ML24344A110
| ML24344A110 | |
| Person / Time | |
|---|---|
| Site: | Peach Bottom  |
| Issue date: | 12/13/2024 |
| From: | Kevin Folk NRC/NMSS/DREFS/EPMB1 |
| To: | Wilson C Constellation Energy Generation |
| References | |
| EPID L-2024-SLE-0003 | |
| Download: ML24344A110 (1) | |
Text
Christopher D. Wilson Director, License Renewal Constellation Energy Generation, LLC 200 Exelon Way Kennett Square, PA 19348
SUBJECT:
PEACH BOTTOM ATOMIC POWER STATION, UNITS 2 AND 3 -
SUMMARY
OF THE 2024 SUPPLEMENTAL ENVIRONMENTAL AUDIT RELATED TO THE REVIEW OF THE SUBSEQUENT LICENSE RENEWAL APPLICATION (EPID NUMBER: L-2024-SLE-0003) (DOCKET NUMBERS: 50-0277 AND 50-0278)
Dear Christopher D. Wilson:
A review team consisting of staff from the U.S. Nuclear Regulatory Commission (NRC or the staff) participated in a virtual supplemental environmental audit during the week of November 18, 2024, for Peach Bottom Atomic Power Station, Units 2 and 3, as part of the subsequent license renewal application environmental review. A formal exit meeting was conducted on November 25, 2024. The goal of the audit was to gather information to ensure that the environmental requirements for license renewal, as codified in Title 10 of the Code of Federal Regulations Part 51 Environmental Protection Regulations for Domestic Licensing and Related Regulatory Functions, were met. A letter dated November 13, 2024, (Agencywide Documents Access and Management System [ADAMS] ML24313A101), was sent containing an audit plan with environmental information needs.
An entrance meeting was held on November 19, 2024, to introduce participants and discuss audit logistics. During the remainder of the audit, the NRC staff participated in smaller groups (breakout sessions) with Constellation Energy Generation, LLC (CEG), and Enercon Services, Inc. (Enercon) representatives to address the audit needs identified in the audit plan. Enclosure 1 to this letter provides a list of representatives from the NRC, CEG, and Enercon who participated in the audit.
At the conclusion of the audit, the NRC staff summarized the status of the review with CEG and Enercon representatives during the exit meeting held on November 25, 2024. Many of the staffs questions identified in the audit plan or subsequently during the audit sessions were answered through the conduct of the audit. Those that were answered but would need to be documented for use in the NRCs supplemental environmental impact statement could be submitted (a) as a supplement to the application, (b) as responses to requests for additional information (RAIs), or (c) as responses to requests for confirmation of information (RCIs). Enclosure 2 to this letter contains the staffs RCIs and RAIs. NRC requests CEGs response to these items within 45 days of the receipt of this letter.
December 13, 2024
C. Wilson 2
While the NRC staff did not identify any significant environmental issues during this audit, the staff indicated that the environmental review was ongoing and that any additional information necessary to support the review would be formally requested via the RAI process in the future.
Persons who do not have access to ADAMS or who encounter problems in accessing the documents located in ADAMS should contact the NRC's Public Document Room staff at 800-397-4209 (or 301-415-4737) or via email at pdr.resource@nrc.gov.
If you have any questions, please contact me via email at Kevin.Folk@nrc.gov.
Sincerely, Kevin T. Folk 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. 50-0277 and 50-0278
Enclosures:
As stated cc: Listserv Signed by Folk, Kevin on 12/13/24
C. Wilson 3
SUBJECT:
PEACH BOTTOM ATOMIC POWER STATION, UNITS 2 AND 3 -
SUMMARY
OF THE 2024 SUPPLEMENTAL ENVIRONMENTAL AUDIT RELATED TO THE REVIEW OF THE SUBSEQUENT LICENSE RENEWAL APPLICATION (EPID NUMBER: L-2024-SLE-0003) (DOCKET NUMBERS: 50-0277 AND 50-0278)
DATED:
DISTRIBUTION:
PUBLIC MSampson, NRR/DNRL RidsNrrDnrl Resource SLee, NRR/DNRL RidsACRS_MailCTR Resource AKlett, NRR/DORL RidsNrrDorlLpl1 Resource HGonzalez, NRR/DORL RidsNrrPMPeachBottom Resource DRoth, OGC RidsRgn1MailCenter Resource APatz, OEDO/AO RidsNrrOd Resource SBurnell, HQ/OPA RidsRgn1Dnms Resource CWolf, OCA RidsRgn1Drp Resource MHoskins, OCA RidsRgn1Drs Resource SRutenkroger, RI/DORS RidsRgn1Ora Resource CDukehart, RI/DORS RidsRgn1Opa Resource SElkhiamy, RI/DORS JHammock, NRR/DNRL DTifft, RI, ORA MYoo, NRR/DNRL SKoenick, NMSS/REFS KFolk, NMSS/REFS KLoomis, NMSS/REFS EMAIL:
CWilson, CEG - christopher.wilson2@constellation.com HPell, CEG - hannah.pell@constellation.com KMeek, CEG - Kristin.Meek@constellation.com AStalker, CEG - Allison.Stalker@constellation.com ADAMS Accession No.: ML24344A110 OFFICE NE/PM:EPMB1 LA:REFS BC:EPMB1 NE/PM:EPMB1 NAME KFolk AWalker-Smith SKoenick KFolk DATE 12/10/2024 12/11/2024 12/12/2024 12/13/2024 OFFICE RECORD COPY December 13, 2024 LIST OF PARTICIPANTS PEACH BOTTOM ATOMIC POWER STATION, UNITS 2 AND 3 SUBSEQUENT LICENSE RENEWAL APPLICATION SUPPLEMENTAL ENVIRONMENTAL AUDIT November 19-22, and November 25, 2024 The U.S. Nuclear Regulatory Commission (NRC) team members, Constellation Energy Generation, LLC (CEG) and Enercon Services, Inc. (Enercon) staff, as well as their discipline or titles, participating in the supplemental environmental audit are shown below.
NRC Discipline or Title Team Members Environmental Project Manager Kevin Folk, NMSS Environmental Project Manager (Backup, Training)
Karen Loomis, NMSS Air Quality and Noise Nancy Martinez, NMSS Aquatic Resources Briana Arlene, NMSS Cumulative Impacts (Effects)
Brian Glowacki, NMSS Environmental Justice Jeff Rikhoff, NMSS Federally Protected Ecological Resources Briana Arlene, NMSS Geologic Environment Kevin Folk and Sam Cohen, NMSS Greenhouse Gases/Climate Change Nancy Martinez, NMSS Groundwater Resources Kevin Folk and Sam Cohen, NMSS Historic and Cultural Resources Jeff Rikhoff, NMSS Human Health Dr. Donald Palmrose, NMSS Land Use and Visual Resources Jeff Rikhoff, NMSS Meteorology and Climatology Nancy Martinez, NMSS Postulated Accidents, Severe Accident Mitigation Alternatives Jerry Dozier, NRR Replacement Power Alternatives Brian Glowacki, NMSS Socioeconomics Jeff Rikhoff, NMSS Spent Nuclear Fuel Leah Parks, NMSS Surface Water Resources Kevin Folk and Sam Cohen, NMSS Environmental Justice Jeff Rikhoff, NMSS NMSS=Office of Nuclear Material Safety and Safeguards; NRR=Office of Nuclear Reactor Regulation.
2 CEG Discipline or Title Team Members Environmental Lead, License Renewal Kristin Meek Licensing Lead, License Renewal Hannah Pell Director, License Renewal Christopher Wilson Senior Manager, License Renewal Sarah Swienton Senior Engineer, License Renewal Sarah Brochu Engineering Manager, License Renewal Julian Laverde Principal Environmental Specialist, License Renewal Allison Stalker Regulatory Assurance Manager, Peach Bottom Brian Woodard Principal Regulatory Engineer, Peach Bottom Amy Huber Senior Environmental Specialist, Peach Bottom Samantha Rice Environmental Specialist, Peach Bottom Lindsey White Manager, Environmental Programs Debra Musser Site Chemistry & Radwaste Manager, Peach Bottom Tamara Hanlon Senior Chemist, Peach Bottom Erika Wagner Senior Radwaste Chemist, Peach Bottom Mary Brass Principal Project Manager, Peach Bottom Dale Chapman Principal Project Manager, Peach Bottom David Williams Developmental Manager, Peach Bottom Scott Weichler Senior Staff Engineer, Peach Bottom Floyd Reeser Maintenance Manager, Peach Bottom Ronald Toomey Principal Reactor Engineer, Peach Bottom Jeffrey Holley Systems Engineer, Peach Bottom Ruth Kurak ISFSI Implementation & Support Manager Sonja Patrick Dry Cask Storage Manager Paul Gregory ISFSI Implementation & Support Manager Kimberly Hobbs Senior Fuels Engineer Lily-An Korbeil Operations Shift Supervisor John Frauenheim ISFSI = Independent Spent Fuel Storage Installation.
3 Enercon Discipline or Title Team Members Environmental Licensing Manager Rachel Turney-Work Environmental Project Manager Stacy Burgess Air Quality, Greenhouse Gas Emissions and Climate Change Jerry Riggs Federally Protected Ecological Resources Jay Hemmis General Topics, Cumulative Impacts Lisa Santoro Historic and Cultural Resources Fred Woolridge Noise Derek Allen Geologic Environment, Water Resources (Groundwater and Surface Water)
Jennifer Meek Waste Management, Spent Nuclear Fuel, Uranium Fuel Cycle Emily Keenan, Mary Hoganson Socioeconomics Cheyenne Riggs Human Health Emily Keenan, Mary Hoganson Severe Accident Mitigation Alternatives Analysis Neil Johnson PEACH BOTTOM ATOMIC POWER STATION, UNITS 2 AND 3 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 January 2020 final supplemental environmental impact statement (FSEIS) (NUREG-1437, Supplement 10, Second Renewal)
(ML20023A937) for the Peach Bottom Atomic Power Station (Peach Bottom) SLR application in accordance with the NRC's regulations in 10 CFR 51.92.
Requests for Confirmation of Information During the supplemental environmental audit, the NRC staff reviewed documents that were made available on the applicants (Constellation Energy Generation, LLC (CEG)) electronic information portal for Peach Bottom in response to the staffs audit information needs (ML24313A101). The staff also participated in breakout sessions with applicant personnel to gather information that will likely be used in the supplement to the 2020 FSEIS. To the best of the staffs knowledge, other than the Peach Bottom Additional Information report (ML24319A074) which was submitted on the docket, the information on the electronic portal and discussed in breakout sessions is not currently on the docket or publicly accessible. During the audit, staff was able to disposition or close out several audit data needs (i.e., GEN-1, GEN-2, WM-2-WM-4, WM-8-WM-10, and SNF-1). However, the NRC staff 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.
2 AQN-1 Confirm the following reported air pollutant emissions for Peach Bottom (for the period 2018-2023):
Year CO NOx PM10 PM2.5 SOx VOC Lead Total HAPs Emissions Limits 100 100 100 100 100 50 0.01 25 2018 3.43 14.95 8.32 0.26 0.11 0.32 0.0003 0.0003 2019 3.04 13.18 9.96 0.23 0.13 0.35 0.0003 0.0183 2020 3.6 13.62 11.43 0.23 0.08 0.4 0.0002 0.0087 2021 2.58 10.94 6.5 0.17 0.04 0.28 0.0001 0.0072 2022 2.5 11.42 10.14 0.18 0.05 0.27 0.0002 0.0112 2023 2.87 13.34 1.3 0.31 0.85 0.69 0
0.0063 CO = carbon monoxide, HAPs = hazardous air pollutants, NOx = nitrogen oxides, SOx = sulfur oxides, PM10 = particulate matter less than 10 micrometers, PM2.5 = particulate matter less than 2.5 micrometers, VOC = volatile organic compounds.
Note: All units are tons per year.
AQN-2 Confirm that CEG has received no notices of violation or non-compliances associated with Peach Bottoms air pollutant emissions permit (no. 67-05020) from 2018 through November 13, 2024.
NOI-1 Confirm that CEG has neither performed nor sponsored any ambient noise studies in the immediate vicinity of the Peach Bottom site between July 2018 and November 13, 2024.
NOI-2 Confirm that CEG has not received any noise complaints associated with operation of Peach Bottom from 2018 through November 13, 2024.
3 SW-1 Confirm the following surface water withdrawals for Peach Bottom (for the period January-September 2024):
Withdrawal (million gallons per day [mgd])
Consumption (mgd)
Month Average Maximum Average Maximum January 2,240.99 2,242.31 14.66 18.52 February 2,240.70 2,241.05 15.27 21.82 March 2,240.88 2,243.07 17.60 21.59 April 2,240.76 2,241.37 20.31 25.22 May 2,194.35 2,243.89 25.32 31.48 June 2,265.31 2,281.68 29.74 33.34 July 2,207.78 2,286.08 28.19 35.58 August 2,280.96 2,281.06 32.40 36.52 September 2,272.53 2,283.79 28.26 31.47 SW-2 Based on the information gathered and discussed during the audit, confirm the following statements. The renewal application for Peach Bottoms National Pollutant Discharge Elimination System (NPDES) permit (No. PA0009733) is still undergoing review by the Pennsylvania Department of Environmental Protection (DEP). CEG routinely interacts with the DEP and no additional information to support the review has been requested. CEG does not have an estimated date for completion of DEPs review or issuance of the permit renewal.
SW-3 Based on the information gathered and discussed during the audit, confirm the following statements regarding CEGs compliance with Peach Bottoms NPDES permit (No. PA0009733) for the period 2018 through 2024. There were no notices of violation issued since 2019. One NPDES permit exceedance occurred in November 2019 for total suspended solids (TSS) at Outfall 003, wastewater from a water treatment settling basin. The daily limit for TSS at this outfall is 100 milligrams per liter (mg/L). The TSS result from a sample collected on November 5, 2019, was 167 mg/L. The settling basin is pumped quarterly, and the sample was collected just prior to a scheduled cleanout. The sample was also collected during maximum water draw during the restart of Unit 3 after a refueling outage. Corrective actions included:
cleaning out the settling basin on November 17, 2019, collecting additional samples to validate compliance with the monthly TSS permit limit (30 mg/L), updates to internal procedures to ensure the settling basin is cleaned out prior to the start of an outage, and to provide guidance to station personnel on sample collection at various NPDES outfalls. The TSS daily permit limit exceedance was reported in the November 2019 discharge monitoring report. Further corrective action was not required.
4 SW-4 Based on the Peach Bottom Additional Information report (ML24319A074) and information gathered and discussed during the audit, confirm the following clarifying information regarding CEGs response to the two instances in 2022 where low flow conditions warranted implementation of the consumptive use mitigation plan (CUMP) for Peach Bottoms consumptive water use. For the period 2018 through 2024, the CUMP mitigation threshold was met in 2022 on August 15-22 and September 2022. As discussed in the 2022 annual report submitted by CEG to the Susquehanna River Basin Commission and Federal Energy Regulatory Commission, there were periods of low flow at these times, but there were no instances where operational flow through Conowingo Dam fell below natural inflow to Conowingo Pond. Therefore, Conowingo Dam did not need to use any of the 800 cubic feet per second (cfs) of leakage, including the 220 cfs allotment for Peach Bottom, to meet the minimum flow requirements per the CUMP.
GW-1 Based on the information gathered during the audit (information need GW-2), confirm the following statements. CEG continues to operate three active groundwater supply wells at Peach Bottom with a maximum total capacity of 15 gallons per minute (gpm). The yard drain sump and dewatering system remains in operation with a discharge capacity of 50 gpm to an NPDES-permitted outfall.
FPE-1 The NRC staff completed the U.S. Fish and Wildlife Service's (FWS) Northern Long-eared Bat and Tricolored Bat Rangewide Determination Key (DKey) using information obtained from CEG personnel during the supplemental environmental audit. Confirm that the staff's responses to the DKey accurately reflect activities that may occur on the Peach Bottom site during the SLR term. The staff's responses can be viewed in the attachment titled, "Determination Key Result,"
to the FWS's November 22, 2024, letter to the NRC (ML24327A164, p. 5-13).
SOC-1 Based on information gathered during the audit, confirm the following real estate (property) tax payment information, and payments in additional to tax made on behalf of Peach Bottom (for the period 2020-2024):
2020: York County $201,209; South Eastern School District $729,339; Peach Bottom Township
$15,406.
2021: York County $201,209; South Eastern School District $729,453; Peach Bottom Township
$31,795.
2022: York County $239,964; South Eastern School District $729,453; Peach Bottom Township
$32,449.
2023: York County $235,348; South Eastern School District $729,453; Peach Bottom Township
$31,800.
5 2024: York County $546,277; South Eastern School District $2,456,835; Peach Bottom Township $93,489.
CEG has a new payment after taxes agreement that covers 2024-2032, which includes retroactive payments to the taxing jurisdictions for years 2022-2023 and 2023-2024.
HH-1 Based on the information gathered and discussed during the audit, confirm the following statements. (1) Procedures in place at Peach Bottom for personnel protection regarding microbiological hazards include corporate procedures for Legionella Monitoring, Respiratory Protection Program, and Selection of Respiratory Protection for Non-Radiological Use. (2)
Updates to the Peach Bottom Atomic Power Station occupational and electrical safety programs are made on an as-needed basis, based on applicable regulatory changes and industry/CEG fleet operational changes. (3) CEG ensures that Peach Bottom's in-scope transmission lines satisfy National Electrical Safety Code standards through adherence to station electrical safety procedures.
WM-1 Based on the information gathered and discussed during the audit, confirm the following statements regarding abnormal gaseous radiological releases that have occurred at Peach Bottom since December 31, 2023. One gaseous abnormal release of tritium occurred from the Auxiliary Boiler in 2023 due to steam from the boiler being sent out the roof of the boiler house (as discussed in CEGs 2023 Radioactive Effluent Release Report for Peach Bottom, ML24120A276). The suspected causes of the tritium were valves in both the Unit 2 and Unit 3 Moisture Separator, which could only be replaced during an outage. The Unit 3 valves were subsequently replaced during the 2023 Unit 3 outage and monitoring frequency was increased at the plant. There was one abnormal gaseous release from the Auxiliary Boiler in 2024 with the suspected cause being the valves in the Unit 2 Moisture Separator. The valves were subsequently replaced during the 2024 Unit 2 outage. With the replacement of both the Unit 2 and Unit 3 valves, CEG expects that the source of the leak has now been repaired. The increased monitoring will continue until sufficient evidence is obtained to conclude all leaks have been identified and corrected. The impact from this release was captured in a gaseous release permit and was below regulatory limits.
WM-2 Based on the information gathered associated with audit need WM-5, confirm that CEG does not have any planned changes or upgrades to the non-radiological waste program at Peach Bottom during the proposed SLR term.
6 WM-3 Based on the information gathered associated with audit need WM-6, Peach Bottom is subject to the reporting provision of Title 40 of the Code of Federal Regulations 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. Confirm there have not been any reportable discharges at Peach Bottom since 2018 that would trigger this notification requirement.
WM-4 Based on the information gathered associated with audit need WM-7, confirm that CEG does not have any planned changes or upgrades to the low-level radiological waste program at Peach Bottom during the proposed SLR term.
UFC-1 Based on the information gathered and discussed during the audit, confirm the following statement. Fuel enrichment up to 5 percent by weight of uranium-235 and the 62,000 megawatt-days per metric tonne of uranium (MWd/MTU) average peak rod fuel burnup limit for each unit are a part of the design basis. CEG has no current plans to exceed these limits.
GHG-CC-1 Based on the information gathered and discussed during the audit, confirm the following information regarding direct and indirect greenhouse gas (GHG) emissions resulting from operation at Peach Bottom (for the period 2018-2023):
Peach Bottom direct and indirect GHG emissions are as provided in the following table:
Emissions (metric tons, carbon dioxide equivalent (CO2e))
2018 2019 2020 2021 2022 2023 Direct Emissions 6,710 6,311 3,816 3,455 5,279 2,780 Indirect Emissions 571 605 581 532 557 598 Total 7,281 6,916 4,397 3,987 5,836 3,378
7 Relative percentages for each GHG source are as provided in the following table:
Peach Bottom GHG Emissions Relative Percentages Emissions (metric tons, carbon dioxide equivalent (CO2e))
2018 2019 2020 2021 2022 2023 Stationary Combustion-Power Auxiliary Operations 93.6 95.3 81.7 80.5 74.1 32.7 Fugitive - Sulfur Hexafluoride (SF6) 0.0 0.0 14.9 16.8 25.1 66.2 Process - Carbon Dioxide (CO2) 0.2 0.2 0.3 0.5 0.3 0.7 Hydrofluorocarbon/ Perfluorocarbon (HFC/PFC) Refrigerants 0.0 0.3 0.4 0.0 0.2 0.1 Ozone Depleting Chemical (ODC)
Refrigerants 6.3 4.2 2.7 2.2 0.3 0.2 Direct emission sources for Peach Bottom operations include those listed in its air emissions permit and other Peach Bottom owned and controlled emissions units not required to be in the permit.
The emission sources included in the direct emission calculations that were not included in the air emission permit include one breaker that uses SF6, fire suppression equipment that uses CO2, CO2 released while purging the main generator, and HFC and PFC refrigeration units. The SF6 breaker is inspected daily by equipment operators.
Operations supervision staff routinely review the equipment operator rounds to verify steady pressure trends, indicating no leakage, or for early indications of degradation.
There is an alarm in the Main Control Room that will initiate if the low-pressure threshold for the breaker is reached.
Indirect emissions account for electricity used by the Peach Bottom facility, with the assumption that the electricity was sourced from the electrical grid and based on the mix of electrical generation found in Peach Bottoms electrical subregion used to estimate GHG emissions.
Estimated greenhouse gas emissions for the combustion units are based on fuel usage and the U.S. Environmental Protection Agencys 2023 Emission Factors for GHG Inventories table to derive CO2eq emissions. The emission factors used are as follows:
Distillate Fuel Oil No. 2; 0.138 million British thermal units per gallon (mmBtu/gal); 73.96 kilograms CO2/mmBtu; 3.0 grams (g) CH4/mmBtu; 0.6 g N2O/mmBtu; and Liquefied Petroleum Gases (LPG); 0.092 mmBtu/gal; 61.71 kg CO2/mmBtu; 3.0 g CH4/mmBtu; 0.60 g N2O/mmBtu
8 The Global Warming Potentials applied are as follows:
Methane (CH4): 25; Nitrogen oxide (N2O): 298; R-134a (HFC-134a): 1,430; R-404a: 3,922; R-410a: 2,088; SF6: 22,800; Halon 1211: 1,300; Halon 1301: 6,900; R-114: 9,800; R-12: 8,100; R-22: 1,500; and R-502: 4,418.45.
CI-1 From the information gathered during the audit, please confirm the following about the two identified projects at Peach Bottom. (1) The purpose of the Sewage Treatment Plant (STP) project is to install a new plant to replace the existing STP. This includes installation of a new pumping station in the previously disturbed parking lot in front of the Training Center, which will collect sewage at the site and pump it across Rock Run Creek to the new STP located in the independent spent fuel storage installation parking lot. The new STP will have a new outfall for treated effluent discharging to the Susquehanna River. As of November 2024, the project is in the testing phase and work to place the project into service is scheduled for December 2024.
State permits and approvals required include: Pennsylvania Natural Diversity Inventory environmental review for animal and plant impact, GP-04 permit for installation of utilities across Rock Run Creek (PA DEP General Permit File No. GP046703333-005 and GP056703222-011),
GP-05 permit for outfall installation (PA DEP General Permit File No. GP056703223-008),
evidence to the contrary for engineering study to define 100-year floodplain for Rock Run Creek, and Water Quality Management permit for treatment of wastewater sewage. Township permits required include Land Development and Stormwater permit for local development and Uniform Construction Code Building Permit for building related construction activities. (2) The purpose of the 3SU Cable Project was to abandon the existing 3SU cable and replace the 3SU feeder cable with new cable. The existing feed was completely underground, whereas the new feed has portions underground and portions overhead. Four poles were installed to be able to run the cable overhead and not disturb the ground and the original cables that were buried. The overhead route required some tree and vegetation clearing to allow the underground duct banks, riser structures, steel poles and cables to be installed and to ensure adequate clearances are provided and maintained. Areas along the route were graded to allow pole and duct bank installation. An environmental impact review was performed per station procedure to ensure potential environmental impacts were mitigated or avoided. The 3SU cable replacement work was completed in September 2023 and the cable is in service. The areas that were disturbed are covered by the erosion control permit that will remain open until permanent stabilization is established. PA PAG-02 permit (#PAC670567, Authorization to Discharge Under the NPDES General Permit for Discharges of Stormwater Associated with Construction Activities) was obtained for the project and which has been renewed until Fall 2025.
9 SAMA-1 Based on the information gathered and discussed during the audit, confirm the following information and statements with respect to CEGs consideration of any new and significant information regarding core damage frequency (CDF) for Peach Bottom.
New information reviewed by CEG included the following.
Peach Bottom Unit 2 Peach Bottom Unit 3 Full Power Internal Event (FPIE)
(includes internal flood) CDF 2.7E-6 2.8E-6 Fire Probabilistic Risk Assessment (FPRA) CDF 2.8E-5 4.0E-5 Seismic Probabilistic Risk Assessment (SPRA) CDF 2.2E-5 2.2E-5 Total CDF 5.3E-5 6.5E-5 These values represent a reduction in impacts since the initial license renewal and are within the range of CDFs the NRC evaluated in the NRCs 2024 License Renewal Generic Environmental Impact Statement.
For other areas of increase in impacts, new source term information, use of BEIR-VII coefficients, power uprates, higher fuel burnup, low power shutdown, spent fuel fool accidents, PBAPs is consistent with the findings in the 2024 License Renewal Generic Environmental Impact Statement.
With regard to uncertainty, the ratio of the 1996 95th percentile upper confidence bound population dose to that used in the LR GEIS is 201 times lower, indicating a significant reduction in impacts.
With regard to population growth, CEG estimates a 28 percent higher population at the midpoint of the period of extended operation, which is a small change compared to other reduction factors.
Severe accident mitigation alternatives (SAMAs) were evaluated using the NEI 17-04 methodology in the SLR and no new and significant SAMAs were found. The decrease in the CDF values since the SLR submittal leads to the same conclusion without the need to re-evaluate those results.
10 PEACH BOTTOM ATOMIC POWER STATION, UNITS 2 AND 3 SUBSEQUENT LICENSE RENEWAL APPLICATION ENVIRONMENTAL REVIEW SUPPLEMENTAL ENVIRONMENTAL AUDIT REQUESTS FOR ADDITIONAL INFORMATION GW-1 REQUIREMENT: Title 10 of the Code of Federal Regulations (10 CFR) Section 51.53(c)(3)(ii)(P) states that an applicant shall assess the impact of any documented inadvertent releases of radionuclides into groundwater. The applicant shall include in its assessment a description of any groundwater protection program used for the surveillance of piping and components containing radioactive liquids for which a pathway to groundwater may exist. The assessment must also include a description of any past inadvertent releases and the projected impact to the environment (e.g., aquifers, rivers, lakes, ponds, ocean) during the license renewal term. Further, 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.
ISSUE: Based on the U.S. Nuclear Regulatory Commission staffs review of information gathered during the audit associated with audit need GW-1 as well information contained in Constellation Energy Generation, LLC 2023 Annual Radiological Environmental Operating Report for Peach Bottom (Agencywide Documents Access and Management System ML24150A273), several groundwater protection monitoring wells have exhibited elevated tritium concentrations.
REQUEST: Provide the monthly (or latest quarterly) groundwater protection program monitoring results for tritium in wells MW-PB-25, MW-PB-28, and MW-PB-30 (for 2024 year to date). In addition, provide an assessment of the spikes in tritium detections in Well MW-PB-30 in 2022 and 2024. Discuss sources contributing to the spikes as well as investigations performed, and corrective actions taken