)-199, new seismic hazard curves have been developed for each nuclear power plant site.
Provide these updated seismic hazard curves for the Perry Plant site and discuss if these updated seismic hazard curves are incorporated in the Perry Plant seismic PRA model. If not, provide an assessment of the impact of this updated information on the SAMA analysis.
ii.
Table G2-2 reports a seismic CDF and seismic LERF of 1.46E-05 per year and 5.19E-06 per year, respectively, based on using a truncation of 2.0E-10 per year. Provide justification that this truncation level is sufficiently low to show convergence or stable results, and that truncation does not distort the seismic CDF and seismic LERF results or the delineation and ranking of seismic-induced sequences. Additionally, provide justification that the convergence criterion does not impact the SAMA analysis.
iii.
Provide a breakdown of the contribution to seismic CDF by initiating events and provide a description of the dominant initiating events. Confirm that the total seismic CDF is the same as that reported in the ER.
b.
Section G.1.2 explains that the Perry Plant IPEEE utilized the FIVE methodology to
21 assess fire risk and that the resultant fire CDF estimated using this methodology is 3.1E-05 per year. Both Section G.1.2 and table 4.15-2 explain that fire risk was not addressed in the SAMA assessment. Address the following with respect to the fire analysis:
i.
Provide a breakdown of the contribution to the Perry Plant individual plant examination for external events (IPEEE) fire CDF by initiating events and provide a description of the dominant initiating events.
ii.
The IPEEE fire CDF is significantly higher than the internal events, including internal flooding, CDF and about twice the seismic CDF yet the contribution from fire events is not included in the assessment of the benefits of each SAMA. This results in a potential significant underestimate of the calculated benefits of each SAMA. Provide a revised SAMA analysis that explicitly accounts (e.g., external events multiplier) for the contribution to the calculated benefits of each SAMA from the potential reduction in fire risk.
c.
Section G.1.2 explains that other external events such as high winds, floods, aircraft accidents, hazardous materials, and turbine missiles were assessed in the PNPP IPEEE and that there are no significant events of concern. However, the ER provides no evaluation of relevant plant-specific assessments that have been conducted since the IPEEE. Address the following:
i.
Summarize the screening assessment in the IPEEE that addresses these other external hazards and which was used as the basis for the ER conclusion. In the response, discuss the screening criteria used in the IPEEE and its applicability to the SAMA analysis, and, specifically, whether changes to the plant, the plant site, or the area surrounding the plant site made since the IPEEE have impacted the conclusions of the IPEEE.
ii.
Following the accident at the Fukushima Dai-ichi nuclear power plant, Energy Harbor (formerly FirstEnergy Nuclear Operating Company) responded to an NRC 10 CFR 50.54(f) request for information. This response included a reevaluation of the external flood hazards, the development of mitigating strategies for external floods, and a focused evaluation of the external flooding mechanisms for which the reevaluated flooding hazards is not bounded by the current design basis. Energy Harbor's mitigation strategies assessment (MSA) included addressing the following flood mechanisms: probable maximum storm surge, SRF, and LIP (ML19323F020). This focused evaluation was a deterministic (that is, not a probabilistic) evaluation. Provide a discussion of these external flood hazards and the associated impact on PNPP to support the conclusion that they would not impact the SAMA analysis, such as not contributing to an external events multiplier nor leading to any cost-beneficial SAMAs. In the response address the status of implementation of the flooding mitigation strategies identified in the MSA and its impact on the SAMA analysis.
iii.
NRC RIS 2015-06, while not requiring regulatory action, identified several instances in which nuclear power plants were determined to not conform with their tornado-generated missile licensing basis. Discuss any changes to the Perry Plant site or surrounding environment or to Perry Plant that would change the conclusions of the IPEEE regarding tornado-generated missiles and which could impact the SAMA analysis.
22 SAMA-4 Please provide the following information regarding the Level 3 PRA used in the SAMA analysis. The basis for this request is as follows: applicants for license renewal are required by 10 CFR 51.53(c)(3)(ii)(L) to consider SAMAs, if not previously considered, in an environmental impact assessment, related supplement, or environmental assessment for the plant. As part of its review of the Perry Plant SAMA analyses, NRC staff evaluates the applicant's analysis of accident consequences in the Level 3 PRA.
The requested information is needed in order for the NRC staff to reach a conclusion on the sufficiency of the applicant's Level 3 PRA model for supporting the SAMA evaluations.
a.
Tables G1.4-13 and G1.4-14 provide the results for total population dose and total offsite economic costs, respectively, of several sensitivity analyses on Level 2 and Level 3 analysis parameter assumptions. For Case 10, the increase in total population dose is reported to be 5.9 percent and the increase in total offsite economic costs is reported to be 74.1 percent. Provide the corresponding results for population dose risk, offsite economic cost risk, and maximum benefit and discuss the impact of these results on the SAMA cost-benefit evaluation.
b.
Table G1.4-4 provides the estimated core inventory input to the Level 3 analysis.
Clarify whether adjustments of the core inventory values are necessary to account for differences between fuel cycles expected during the period of extended operation and the fuel cycle upon which the Level 3 analysis is based (e.g., to account for any changes in future planned fuel management practices or fuel design).
c.
Section G.1.4.2.6 indicates that meteorological data for the years 2019 through 2021 were used in the consequence analysis. Specify the sources of the data and, if the plant meteorological tower data was not used, provide justification not using it.
Discuss how data from this data set (e.g., temperature, wind speed, wind direction, precipitation) were selected as input to the MACCS code and explain why the selected data is reasonable for the SAMA analysis (e.g., does not underestimate the estimated benefits of SAMAs), or alternatively provide the results of a sensitivity analysis. Discuss the extent to which there was missing data and how missing data was accounted for in the SAMA evaluation.
d.
Section G.1.4.2.1 identifies the Ohio Department of Development (OHDD, 2022) and the Center for Rural Pennsylvania (CRPA, 2022) as the sources for the population projection to the year 2046. A review of this data indicates the population for most counties surrounding the Perry Plant decline between 2020 and 2050, and for some counties the decline is substantial. Because the proposed period of extended operation for Perry Plant is from 2026 to 2046, using the projected population in 2046 may underestimate the estimated benefits of SAMAs during the early years of the extended operating period. Discuss the impact of this potential non-conservatism on the SAMA evaluation.
e.
Section G.1.4.2.1 states that transient population was not included in the SAMA evaluation because it was assumed to be negligible. Discuss the impact on the SAMA evaluation of this non-conservative assumption.
f.
Table G1.4-2 provides the values of evacuation, relocation, and decontamination costs used in the WinMACCS code used for the SAMA evaluation. The recommended values for use in the MACCS code were updated to current year
23 dollars based on the consumer price index. The technical bases for the recommended MACCS values date back to NUREG-1150 and earlier. Recently Sandia National Laboratories has developed an updated technical basis and recommended values for these parameters for use in analyses using the MACCS code (NUREG/CR-7270). In many cases the recommended updated values are significantly greater than those used in the PNPP SAMA analysis. For example, the MACCS parameter EVACST value used in the PNPP SAMA analysis is
$66.7/person-day (2021 dollars) while the recommended value in NUREG/CR-7270 is $230/person-day (2018 dollars). Provide an assessment of the impact of the NUREG/CR-7270 technical bases/recommendations on the SAMA evaluation.
SAMA-5 Provide the following information with regard to the selection and screening of Phase I SAMA candidates. The basis for this request is as follows: applicants for license renewal are required by 10 CFR 51.53(c)(3)(ii)(L) to consider SAMAs if not previously considered in an environmental impact assessment, related supplement, or environmental assessment for the plant. As part of its review of the Perry Plant SAMA analysis, the NRC staff evaluates the applicants basis for the selection and screening Phase I SAMA candidates. The requested information is needed in order for the NRC staff to reach a conclusion on the adequacy of the applicants Phase I SAMA selection and screening process for the SAMA evaluation.
a.
Section G.2.1 explains that the source of the 157 identified Phase I SAMA candidates were the NUREG-1437 supplements for other plants (129 SAMA candidates) and PNPP-specific assessments (28 SAMA candidates). Address the following with regards to the SAMA identification process:
i.
Provide the complete list of 157 Phase I SAMA candidates and identify the reference source(s) and/or identification basis for each.
ii.
The ER does not explain how the selected set of Phase I SAMA candidates address or mitigate the major risk contributors in the Level 1 (i.e., CDF) and Level 2 PRA analysis. Provide the following:
1.
A description of how the dominant risk contributors at Perry Plant, including dominant sequences and cutsets from the PRA (e.g.,
equipment failures, operator actions, initiators, phenomenology) identified through importance analyses, were used to identify potential plant specific SAMAs for Perry Plant; define and justify the rationale for the cutoff value used to determine what is a dominant risk contributor, 2.
A listing and description of equipment failures and human actions (including probability and risk reduction worth for each) that have the greatest potential for reducing risk at PNPP based on importance analysis and cutset screening, and 3.
For each dominant contributor identified in the previous bullet, provide a cross-reference to the Phase I SAMA(s) evaluated in the ER that address that contributor, and 4.
If a SAMA candidate was not identified for a dominant risk contributor, justify why SAMAs to reduce the risk of this contributor are not considered.
24 iii.
Section 4.15.3.1 explains that the initial listing of potential SAMAs was developed using, in part, available generic industry identification of SAMAs.
The cited reference for the generic industry SAMAs is Section C.1.4 of NUREG-1437, Revision 0. This reference does not identify potential SAMA candidates. Address the following:
1.
Explain how Section C.1.4 of NUREG-1437, Revision 0, was used to identify generic industry SAMAs and provide the identified SAMA candidates developed from this reference.
2.
Explain how the list of generic BWR enhancements identified in NEI 05-01, Rev. A was considered in the identification of Phase I SAMA candidates. If not considered, provide an assessment of the applicability of these generic enhancements to Perry Plant, including the results of a Phase I and Phase II SAMA analysis as applicable.
iv.
Based on the Phase I SAMA identification process described in the ER, risk insights and potential plant improvements from the PNPP Individual Plant Examination (IPE) and IPEEE were not fully considered. For example, several potential plant improvements were identified in the IPE submittal to NRC (ML20102A255) and in the IPEEE submittal to NRC (ML20115J969).
Additionally, while the IPEEE did not identify any fire-related plant improvements, it did identify several risk-significant fire areas/compartments (i.e., those that exceeded the fire CDF screening criteria of 1.0E-06 per year). Provide the following:
1.
An assessment of the insights and potential plant improvements from the Perry Plant IPE and IPEEE and disposition these for the SAMA analysis, 2.
Identify and describe the new Phase I SAMA candidates (e.g., those that mitigate fire risk, those from the IPE and IPEEE that have not been implemented) generated from this assessment, 3.
Explicitly address a SAMA to install incipient detection and/or suppression in the Division 2 Switchgear Room and Main Control Room and a SAMA to upgrade the alternate shutdown panel(s) to include additional system controls, and 4.
As applicable, provide a description of and results for a Phase I and Phase II SAMA assessment of each new Phase I SAMA candidate.
b.
For each of the Phase I SAMA candidates, provide the screening criteria and basis for those that were screened in the Phase I analysis.
c.
Section G.2.3 explains that the Phase I SAMA screening process used 50% of the maximum benefit when screening on excess implementation costs. This is stated to be based on a review of the risk contributions for CDF and LERF from any single SAMA. The NRC staff has concerns with this approach because detailed benefit analysis is not performed on all Phase I SAMA candidates. According to Table G2-5, the Phase I SAMA candidates that were screened using the 50% maximum benefit, but which would not have screened using the maximum benefit, are SAMA
25 6, Install Curbs for Switchgear Rooms, and SAMA 7, Enhance DC Power for Internal Flooding. Address the following:
i.
Describe the review process used to make the determination that no single SAMA would be expected to result in a 50 percent risk reduction. Justify that this process considered the major risk contributors to the Level 1 CDF and Level 2 PRA analysis (see RAI 5.a.ii).
ii.
If the use of 50 percent of the maximum benefit cannot be justified, provide a Phase II assessment for SAMA 6 and SAMA 7.
d.
Table G2-5 identifies SAMA 5, Install Flood Doors for Switchgear Rooms, as having a maximum benefit that exceeds the estimated implementation cost and so it is specified to be retained for the Phase II assessment. However, table G2-6 determines the final outcome of the screening analyses is to screen this SAMA.
The reason given is that it has a negative cost benefit based on implementation cost and maximum benefit, which is contradictory to the cost-benefit results reported in Table G2-5. Justify the screening of SAMA 5 or provide a Phase II assessment for this SAMA.
e.
Table G2-5 identifies SAMA 14, Add Alternative Containment Spray (L2 only), as having a maximum benefit that exceeds the estimated implementation cost and so it is specified to be retained for the Phase II assessment. However, table G2-6 determines the final outcome of the screening analyses is to screen this SAMA based on a qualitative assessment that it would have negligible/limited benefits. It is unclear to the NRC staff that this is the case, especially if uncertainties/sensitivities are considered. Provide further justification for the screening of SAMA 14 or provide a Phase II assessment for this SAMA.
f.
Table G2-5 provides the estimated implementation cost for each SAMA candidate that was not previously screened in the SAMA analysis. Describe the cost estimating process and bases used to develop the implementation cost estimate for each SAMA candidate, including specifying what costs are included in the estimate (e.g., procurement, installation). Additionally, discuss any conservatisms in the cost estimates (e.g., cost estimate did not include the cost of replacement power during extended outages required to implement the modifications, cost estimate did not include contingency costs associated with unforeseen implementation obstacles).
SAMA-6 Provide the following information with regard to the Phase II cost-benefit evaluations.
The basis for this request is as follows: applicants for license renewal are required by 10 CFR 51.53(c)(3)(ii)(L) to consider SAMAs if not previously considered in an environmental impact assessment, related supplement, or environmental assessment for the plant. As part of its review of the Perry Plant SAMA analysis, NRC staff evaluates the applicants costbenefit analysis of Phase II SAMAs. The requested information is needed in order for the NRC staff to reach a conclusion on the acceptability of the applicants cost estimations for individual SAMAs and costbenefit evaluation.
a.
Section G.3 indicates that the conversion factor for assigning monetary value to on-site and off-site exposures used in the SAMA analysis is $2,000 per person-rem.
While this value is used in the NEI 05-01, Revision A, guidance, its basis is from NUREG-1530 (ADAMS Accession Number ML063470485). NUREG-1530, Reassessment of NRCs Dollar Per Person-Rem Conversion Factor Policy, was
26 updated to Revision 1 in 2022 (ML22053A025). The dollar per person-rem conversion factor from this updated NUREG is to be used in regulatory applications that require the determination of the monetary valuation of the consequences associated with radiological exposures, including SAMA assessments associated with environmental analyses. Section 6 of NUREG-1530, Revision 1, provides a best estimate value, low value, and high value in 2014 dollars and specifies that sensitivity analyses should be performed to evaluate the impact of using this range of values. Section 7 of this NUREG provides the method that is to be used to update the dollar per person-rem conversion factor from 2014 to current year dollars. Discuss the impact on the Phase I and Phase II SAMA evaluation from applying the NUREG-1530, Revision 1, guidance.
b.
The Phase II evaluations of SAMA 11, Add Alternate Emergency Diesel Generator Room Cooling, and SAMA 17, Increase Capacity of Relays, reported in Section G.2.4.1 and G.2.4.2, respectively, only provide the results by release category for CDF and population dose risk. Provide the similar results for offsite economic cost risk.
c.
Section G.3.3.3 on total averted occupational exposure costs and Section G.3.4 on averted onsite costs state that the estimates of these parameters include consideration of at-power internal events, internal flooding events, and fires, along with low-power shutdown (LPSD) internal events, internal flooding events, and fire events. Clarify this statement and explain how fire events and LPSD events are explicitly considered in the determination of SAMA benefits.
d.
Section G.3 indicates that the SAMA analysis was performed assuming a 7 percent discount rate. NEI 05-01, Revision A, specifies that a sensitivity analysis should be performed assuming a 3 percent discount rate. This NEI 05-01 guidance reflects NRC guidance in Section 4.3.5 of NUREG/BR-0058, Revision 4 (ML042820192),
which reflects guidance provided in Office of Management and Budget Circular A-4 on regulatory analysis (https://obamawhitehouse.archives.gov/omb/circulars_a004_a-4/). Discuss the impact on the Phase I and Phase II SAMA evaluation from assuming a 3 percent discount rate.
e.
NEI 05-01, Revision A, specifies that a sensitivity analysis is to be performed that assesses the impact of PRA model uncertainties on the SAMA analysis. While Section G.1.4.3 of the ER discusses the assessments and results of several sensitivity analysis cases on WinMACCS input parameters, a sensitivity analysis is not provided in the ER that addresses PRA model uncertainties. For this sensitivity analysis, NEI 05-01, Revision A, specifies the development of an uncertainty factor derived from the ratio of the 95th percentile to the mean estimate for internal events CDF and multiplying this ratio by the base case benefit results. Discuss the impact on the Phase I and Phase II SAMA evaluation from consideration of CDF uncertainty. In the response provide the 5th, 95th, mean, and median results of the internal events, including internal flooding, CDF, and the seismic CDF.
SAMA-7 For certain SAMAs considered in the Perry Plant Environmental Report, there may be lower cost or more effective alternatives that could achieve much of the risk reduction.
In this regard, provide an evaluation of the following SAMA. The basis for this request is as follows: applicants for license renewal are required by 10 CFR 51.53(c)(3)(ii)(L) to consider SAMAs if not previously considered in an environmental impact assessment, related supplement, or environmental assessment for the plant. As part of its review of
27 the Perry Plant SAMA analysis, the NRC staff considers additional SAMAs that may be more effective or have lower implementation costs than the other SAMAs evaluated by the applicant. The requested information is needed in order for the NRC staff to reach a conclusion on the adequacy of the applicants determination of costbeneficial SAMAs.
a.
SAMA 2, Automate Suppression Pool Cooling, and SAMA 16, Automate Standby Liquid Control, each involve major new systems to presumably mitigate failure of operator actions by automating system initiation. Describe the events that these SAMAs mitigate and discuss the possibility of lower cost alternatives such as:
simpler hardware changes and/or procedure and training improvements.
b.
All the identified SAMAs involve procurement and installation of major new systems and none of the SAMAs consider procedure and training improvements that is typically a much lower cost alternative. Discuss the possibility of SAMAs to improve procedure and training improvements.
Document Needs SAMA-8 The most recent PRA peer review reports, and/or self-assessment reports, and F&O closure review reports for all hazards (i.e., internal events, including internal flooding, and seismic).
SAMA-9 Documentation associated with the Level 2 and 3 PRA model reviews.
SAMA-10 Available documentation of the review of the results of the Perry Plant Level 2 PRA by the team of Perry Plant experts representing various site organizations (e.g.
Operations, System Engineering, Mechanical/Safety Analysis, PRA and License Renewal) to confirm that the model is representative of the plant and the results are reasonable.
SAMA-11 PRA notebooks for Model PRA-PY1-AL-R01 used in the SAMA analysis that document the quantification results and which provide the breakdown of the contributors to CDF.
SAMA-12 Documentation of the CETs developed to produce results for each of the CET end states or STCs reported in the ER.
SAMA-13 Documentation of the Level 3 analysis and the core inventory.
SAMA-14 Documentation of the identification and disposition of SAMAs identified from the review of SAMAs from other SAMA analyses and from other sources.
Replacement Power Alternatives (Jeff Rikhoff, Dave Goodman)
Audit Needs ALT-1 Section 7.2.2.4 of the ER eliminates a new nuclear (e.g., small modular reactor [SMR])
alternative from detailed analysis. Please provide additional information as to why a new nuclear SMR alternative was determined not to be feasible for detailed analysis.
ALT-2 Section 7.2.2.7 of the ER eliminates a completely renewable combination alternative from detailed analysis. Please provide additional information as to why a completely
28 renewable energy combination alternative was determined not to be feasible for detailed analysis.
ALT-3 Section 7.2.3.2 of the ER states that six 125 megawatt (MW) solar installations would be constructed, along with battery storage to produce baseload electricity. Please identify how much battery storage (if any) would be needed to support the six 125 MW solar installations in the Renewable and Natural Gas Combination alternative.
ALT-4 Throughout Section 7 of the ER, replacement energy alternatives to the proposed action are limited to being located within the state of Ohio. Please explain why replacement energy alternatives are limited to Ohio. Would other locations outside of Ohio work for replacement energy alternatives if Perry were closed?
ALT-5 Section 7.2.3.1 of the ER states that a replacement energy natural gas-fired power plant would be located at the PNPP site. Could a replacement energy natural gas-fired power plant be located elsewhere (e.g., at another existing power plant site)? If so, where might it be located?
Document Needs None Socioeconomics (Leah Parks, Jeff Rikhoff)
Audit Needs SOC1 Table 3.92 in the ER shows Perry Plants property tax payments to Lake County Tax Jurisdiction from 20172021. If the information is available at this time, please provide Perry Plants 2022 property tax payment.
SOC-2 Section 3.9.5 of the ER states that new annual lease payments (anticipated to be in the range of $50,000-75,000 per year during the full period of extended operation) to the State of Ohio for a reissued Halite Non-Extraction Lease agreement to protect the Lake Erie intake and discharge tunnel lakebed area from subsidence began in 2022. Please explain the history and circumstances that causes these annual lease payments and any other additional information about its origin and duration, if available.
SOC-3 Section 3.9.6 describes the Ohio Department of Transportation (ODOT) the rehabilitation of US 20/North Ridge project involving minor widening and drainage replacement. The ODOT website denotes the construction period for this project as beginning in Fall 2023 and ending in Fall 2028. Please be prepared to discuss the status of the road-widening project and whether there are plans to address potential site access issues during outages.
Document Needs None
29 Spent Nuclear Fuel (Leah Parks, Beth Alferink)
Audit Needs None Document Needs None Surface Water Resources (Lloyd Desotell/Rajiv Pasad)
Audit Needs SW-1 Please describe the difference between the United States Geological Survey datum and mean sea level; both are used in ER Section 3.6.1.
SW-2 ER Section 3.7.3, Table 9.1-1, and Attachment B mention that the current NPDES permit had an expiration date of February 28, 2023. Was a renewal application submitted to the Ohio Environmental Protection Agency? If yes, please provide documentation.
Document Needs SW-3 2022 and 2023 annual water withdrawal reports submitted to the Ohio Department of Natural Resources Division of Water Resources.
SW-4 Stormwater Pollution Prevention Plan SW-5 Spill Prevention, Control, and Countermeasure Plan Termination of Operations and Decommissioning (Beth Alferink)
Audit Needs DECOM-1 As part of the review and response to WM-7, please review the impacts on Termination of Operations and Decommissioning.
Document Needs None Terrestrial Resources (Caroline Hsu)
Audit Needs TER-1 Section 3.7.2.6 of the ER states that Energy Harbor maintains records of bird mortality and nesting within the Perry Plant site and that there were seven condition reports
30 related to bird mortality and nesting between 2017-2021. Please provide all condition reports for bird mortality and nesting from 2013-2023 (to present). For bird mortality and injuries, please summarize such incidents by date, species, counts, cause, and infrastructure if relevant (e.g., cooling towers, buildings, transmission or distribution lines, meteorological towers, screens, etc.).
TER-2 Section 3.3.7.2 of the ER states the following: 1) Perry Plant has no site-specific avian plans or mitigation measures, 2) Energy Harbors corporate environmental avian subject matter expert is notified for identification and handling for events related to bird mortality and nesting, 3) Ohio Department of Natural Resources is then notified for recommendation for further action if a bird is state and/or federally listed, and 4) removal of a nest from plant structures follow procedures outlined in the plant administrative procedures. Section 3.7.6 mentions bird nest removal. Section 9.5.6 states that Perry Plant adheres to the Migratory Bird Treaty Act (MBTA) and does not currently hold any MBTA-related permits.
Please clarify the following: 1) does Energy Harbor have a federal migratory bird special utility permit, eagle permit, or any other migratory bird permit from the US Fish and Wildlife Service (FWS)? 2) are migratory bird injuries or mortality incidents reported to FWS?
Please provide 2013-2023 documentation relating to PNPP migratory bird handling and nest removal if not already covered under TER-1 or TER-2.
TER-3 Section 3.7.2.6 of the ER presents contradictory information about vegetation management under in-scope transmission lines in the paragraph. Sentence 3 of this paragraph states the following: There are no site-specific procedures regarding maintenance of vegetation under the in-scope transmission lines at the PNPP [Perry Plant] site. Sentence 7 of same paragraph states the following: PNPP [Perry Plant] has site-specific procedures for the application of herbicides and pesticides to control vegetation under in-scope transmission lines.
Please clarify whether Perry Plant has site specific procedures for controlling vegetation, whether those procedures include herbicide and pesticide application and whether those only apply to in-scope transmission lines. Provide any site-specific, vegetation management protocols. If herbicides or pesticides are used, please provide formulation, application information, and BMPs if not already covered under TER-1.
TER-4 Section 3.3.7.2 of the ER states that Perry Plant has no site-specific bat protection plans or mitigation measures in place for Perry Plant. Does Energy Harbor have any bat injury or mortality records from 2013-present? If so, please provide. Does Energy Harbor have any avian surveys or bat surveys from within the last 5 years? If so, please provide.
TER-5 Birds and bats can collide with communication towers, including meteorological towers.
Collision rates are influenced by height, lighting regime, and whether the tower is guyed or freestanding. Section 2.2.4 of the ER states that Perry Plant has one 60m, guyed meteorological tower, but does not state that whether tower is unlit or lit. Please confirm that the meteorological tower is 60m above ground level and guyed. If lit, please state lighting colors and whether lights are steady or blinking.
Document Needs
31 TER-6 Section 3.7.6 of the ER states that Perry Plant relies on administrative controls and other regulatory programs to ensure habitats and wildlife are protected. Section 3.7.7 states that Energy Harbor maintains an Environmental Protection Plan. Please provide a copy of relevant administrative control documents and BMPs relating to protection of habitats and species, including storm water management, spill prevention, bird nest removal, and pesticide applications (herbicide, insecticide, rodenticide, fungicide). Also, please provide the Environmental Protection Plan.
TER-7 Section 3.7.7.3 states that annual vegetation and wetland monitoring is conducted at Perry Plant following a stream relocation project in 2015. Please provide the monitoring reports for this stream restoration site.
Uranium Fuel Cycle (Beth Alferink)
Audit Needs None Document Needs None Waste Management (Leah Parks, Beth Alferink)
Audit Needs WM-1 As part of the effluent control systems, please plan to discuss the provisions made to sample and analyze fluids before discharge as discussed in 2.2.6.1. Please plan to discuss how the plant processes radioactive effluents to maintain radiation doses to the public to levels that are ALARA. Additionally, if there are there any proposed changes or upgrades to the program being considered during the license renewal term, please be prepared to discuss them.
WM-2 Section 2.2.6.6 notes that Perry Plant is an infrequent and episodic generator of mixed waste and if generated, low-level mixed waste is stored in the service building hot shop until disposed. However, Perry Plant does not currently have any mixed waste stored onsite. Are any other wastes besides mixed waste stored in this location? What are the plans and procedures associated with long-term storage of mixed waste?
WM-3 Section 2.2.6.5 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 (e.g., are there minimum quantity shipment plans or procedures for decision making)? In addition, please 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). Additionally, if there are any proposed changes or upgrades to the program being considered during the license renewal term, please be prepared to
32 discuss them.
WM-4 Perry Plant 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. In Section 9.5.3.6 of the ER, the applicant discusses reportable spills and states that for the period of 2017-2021, there were no reportable releases at Perry Plant that have triggered this notification requirement. If there have been any reportable releases which would trigger this notification requirement since the ER was written, please provide a description of the releases.
WM-5 If there have been any reportable unplanned releases of radioactive materials (unplanned/inadvertent radioactive liquid or gaseous releases) which would trigger a notification requirement or have been released to the underdrain or groundwater 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.
WM-6 If there have been any reportable inadvertent releases or spills of nonradioactive contaminants 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.
WM-7 Please have the Chemistry Superintendent available to discuss the Emergency Service Water silt/sediment that has been stored in the onsite chemical lagoon and the Unit 2 Cooling Water suction bay. This discussion should also include the need for future silt/sediment storage, sampling requirements or plans, and potential future locations of silt/sediment storage. (Also noted as DECOM-1)
Document Needs WM-8 Please provide procedures related to the radioactive and nonradioactive Waste Management Program, Waste Minimization Program, and Stormwater Pollution Prevention Plan.
WM-9 Drawings and photos that are highlighted/marked showing the flow paths for releases for both radiological and non-radiological waste paths. Please have subject matter experts available to discuss the flow paths.
WM-10 Please provide the log of approved waste vendors used to manage and dispose of hazardous and non-hazardous waste as discussed in Section 2.2.7 of the ER.
Perry Nuclear Power Plant, Unit 1 Environmental Audit Schedule Monday, January 22, 2024 START END ACTIVITY 9:00 am ET 9:30 am ET Entrance meeting between U.S. Nuclear Regulatory Commission (NRC), Energy Harbor and contractors 9:30 am ET 4:00 pm ET Virtual tours/virtual meetings between NRC, Energy Harbor, and contractor subject matter experts (SMEs)
Tuesday, January 23, 2024 START END ACTIVITY 9:00 am ET 4:00 pm ET Virtual meetings between NRC, Energy Harbor, and contractor SMEs Wednesday, January 24, 2024 START END ACTIVITY 9:00 am ET 4:00 pm ET Virtual meetings between NRC, Energy Harbor, and contractor SMEs Thursday, January 25, 2024 START END ACTIVITY 9:00 am ET 4:00 pm ET Virtual meetings between NRC, Energy Harbor, and contractor SMEs Friday, January 26, 2024 START END ACTIVITY 9:00 am ET 12:00 pm ET Virtual meetings between NRC, Energy Harbor, and contractor SMEs Tuesday, January 30, 2024 START END ACTIVITY 9:00 am ET 4:00 pm ET NRC site visit Friday, February 2, 2024 START END ACTIVITY 11:00 am ET 11:30 am ET Exit meeting between NRC, Energy Harbor, and contractors