ML24295A118
| ML24295A118 | |
| Person / Time | |
|---|---|
| Site: | Point Beach  |
| Issue date: | 10/31/2024 |
| From: | Kevin Folk NRC/NMSS/DREFS/EPMB1 |
| To: | Mack K Florida Power & Light Co |
| References | |
| EPID L-2020-SLE-0002 | |
| Download: ML24295A118 (1) | |
Text
Enclosure 2 POINT BEACH NUCLEAR PLANT, UNITS 1 AND 2 SUBSEQUENT LICENSE RENEWAL APPLICATION ENVIRONMENTAL REVIEW SUPPLEMENTAL ENVIRONMENTAL AUDIT REQUESTS FOR CONFIRMATION OF INFORMATION Regulatory Basis The U.S. Nuclear Regulatory Commissions (NRC) regulations at Title 10 of the Code of Federal Regulations (10 CFR) Part 51, which implement Section 102(2) of the National Environmental Policy Act of 1969, as amended (NEPA), include requirements for applicants to provide information as may be useful in aiding the NRC staff in complying with NEPA. Licensees are required by 10 CFR 51.53(c)(1) to submit with its application a separate document entitled Applicant's Environmental ReportOperating License Renewal Stage.
As part of its environmental review, the NRC staff is required to prepare an environmental impact statement which, for reactor license renewal, is a supplement to NUREG-1437, Revision 2 Generic Environmental Impact Statement for License Renewal of Nuclear Plants (Agencywide Documents Access and Management System (ADAMS) ML24087A133). Review guidance for the staff is provided in NUREG-1555, Supplement 1, Revision 2, Standard Review Plans for Environmental Reviews for Nuclear Power Plants: Supplement 1 - Operating License Renewal (ML23201A227).
On August 6, 2024, the NRC published a final rule (89 FR 64166) revising its environmental protection regulations in 10 CFR 51, Environmental protection regulations for domestic licensing and related regulatory functions. The final rule updates the potential environmental impacts associated with the renewal of an operating license for a nuclear power plant for up to an additional 20 years, for either an initial license renewal or a single subsequent license renewal (SLR) term. Revision 2 to NUREG-1437 provides the technical basis for the final rule.
Consequently, the NRC staff will prepare a supplement to the 2021 draft supplemental environmental impact statement (SEIS) (ML21306A226) for the Point Beach SLR application in accordance with the NRC's regulations in 10 CFR 51.72.
Requests for Confirmation of Information (RCIs)
During the supplemental environmental audit, the NRC staff reviewed documents that were made available on the applicants (NextEra Energy Point Beach, LLC (NEPB)) electronic information portal in response to the staffs preliminary information needs (ML24256A140). The staff also participated in breakout sessions with applicant personnel to gather information that will likely be used in the supplement to the 2021 draft SEIS. To the best of the staffs knowledge, the information on the electronic portal and discussed in breakout sessions is not currently on the docket or publicly accessible. The NRC staff respectfully requests that the applicant provide confirmation that the information reviewed or discussed during the audit and listed below is correct or provides the associated corrected information.
1)
RCI ALT-1 As discussed during the virtual tour, confirm that (1) there have been no significant changes in the location of the Point Beach Solar installations since 2021, (2) Two Creek Solar became operational in November 2020, and (3) Point Beach Solar became operational in September 2021.
2 2)
RCI AQN-2 Confirm that on February 7, 2024, the Wisconsin Department of Natural Resources (WDNR) identified a deviation with respect to Point Beachs air pollution control permit that involved the use of an ASTM standard for the determination of sulfur content not listed in Point Beachs permit 436034500-P40 and that the deviation was resolved by implementing the use of one of the ASTM standards defined in the most recent air permit (436034500-P40) dated 04/12/2023.
Additionally, confirm that NEPB has not received any notices of violation or non-compliances associated with Point Beachs air permit since 2022.
3)
RCI NOI-1 Confirm that there have been no noise complaints regarding Point Beach operations since 2021.
4)
RCI NOI-2 Confirm that there have been no changes in primary noise sources at Point Beach from those identified in the Point Beach 2021 draft SEIS.
5)
RCI NOI-3 Confirm that there have been no changes to primary offsite noise sources in the vicinity of Point Beach from those identified in the Point Beach 2021 draft SEIS.
6)
RCI SW-1 Confirm that the listed monthly surface water withdrawals for Point Beach (for the period January-July 2024) are accurate as reported:
Month Volume (Million gallons per month)
January 2024 21,603 February 2024 20,210 March 2024 31,170 April 2024 33,132 May 2024 34,236 June 2024 33,132 July 2024 34,236 7)
RCI SW-2 As contained within the response to audit need GEN-2 and based on review of information during the audit, confirm the following regarding Wisconsin Pollutant Discharge Elimination System (WPDES) exceedances over the last 5 years: there were documented exceedances for total suspended solids in December 2020, January 2021 and January 2022 associated with turbidity in Lake Michigan; and one exceedance for biochemical oxygen demand in March 2023.
All exceedances were associated with the sewage treatment plant. These exceedances were
3 reported to WDNR and documented in discharge monitoring reports. NEPB has not received any notices of violation associated with Point Beachs WPDES permit over the last 5 years.
8)
RCI GW-1 Confirm that the listed monthly groundwater withdrawals for Point Beach (for the period January-July 2024) are accurate as reported:
Month EIC Well (gallons)
Main Well (gallons)
SBCC Well (gallons)
Warehouse 6 Well (gallons)
Warehouse 7 well (gallons)
Total (gallons)
Total (average gallons per minute)
January 2024 1,161 596,825 4,180 1,600 2,100 605,866 13.57 February 2024 1,632 372,200 4,539 1,500 2,100 381,971 9.15 March 2024 1,813 373,500 3,698 1,400 2,200 382,611 8.57 April 2024 2,750 345,300 3,588 1,600 2,100 355,338 8.23 May 2024 926 305,400 2,878 1,500 1,300 312,004 6.99 June 2024 1,577 411,300 3,284 1,400 400 417,961 9.68 July 2024 1,740 409,799 3,097 1,300 700 416,636 9.33 9)
RCI TER-1 Confirm the statement that NEPB is not aware of any wildlife or avian incidents, mortalities, injuries, nest relocations, or similar incidents that have occurred at Point Beach for the period 2019-2023 and that there have been no new wildlife or avian incidents since 2023.
10)
RCI HCR-1 As discussed during the audit, confirm the following statements. NextEra Energy, Inc./NEPB retained Commonwealth Heritage Group, Inc. (Commonwealth) to conduct a National Register of Historic Places (NRHP) eligibility determination for Point Beach. Commonwealth determined that Point Beach does not meet the criteria for listing on the NRHP. This determination of NRHP eligibility has not been reviewed by the Wisconsin State Historic Preservation Office. In addition, NEPB has not conducted Historic American Building Survey and Historic American Engineering Record eligibility determinations for Point Beach.
11)
RCI SOC-1 From information gathered during the audit (information need SOC-1), confirm that the following information for annual gross-receipts license fees (payable to the State of Wisconsin) on behalf of Point Beach for 2019-2023 are accurate:
4 Year Payment ($)
2019 8,027,489 2020 8,449,153 2021 8,883,078 2022 9,176,051 2023 9,703,433 12)
RCI HH-1 As discussed during the audit with respect to apparent changes in occupational exposure, confirm the following statement. The approximately 14 percent difference in occupational exposure occurred during 2019-2021 (presented in NUREG-0713, Vol 43) as compared to 2018-2020 (presented in NUREG-0713, Vol 42) for the following reasons: (1) there was an outage with additional Steam Generator and RTD work that was not performed during 2018-2020, and (2) a dry fuel campaign was performed in 2021 and was not performed during 2018-2020.
13)
RCI HH-2 Confirm the statement that NEPB plans no changes or future updates to Point Beachs safety program with respect to occupational and electrical safety.
14)
RCI HH-3 As discussed during the audit with respect to Point Beachs electrical safety program, confirm the following statements. NEPBs Electrical Safety Procedure does not reference or point to NESC (National Electrical Safety Code). However, the procedure points to Occupational Safety and Health Administration regulations.
15)
RCI WM-1 Confirm that the following statements are accurate. NEPB has documented two inadvertent radioactive liquid or gaseous releases since 2020. One abnormal liquid release occurred in 2021 when a Unit 1 hotwell containing tritium was discharged directly to circulating water on 8/2/2021, and an abnormal gaseous release occurred in July 2023. There have not been any other reportable unplanned releases of radioactive materials that would trigger a notification requirement from 2019-2023 and since the 2023 effluent report was written.
16)
RCI WM-2 Confirm that the following statements are accurate. NEPB has documented two reportable inadvertent nonradioactive releases since 2020. A reportable spill occurred in January 2021 when approximately eight gallons of diesel fuel was released due to a hose failure on a pickup truck. Information reviewed during the audit indicates that there have been no additional inadvertent nonradioactive releases that impacted soil or groundwater at Point Beach in 2020 through October 2023, and that no groundwater remediation activities for nonradioactive environmental concerns have been conducted since 2015 or are ongoing. No other reportable spills have occurred since October 2023.
5 17)
RCI WM-3 Confirm that the following statements are accurate. Between 2015 and 2021, there have been no reportable oil spills, within the scope of the reporting provision of 40 CFR 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. There have not been any reportable discharges that would trigger this notification requirement since 2021.
18)
RCI WM-4 Confirm that the following statements are accurate. Between 2015 and June 2021, there have been no reportable releases of a regulated substance from an underground storage tank containing a hazardous substance at Point Beach, within the scope of the reporting provisions of Wisconsin Administrative Code NR 706.11. There have not been any reportable releases at Point Beach that have triggered this notification requirement since June 2021.
19)
RCI SNF-1 Section 3.1.4 of NEPBs 2020 Environmental Report (ML20329A248) states that, If ISFSI
[independent spent fuel storage installation] expansion were needed, PBN expects that the expansion would occur generally west of the existing facility within the ISFSI-defined area and would cause no significant environmental impact. As documented in Section 2.1.4.4 of the 2021 draft SEIS, expansion would occur in the ISFSI-defined area andwould cause no significant environmental impact. Based on statements made by NEPB staff during the audit, Point Beach has available space within the ISFSI-defined area should an expansion be needed during the SLR term. Please confirm that if expansion of the ISFSI pad is needed, there is previously disturbed land available to accommodate such expansion and no significant environmental impact would be anticipated.
20)
RCI GHG-CC-1 With respect to the use of sulfur hexafluoride (SF6) at Point Bach, confirm the following:
SF6 is used in circuit breakers, circuit switchers, and in condenser tube leak detection.
The total inventory of SF6 in circuit breakers and switchers is 392.7 kilograms and there is no requirement to record the weight or loss of SF6 to reflect leakage and therefore annual greenhouse gas (GHG) emissions from circuit breaker and switches are not available.
Circuit breakers and switches are inspected in accordance with site routine maintenance procedures.
Water box condenser tube leak detection is performed in accordance with site procedures, has been performed in the past several years, and GHG emissions for 2023, 2022, and 2021, are 90 metric tons (MT) of carbon dioxide equivalents (CO2eq), 50 MT of CO2eq, and 127 MT of CO2eq.
6 21)
RCI GHG-CC-2 Confirm that Point Beach does not generate sufficient GHGs to trigger reporting by the State of Wisconsin, no requirement exists to report fugitive emissions from ozone depleting substances used in refrigeration appliances at Point Beach, and therefore NEPB does not track annual refrigerant fugitive emissions.
22)
RCI CI-1 Confirm the statements from information reviewed during the audit that (1) NEPB is not aware of any projects or actions, either onsite or in the vicinity of the plant, that should be considered in the cumulative effects analysis, and (2) no SLR-related refurbishment activities or replacement actions for Point Beach have been identified.
23)
RCI SAMA-1 As contained within the response to audit need SAMA-1 and as discussed during the audit, confirm that the following information is accurate with respect to NEPBs consideration of new and significant information for severe accidents:
Unit 1 2023 Update Unit 2 2023 Update Point Beach Internal Events including Flood 1.9E-06 2.0E-06 Point Beach Fire Core Damage Frequency (CDF) 6.4E-5 8.2E-5 Point Beach SEISMIC CDF 6.2E-06 6.2E-06
7 POINT BEACH NUCLEAR PLANT, UNITS 1 AND 2 SUBSEQUENT LICENSE RENEWAL APPLICATION ENVIRONMENTAL REVIEW SUPPLEMENTAL ENVIRONMENTAL AUDIT REQUESTS FOR ADDITIONAL INFORMATION 1)
RAI GEN-1 REQUIREMENT: Title 10 of the Code of Federal Regulations (10 CFR) Part 51.45(d) requires that environmental reports list all Federal permits, licenses, approvals and other entitlements which must be obtained in connection with the proposed action and describe the status of compliance with these requirements. The U.S. Nuclear Regulatory Commissions (NRCs) regulations in 10 CFR 51.71(d), Draft environmental impact statement-contents, require that, in part, the staff consider in its analysis compliance with environmental quality standards and requirements that have been imposed by Federal, State, regional, and local agencies having responsibility for environmental protection.
ISSUE: The staff must consider any changes in the status of compliance with respect to Point Beach operations as documented in Appendix B, Table B-2 in the draft supplemental environmental impact statement (SEIS) (NUREG-1437, Supplement 23; ML21306A226) and as previously included in Table 9.1-1 of NextEra Energy Point Beach, LLC (NEPBs) 2020 Environmental Report for subsequent license renewal (SLR) (Agencywide Documents Access and Management System [ADAMS] ML20329A248). During the audit, NRC staff reviewed an update to the status of compliance information for Point Beach.
REQUEST: Provide the updated Table 9.1-1, Environmental Authorizations for Current PBN Operations for docketing. In addition, for all permits/authorizations slated to expire within the next 12 months, briefly summarize plans for renewing them, as applicable.
2)
RAI GEN-2 (formerly RAI GEN-3)
REQUIREMENT: 10 CFR 51.53(c)(iv) requires that environmental reports contain any new and significant information regarding the environmental impacts of license renewal of which the applicant is aware. Further, 10 CFR 51.41 requires that applicants submit information that may be useful in aiding the Commission in complying with section 102(2) of NEPA.
ISSUE: From the information gathered and discussed during the environmental audit, NEPB has prepared supplemental additional information to NEPBs November 2020 Environmental Report (ML20329A248) that, in part, evaluates new information and provides an assessment of applicable new/modified Category 2 issues resulting from NRCs issuance of NUREG-1437, Revision 2. As part of the NRC staffs preparation of its supplement to the 2021 draft SEIS, the NRC staff must consider and independently evaluate such information.
REQUEST: Provide the report, Environmental Report Additional Information (59 pages, dated August 2024, or as revised) for docketing.
3)
RAI LV-1 REQUIREMENT: Section 307(c)(3)(A) of the Coastal Zone Management Act of 1972, as amended (CZMA) (16 U.S.C. 1456(c)(3)(A)) requires that applicants for Federal licenses who conduct activities in a coastal zone provide a certification to the licensing agency (here, the NRC) that the proposed activity complies with the enforceable policies of the States coastal
8 zone program. The CZMA implementation regulations are applicable to renewal of Federal licenses for actions not previously reviewed by the State (15 CFR 930.51(b)(1)).
ISSUE: Section 3.2.1.2 of the 2021 draft SEIS states, in part, that NextEra submitted a CZMA consistency certification package to the Wisconsin Coastal Management Program (WCMP) in support of Point Beach SLR. As of publication of the draft SEIS, the NRC had not been notified that the WCMP concurred with the submittal. During the audit, NRC staff reviewed a letter from the WCMP responding to NextEras request.
REQUEST: Provide a copy of the letter from the WCMP (dated March 26, 2021) for docketing.
4)
RAI FPE-1 REQUIREMENT: Licensees are required by 10 CFR 51.53(c)(3)(ii)(E) to assess the impact of refurbishment, continued operations, and other license renewal-related construction activities on important plant and animal habitats. Additionally, the applicant shall assess the impact of the proposed action on threatened or endangered species in accordance with Federal laws protecting wildlife, including but not limited to the Endangered Species Act (ESA). Additionally, the ESA regulations at 10 CFR 402.10 require Federal agencies to confer with the U.S. Fish and Wildlife Service (FWS) concerning species proposed for Federal listing under ESA Section 7.
ISSUE: In 2020, the FWS issued a 12-month finding announcing its intent to prepare a proposed rule to list the monarch butterfly as threatened (85 FR 81813). In 2022, the FWS identified the monarch butterfly listing action as a priority (87 FR 26152). This species range includes Manitowoc County.
REQUEST: Provide an analysis of the potential impacts of Point Beach SLR on the monarch butterfly.
5)
RAI GHG-CC-3 REQUIREMENT: 10 CFR 51.53(c)(3)(ii)(Q) states that applicants shall include an assessment of the effects of any observed and projected changes in climate on environmental resource areas that are affected by license renewal.
ISSUE: During the audit, NRC staff reviewed and discussed additional information prepared in response to audit need GHG-CC-3, that indicates, in part, that summer surface water temperature near the plant shows no increasing or decreasing trend. However, site-specific data was not provided to support this finding.
REQUEST: Provide time-series figures of average monthly intake temperatures and average monthly seasonal intake temperatures for the available period of record. Additionally, provide a discussion and any relevant information as to whether any warming trend has been observed.