ML25212A009
| ML25212A009 | |
| Person / Time | |
|---|---|
| Site: | Robinson  |
| Issue date: | 08/06/2025 |
| From: | Loomis K NRC/NMSS/DREFS/EPMB1 |
| To: | Basta L H B Robinson Steam Electric Plant |
| Shared Package | |
| ML25212A007 | List: |
| References | |
| Download: ML25212A009 (1) | |
Text
1 ROBINSON NUCLEAR PLANT, UNIT 2 INITIAL LICENSE RENEWAL APPLICATION ENVIRONMENTAL REVIEW REQUESTS FOR CONFIRMATION OF INFORMATION Regulatory Basis Licensees are required by Title 10 of the Code of Federal Regulations (10 CFR) Part 51.53(c)(1) to submit with its application a separate document entitled Applicant's Environmental Report Operating License Renewal Stage. The U.S. Nuclear Regulatory Commissions (NRC) regulations at 10 CFR 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. As part of its review, the NRC staff is required to prepare a supplemental environmental impact statement (SEIS). 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.
Requests for Confirmation of Information (RCIs)
The letter to Laura Basta, Site Vice President, at H. B. Robinson Steam Electric Plant, dated June 30, 2025 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML25177A046), contained an audit plan for Robinson Nuclear Plant (RNP), which included a list of information needs with unique identifiers. During the environmental audit, the NRC staff reviewed documents that were made available on the applicants electronic information portal in response to the staff audit needs. The staff also participated in breakout sessions with applicant personnel for certain resource areas to gather information that will likely be referenced in the SEIS. To the best of the staffs knowledge, this information on the applicants electronic information portal and discussed in breakout sessions is not currently on the docket or publicly accessible. The NRC staff requests that the applicant provide confirmation that the information gathered from the audit and listed below is correct or provides the associated corrected information.
1)
RCI GEN-01 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. Appendix B of the draft SEIS will list the permits and licenses issued by Federal, State, and local authorities for activities at RNP, as identified in table 9.1-1 of the environmental report (ER), dated April 1, 2025 (ML25091A296). As part of the SEIS, the NRC staff must consider whether there have been any changes to operating permits or other requirements. Please confirm the following updates to table 9.1-1 that have occurred since the ER was submitted in April 2025. The updated dates (including updates permits and those administratively extended) are shown in italics.
2 Table 9.1-1 UPDATES Environmental Authorizations for Current Robinson Nuclear Plant Operations Agency Authority Requirement Facility/Permit Number Expiration Date Authorized Activity DOT 40 CFR 107 Subpart G Hazardous Materials Certificate of Registration Reg. No.
050923550105F Expiration:
6/30/2026 Hazardous materials shipments.
USFWS 16 U.S.C 703-712, 50 CFR 13, 50 CFR 16 U.S.C 703-712, 50 CFR 13, 50 CFR, 21.27 Migratory Bird Special Purpose Utility Permit Permit No.
MB000257 Expiration:
3/31/2025, administratively extended until renewed by USFWS Permit to handle non-endangered/threatened migratory birds.
2)
RCI GEN-02 As discussed during the audit, and as a result of Duke Energys new and significant information review and results identified in section 5 of the ER, please confirm no new and significant information was identified for Category 1 issues regarding the environmental impacts of the subsequent license renewal (SLR) for RNP. Additionally:
Confirm that there have been no nonradiological releases impacting soil or groundwater from 2024 to the present. (GW-10)
Confirm there have been no leaks or spills at RNP that have resulted in the detection of tritium in groundwater at 20,000 pCi/L or higher during Unit 2 operations. (GW-11)
Confirm there have been no unplanned radionuclide releases impacting soil or groundwater from 2024 to present. (GW-12)
Confirm Duke Energy has not received any notices of violation (NOVs) or non-compliances with respect to the Darlington County Noise Ordinance from 2019 to present. (NOI-03)
Confirm since the ER was written, RNP has not received any NOVs or non-compliances associated with wastewater discharges to receiving surface waters. (SW-02).
Confirm that there are no changes or upgrades to the effluent control systems and to the waste management program being considered during the license renewal term. (WM-01)
Confirm that Robinson does not routinely generate mixed waste and does not anticipate any changes to the generation rate during the proposed SLR term. (WM-02)
Confirm that there are no proposed changes or upgrades to the Solid Waste Management Systems. (WM-03)
In section 9.3 of the ER, it is stated that for the period of 2020-2024, there were two
3 reportable releases, of which one NOV was issued on May 29, 2024, and South Carolina Department of Environmental Services (SCDES) received communication from Duke Energy about the event and corrective actions, and no further responses were required to resolve the NOV. Please confirm that there are no other reportable releases since the ER was written that triggered the notification requirement. (WM-04)
Confirm that there are no reportable unplanned releases of radioactive materials (unplanned/inadvertent radioactive liquid or gaseous releases) which would trigger a notification requirement since the ER was written. (WM-05)
Confirm that there are no reportable inadvertent releases or spills of non-radioactive contaminants which would trigger a notification requirement since the ER was written.
(WM-06) 3)
RCI-NOI-01 In response to information need NOI-1, please confirm that the distance between the security training facility and:
the nearest residence is approximately 4,000 feet the nearest shoreline boundary is approximately 680 ft nearest site boundary on land is 3,900 ft 4)
RCI-NOI-04 In response to information need NOI-4, please confirm:
Since 2023, Duke Energy received a noise complaint from an inadvertent siren activation in 2024; Duke Energy has received complaints from multiple sources regarding noise emitted from siren testing; Duke Energy proactively communicates via traditional and social media platforms to inform the public of siren testing; Duke Energy provides siren test dates in materials mailed to all residents within the 10-mile emergency planning zone; and In response to noise complaints from inadvertent siren activation, Duke Energy has provided announcements on their company website regarding the event.
5)
RCI SW-03 Please confirm RNP has not reduced power to meet thermal discharge limits over the past five years (2020-2025).
6)
RCI GW-02 In response to information need GW-02, Duke provided additional information about sheet piling installed around the intake structure as described in ER Section 3.6.2.3. Please confirm the following statement.
The description of sheet piling in ER Section 3.6.2.3 is likely incorrect. Sheet piling was installed at the intake structure during construction to act as a temporary cofferdam and was removed after construction. There is likely no sheet piling remaining in place at the intake structure.
4 7)
RCI GW-03 In response to information need GW-03, Duke provided additional information about groundwater elevations in monitoring wells MW-7 near the ash pond and MW-7 near the RNP powerblock shown in ER figure 3.6-7. Please confirm the following statement.
The water level elevation provided in ER figure 3.6-7 for MW-7 near the RNP powerblock is in error. Ground surface elevation and groundwater level elevation were not reported for the MW-7 well located near the RNP powerblock during the July 27-29, 2020, survey.
8)
RCI GW-06 In response to information need GW-06, Duke provided additional information on RNP groundwater withdrawals during 2024. Please confirm the following values to supplement the groundwater withdrawal data provided in ER table 3.6-6a.
ER Table 3.6a updated with 2024 groundwater withdrawals Year 2019 2020 2021 2022 2023 2024 2019-2023 MG M
34.22 42.95 33.8 33.36 32.54 32.09 34.83 Monthly Maximum gpm 767.64 962.21 766.57 33.36 728.92 718.93 662.94 MG M
31.82 32.52 32.25 32 28.92 31.20 31.45 Monthly Average gpm 726.26 740.09 736.37 730.6 717.34 710.29 726.83 MG M
28.32 28.75 29.05 29.17 28.92 28.68 28.81 Monthly Minimum gpm 702.37 688.53 706.29 708.4 704.44 686.66 699.45 MGY 381.79 390.27 387.03 384 377.03 374.41 382.42 Yearly Total MG D
1.05 1.07 1.06 1.05 1.03 1.02 1.05 9)
RCI GW-09 In response to information need GW-09, Duke provided additional information on tritium levels in Lake Robinson, including how the level has changed over time. Duke provided for inspection a table and chart of monthly tritium levels at the R40 sampling location for the period of January 2020 through November 2024. Please confirm the following statement(s).
Monthly tritium levels at the R40 sampling location on Black Creek below the Lake Robinson dam during the period of January 2020 through November 2024 ranged from nondetects to 7,610 pCi/L. Measurements were made on composited hourly samples. Cyclical patterns in the tritium levels coincide with plant outages for refueling, with peak tritium levels in the lake occurring during refueling. Peak monthly tritium values in Lake Robinson that exceeded 4,000 pCi/L were 4,650 pCi/L in September/October 2020, 6,810 pCi/L in November/December 2021, 6,570 pCi/L in September/October 2022, and 7,610 pCi/L in August/September 2024.
5 10)
RCI GW-13 In response to information need GW-13, Duke provided Site Conceptual Model Reports from 2015 and 2020. Please confirm the following information from these reports.
The initial purpose of the following wells installed in 2006 or 2007 was monitoring for 1996 Unit 1 oil spill remediation: P-1, P-2, MW-6, MW-7, MW-9, MW-13. The following wells were installed in 2009 for NEI 07-07 radiological monitoring: PDW-01, PSW-02, PSW-03, PSW-04, and PSW-05. (2015 SCM, table 1)
Permeability in the recent alluvium is about 3.95e-04 cm/s. (2015 SCM, pg. 2-8)
Lack of an immediate (or direct) connection between the water supply wells (Wells A, B, and C) and groundwater in the recent alluvium is supported by original well construction logs showing a cement seal is present to prevent migration along the sides of the wells.
Screen depths for these wells are 178 - 220 ft bgs with the casing sealed to depths of 170 - 172 ft. (2015 SCM pg. 2-4) To evaluate the connection between the recent alluvium and the Middendorf aquifer units, water supply pumping was altered to change heads in the Middendorf aquifer; no response to the head change was seen in the recent alluvium monitoring wells. (2015 SCM pg. 2-15)
Well D is annually tested to demonstrate that it can achieve upwards of 1,300 gpm as a source of emergency (backup) cooling water supply. Static head in Well D trended downward about 10 ft between 2004 and 2012. (2015 SCM pp. 2-11 & 2-12)
Water levels in recent alluvium wells showed a multi-year decline in groundwater elevations, which was attributed to long-term migration of water from the recent alluvium to the Middendorf formation. When Unit 1 ceased operation and groundwater pumping was reduced (about 2012), groundwater levels in the recent alluvium in the power block area increased. (2015 SCM pp. 2-17 & 2-18)
Water depth in the east and west settling ponds is less than 5 ft. (2015 SCM pg. 2-2)
During the transducer study in February - April 2015 water elevations in the ponds were 8-10 ft higher than in the surrounding wells (MW-4R, TS-01B, and TS-02C). (2015 SCM pg. 2-13)
As reported in the 2015 SCM report, since 2012 one sample from each settling pond (collected April 9, 2012) exceeded the tritium MDA level of 4,000 pCi/L: tritium levels were 5,042 pCi/L in the east pond and 6,392 pCi/L in the west pond. (2015 SCM pg. 3-3)
As reported in the 2020 SCM report, surface water samples from the east and west settling ponds are collected on a weekly basis and only one sample exceeded the MDA since 2015: a west pond sample collected on January 16, 2018, had a tritium level of 1,043,000 pCi/L. No corresponding increase in tritium was observed in samples from the downgradient well MW-107. (2020 SCM pp. 15-16) 11)
RCI TER-01 Please confirm that the following statements regarding the operation of the Lake Robinson dam are accurate:
1.
The top of the tainter gates functions as the dam spillway. The height of the spillway is
6 220 feet above Mean Sea Level (MSL).
2.
Flows through the lake and spillway directly reflect the natural seasonality of the influent water volume.
3.
During low flow events, the dam discharge will remain in the normal spill-over configuration and naturally decrease until the lake level reaches 220 feet MSL. At this point, the water will no longer flow over the spillway and will be released via the spillway valves which are controlled by Duke. The minimum rate of discharge will be set to maintain the Black Creek temperature <91.4 degrees Fahrenheit as required by Dukes National Pollutant Discharge Elimination System (NPDES) permit. Duke does not have a minimum water release requirement from the dam to Black Creek.
12)
RCI TER-02 Please confirm there are two structures on site taller than 100 feet above ground level (AGL) as follows: 1) meteorological evaluation tower is 330 feet AGL, guyed, and uses a red flashing light regime, 2) the containment building is 193.5 feet AGL and is not lit.
13)
RCI TER-03 Please confirm that the following statements regarding herbicide use and mowing are correct:
1.
Herbicides and pesticides are used on an as-needed basis in areas including security fence lines, along sidewalks and buildings, and in other areas within the security fenced area to maintain compliance with safety and security protocols at RNP.
2.
Mowing occurs on site within the grassy areas of the security fenced portion of the RNP site, including the area surrounding the industrial buildings and along the dam.
14)
RCI TER-04 Please confirm that the following land management practices occur within the RNP site boundary but are not directly related to the operation of RNP and would continue to occur whether RNP continues operation or not: (1) prescribed fire; (2) tree clearing; (3) planting; (4) pine straw harvesting; and (5) land clearing for the Robinson Solar Farm.
15)
RCI TER-11 Please confirm that the following statements regarding site procedures are correct:
1.
The NRC staff was provided Dukes proprietary Pesticide Compliance Procedure for review. This procedure contains consideration for endangered species and pollinator protection measures and water quality protection measures. The procedure states that pesticide application around water and sensitive areas generally requires a minimum of 25-foot buffer from surface waters and areas which could drain to surface water. The procedure also states that pesticides should not be applied immediately prior to or immediately following rainfall, when wind and/or fog conditions are likely to cause drift, or when dew is heavy on vegetation.
2.
The NRC staff was provided Dukes proprietary Avian Protection Procedure for review.
7 This procedure contains measures, precautions, and guidance to handle the discovery of dead or injured birds and to handle bird nests within a work zone. Duke maintains a Migratory Bird Hot Line that is contacted upon finding a dead or injured bird and provides guidance for how to proceed in compliance with the Migratory Bird Treaty Act, the Endangered Species Act, and the Bald and Golden Eagle Protection Act.
3.
The NRC staff was provided Dukes proprietary Land-Disturbing Activities procedure for review. The procedure states that if the land-disturbing work involves tree clearing or takes place in undeveloped areas, then a natural resource evaluation will be conducted.
This evaluation will assess potential impacts on state or federally listed species.
16)
RCI AQU-01 Please confirm RNP has had no fish kills at Lake Robinson within the current license renewal term.
17)
RCI AQU-07 Please confirm that the 2 feet drawdown below normal pool elevation (220 feet) limit specified in NPDES Permit No. SC0002925 has not been exceeded.
18)
RCI-HCR-02 Please confirm that the following statement is correct:
No historical sites or cemeteries within the RNP property were identified during Duke Energys most recent review of the South Carolina Historic Properties Record (SCHPR) database and no physical evidence or remains of the historic Wiley Warren farmstead or cemetery has been identified onsite at RNP.
19)
RCI-HCR-03 Please confirm that the following statement is correct:
Duke Energy submitted the architectural report to the South Carolina State Historic Preservation Officer on June 12, 2025. To date, Duke Energy has not sent or received any additional correspondence related to historic and cultural resources since the submittal of its SLR application.
20)
RCI-HCR-04 Please confirm that the following statement is correct:
Duke Energy procedures require an Environmental Requirements Review Checklist to be completed by the project manager during the planning stage of a project. The activity checklist specific to cultural resources (Annex 9.6 of ADMP-ENV-EVS-00021) is currently designed to identify if a planned project has the potential to impact archaeological, historic, or architectural resources regardless of National Register of Historic Places-eligibility. Additionally, the current Cultural Resources Procedure (ADMP-ENV-EVS-00095) for facilities operated by Duke Energy identifies the relevant subject matter expert (SME) within the Environmental Health and Safety Team as responsible for consulting with the applicable State Historic Preservation Officer or Tribal Historic Preservation Officer regarding projects that may impact historic or cultural resources,
8 and notifying the relevant party in the event of a discovery situation. The applicable SME is also responsible for ensuring that historic and cultural resources information and regulatory guidance is provided to facility management, environmental and field support, employees, and contractors. To limit the dissemination of information about historic and cultural resources, only those working at the specific project job site will be informed about the potential presence of historic and cultural resources.
21)
RCI-HCR-06 Please confirm that the following statement(s) is correct:
Only one archaeological survey has been conducted within the property boundary:
o 2024 Archaeological Reconnaissance Survey, Robinson Solar Project, Chesterfield and Darlington Counties, South Carolina. Reference 0697866.
SHPO Project No. 24-RL0054. ERM, Duluth, GA.
22)
RCI-SOC-01 Please confirm the following updates to table 3.9-2, showing Duke Energy Property Tax Payments in 2024. Please confirm 2025 payment totals are not yet available. Updates shown in italics.
Table 3.9-2 DEP Property Tax Payments, 2020-2025 Tax Jurisdictions 2020 2021 2022 2023 2024 Darlington County Total Property Tax Paid by Duke Energy
$23,725,408
$25,869,182
$28,232,861
$27,853,699
$25,716,684 Darlington County Total Revenue
$36,582,232
$38,445,212
$41,870,717
$50,474,999
$51,909,453 Property Tax as % of Darlington County Total 64.9 67.3 67.4 55.2 55.0 D1SD Portion of Duke Energy Total Property Tax Appropriated to D1SD
$17,301,195
$18,626,390
$20,496,013
$19,652,246
$23,971,537 Total D1SD Revenue
$141,464,000
$152,729,000
$174,012,000
$184,433,000
$184,154,000 Property Tax as % of D1SD Total Revenues 12.2 12.2 11.8 10.7 13.0 (a) amount rounded to the nearest thousand 23)
RCI-SOC-02 Please confirm the following updates to table 3.9-3, showing Duke Energy emergency preparedness payments for 2024-2025 (updates shown in italics).
9 Table 3.9-3 Local Emergency Preparedness Payments on behalf of RNP, 2020-2025 Recipients 2020 2021 2022 2023 2024 2025 State of South Carolina
$351,789
$378,806
$417,399
$454,485
$509,790
$515,740 Chesterfield County
$22,916
$22,916
$22,916
$22,916
$22,916
$22,916 City of Hartsville
$4,000
$4,000
$4,000
$4,000
$4,000
$4,000 Darlington County
$27,810
$27,810
$27,810
$27,810
$28,847
$29,341 Lee County
$20,000
$23,000
$20,000
$34,000
$34,000
$35,000 Florence County
$11,458
$11,458
$11,458
$11,458
$11,458
$11,458 Hartsville Rescue Squad
$1,000
$1,000
$1,000
$1,000
$1,000
$1,000 Total
$438,973
$468,990
$504,583
$555,669
$612,011
$619,455 24)
RCI-HH-02 Please confirm Duke electrical safety procedures are consistent with NESC (2017 or later) and that in-scope transmission lines are not accessible to the public and have limited access by plant personnel.
25)
RCI-HH-03 Please confirm that the fleet electrical safety procedures, pertaining to Electric Shock Hazards addressed, are in place and the work is conducted under the following electrical safety procedures and safety guidance: General Electrical Safety Work Method, Minimum Approach Distances Work Method, AMP-SAF-HSF-00035, Rev 3, and AD-HS-All-0110 Electrical Safety.
26)
RCI-SNF-01 Please confirm the description in ER Section 3.1.4 is incorrect, and Duke Energy has determined that the current onsite Independent Spent Fuel Storage Installation (ISFSI) pad at Robinson has enough capacity to store spent nuclear fuel through the SLR term.
10 ROBINSON NUCLEAR PLANT, UNIT 2 INITIAL LICENSE RENEWAL APPLICATION ENVIRONMENTAL REVIEW REQUESTS FOR ADDITIONAL INFORMATION 27)
RAI GW-05 REQUIREMENT: Title 10 of the Code of Federal Regulations (10 CFR) Section 51.53(c)(3)(ii)(C) requires that if the applicant's plant pumps more than 100 gallons (total onsite) of groundwater per minute, an assessment of the impact of the proposed action on groundwater must be provided. 10 CFR 51.53(c)(3)(ii)(P) requires an applicant to assess the impact of any documented inadvertent releases of radionuclides into groundwater, including 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.
ISSUE: The U.S. Nuclear Regulatory Commission (NRC) staff is preparing an environmental impact statement (EIS) that considers the impacts of subsequent license renewal for Robinson (RNP) on affected groundwater resources. Among other information, assessing the impact of groundwater pumping (including its effect on inadvertent releases of radionuclides) requires knowledge of the location(s) of groundwater withdrawals and accurate estimates of groundwater withdrawal rate(s). Environmental Report (ER) Section 3.6.3.2 described groundwater use from 13 wells, with well locations shown in ER figure 3.6-6. A summary of RNP yearly groundwater withdrawals from all water supply wells was provided in ER table 3.6-6a for 2019 - 2023 and a monthly summary by purpose (industrial use wells, emergency cooling wells, and irrigation wells) was provided in ER table 3.6-6b. As shown by the yearly totals provided in ER table 3.6-6b, industrial use wells are 99.9 percent of total groundwater withdrawals. As indicated in the notes to ER table 3.6-6b, industrial use withdrawals provided in the table are a sum of monthly withdrawal volumes from nine water supply wells: Well 1, Well 2, Well A, Well B, Well C, Well 9, Well 10, Well AB-1, and Well AB-2.
REQUEST: Please provide yearly groundwater withdrawals (million gallons per year) for each of the nine industrial use wells during each of the years from 2019 - 2024. The NRC staff understand that the withdrawals from Wells A, B, and C are recorded as a combined total and may be provided as such in response to this request. When providing withdrawals for the industrial use wells, compare the sum total withdrawal from all nine wells during each of the years 2019 - 2023 to the value provided in ER table 3.6-6b for that yearly total, and explain the source of any differences in the yearly totals (i.e. the yearly sum total from the nine wells and the yearly total from ER table 3.6-6b).
28)
RAI TER-06 REQUIREMENT: 10 CFR 51.45(d) require the ER to include discussion of the status of compliance with applicable environmental quality standards imposed by Federal, State, regional and local agencies. In addition, 10 CFR 51.53(c)(3)(iv) indicates that an applicants ER must contain any new and significant information regarding environmental impacts of license renewal of which the applicant is aware.
ISSUE: The NRC staff are preparing a supplemental environmental impacts statement (SEIS) that considers the environmental impacts of subsequent license renewal for RNP. As part of the preparing the SEIS, the staff must consider whether the has been any new information related to terrestrial resources. ER Section 3.7.1.2.4 states, "there have been no reported avian
11 incidents at RNP from 2019 through 2024." However, during the site audit, RNP staff indicated that there have been ten avian incidents at RNP during that time period.
REQUEST: Please provide a summary of all avian incidents that have occurred at RNP from 2015 to present and include: (1) the date; (2) the species involved; (3) the condition of the bird and any details regarding its condition; (4) the suspected cause of the incident and any details regarding the suspected cause (including any associated structures); (5) the age of the bird; (6) whether any local or State agencies were contact; and (7) whether any other follow-up actions were taken.
29)
RAI AQU-09 REQUIREMENT: The NRCs regulation at 10 CFR 51.53(c)(3)(ii)(B) requires that if the applicants plant utilizes a once-through cooling or cooling pond water intake and discharge system, the applicant shall provide a copy of current Clean Water Act 316(b) Best Technology Available determinations and, if applicable, a 316(a) variance in accordance with Title 40 of the Code of Federal Regulations (40 CFR) Part 125, or equivalent State permits and supporting documentation. If the applicant cannot provide these documents, it shall assess the impact of the proposed action on fish and shellfish resources resulting from impingement mortality and entrainment and thermal discharges.
The NRCs regulation at 10 CFR 51.53(c)(3)(ii)(B) requires that if the applicants plant utilizes a once-through cooling or cooling pond water intake and discharge system, the applicant shall provide a copy if applicable, a 316(a) variance in accordance with 40 CFR 125, or equivalent State permits and supporting documentation. If the applicant cannot provide these documents, it shall assess the impacts of the proposed action on fish and shellfish resources resulting fromthermal discharges.
The NRC regulation at 10 CFR 51.53(c)(3)(ii)(A) requires that if the applicants plant utilizes cooling towers or cooling ponds and withdraws makeup water from a river, an assessment of the impact of the proposed action on water availability and competing water demands, the flow of the river, and related impacts on stream and riparian ecological communities must be provided.
ISSUE: Because the State has not yet made a Clean Water Act (CWA) 316(b) best technology available (BTA) determination for RNP, the NRC staff require additional information in order to assess the impact of the proposed action on fish and shellfish resources resulting from impingement mortality and entrainment. The NRC staff also require additional information concerning RNPs CWA 316(a) administratively extended / reapplication for a thermal variance in order to assess the impacts of thermal discharges on aquatic organisms. Finally, the NRC staff require additional aquatic studies to understand the stream and riparian ecological communities as they stand today.
REQUEST: Please provide copies of the following document(s):
CWA 316(A) Thermal Effluent Related Studies a) CP&L (Carolina Power and Light Company). 1996. H.B. Robinson Steam Electric Plant Assessment of Potential Biological Impact Associated with Revised Discharge Temperature Limits (Volume 4). Environmental Services Section, New Hill, NC. August.
b) PEC (Progress Energy Carolinas). 2005. H.B. Robinson Steam Electric Plant
12 Alternate Test Species Study Mixing Zone Study and Reasonable Potential Analysis Report. Environmental Services Section, Raleigh, NC. November.
CWA 316(b) Impingement and Entrainment Related Studies a) Normandeau (Normandeau Associates, Inc.). 2007. 2006 Impingement Monitoring at the H.B. Robinson Steam Electric Plant. Report Prepared for Progress Energy Service Company, LLC. Bedford, NH. December 2007.
b) HDR. (HDR Engineering, Inc.). 2019. 2016-2017 Entrainment Characterization Study Report for Robinson Nuclear Plant. Report Prepared for Duke Energy Progress, LLC.
c)
HDR. (HDR Engineering, Inc.). 2022. Clean Water Act 316(b) Compliance Submittal for Robinson Nuclear Plant. NPDES Permit No. SC0002925. Report Prepared for Duke Energy Progress, LLC.
a.
Requesting Section(s): Executive Summary, Chapter 4, Chapter 5, Appendix 4-A Aquatic Environment Characterization Studies a)
Duke Energy (Duke Energy Progress, LLC). 2013. H.B. Robinson Steam Electric Plant 2012 Environmental Monitoring Report. Water and Natural Resources, Environmental Services. Raleigh, NC.
b)
Duke Energy (Duke Energy Progress, LLC). 2016. H.B. Robinson Steam Electric Plant 2013 Environmental Monitoring Report. Water and Natural Resources, Environmental Services. Raleigh, NC.
c)
Duke Energy (Duke Energy Progress, LLC). 2017. H.B. Robinson Steam Electric Plant 2014-2015 Environmental Monitoring Report. Water and Natural Resources, Environmental Services. Raleigh, NC.
d)
Duke Energy (Duke Energy Progress, LLC). 2021. H.B. Robinson Nuclear Plant 2016-2019 Environmental Monitoring Report. Water and Natural Resources, Environmental Services. Raleigh, NC.
e)
CP&L (Carolina Power and Light Company). 1996. H.B. Robinson Steam Electric Plant 1975-1995 Long-term Environmental Monitoring. Environmental Services Section, New Hill, NC. August.
f)
CP&L (Carolina Power and Light Company). 1996. H.B. Robinson Steam Electric Plant Fish Distribution Report and Graphic Illustration of Thermal Plume within Robinson Impoundment (Volume 3). Environmental Services Section, New Hill, NC. August.
30)
RAI-HCR-05 REQUIREMENT: Section 106 of the National Historic Preservation Act (NHPA [54 USC
§306108]) directs Federal agencies to take into account the effect of the undertaking on any district, site, building, structure, or object that is included in or eligible for the National Register of Historic Places (NRHP) within the area of potential effect (APE). NHPAs implementing regulations Title 36 of the Code of Federal Regulations (36 CFR) Section 800.4(1) directs Federal agencies to identify historic properties, including background research, consultation, oral history interviews, sample field investigation, and field survey. In 36 CFR 800.1(c), federal agencies must complete the Section 106 process prior to the issuance of any license. 10 CFR 51.53(c)(3)(ii)(K) requires All applicants shall identify any potentially affected historic and cultural resources and historic properties and assess whether continued operations and any planned refurbishment activities would affect these resources in accordance with the Section 106 of the National Historic Preservation Act and in the context of the National Environmental
13 Policy Act. In addition, 10 CFR 51.53(c)(3)(iv) requires that The environmental report must contain any new and significant information regarding the environmental impacts of license renewal of which the applicant is aware. Also, 10 CFR 40.9(a) requires that Information provided to the Commission by an applicant for a license or by a licensee or information required by statute or by the Commission's regulations, orders, or license conditions to be maintained by the applicant or the licensee shall be complete and accurate in all material respects.
ISSUE: The NRC staff is preparing a SEIS that analyzes the environmental impacts of subsequent license renewal for RNP. As part of SEIS preparation, the staff must consider the aforementioned regulatory requirements. ER Section 3.8.5 states. "An Architectural Survey of RNP and its surrounding area has been performed, and a draft report is planned for March of 2025. Once completed, the survey report will be submitted to the SHPO for review and concurrence.
REQUEST: The NRC is requesting that Duke Energy provide a copy of the architectural report in its entirety, including but not limited to any attachments or appendices, such as the building/structure forms, associated correspondence sent to State Historic Preservation Office, and any correspondence received. Additionally, provide clarifications regarding the following:
Number of buildings/structures in the architectural report APE, including any structures and buildings not evaluated and why If the buildings and structures were evaluated as non/contributing to a district, or only for their individual NRHP-eligibility Confirm that there are no buildings or structures associated with operation located outside the architectural report APE In the architectural report, Appendix A lists 15 contributing building/structures, but the report described 19 NRHP-eligible buildings/structures - clarify the discrepancy 31)
RAI-HH-01 REQUIREMENT: 10 CFR 51.53(c)(3)(i) requires the ER to include impacts of operation during the renewal term, for those issues identified as Category 2 issues in appendix B to subpart A of 10 CFR 51. In addition, 10 CFR 51.53(c)(3)(iv) indicates that an applicants ER must contain any new and significant information regarding environmental impacts of license renewal of which the applicant is aware.
ISSUE: South Carolina Department of Environmental Services (SCDES) was consulted with regards to concerns about any waterborne disease associated with RNPs thermal discharges.
A response \
letter dated July 11, 2025, was received by Duke Energy from SCDES concurring with Duke Energys conclusion that RNPs subsequent license renewal would not adversely affect environment or public health due to exposure to the thermophilic pathogens in Lake Robinson.
REQUEST: Please provide on the docket SCDESs \
July 11, 2025, letter concerning thermophilic pathogens in Lake Robinson 32)
RAI-GHG-01 REQUIREMENT: 10 CFR 51.120 requires copies of the ER draft and final EISs, environmental assessments, and findings of no significant impact, together with any related comments and
14 environmental documents be made available for public inspection.
ISSUE: ER Section 3.13.2.1 states that intake water temperature data is available from May 2014 through May 2024. This data is presented in plots of annual average monthly intake temperature and average monthly seasonal intake temperature as ER figures 3.13-1 and 3.13-2, respectively. In the original submission, ER figures 3.13-1 and 3.13-2 were identical figures.
The correct figure for 3.13-2 has since been submitted to the electronic reading room but is not on the docket.
REQUEST: Please provide on the docket the correct figure for 3.13-2 concerning average monthly seasonal water intake temperature for 2014 through 2024.