NOC-AE-11002691, Response to Request for Additional Information for the Review of the License Renewal Application

Response to Request for Additional Information for the Review of the License Renewal Application

ML11193A074
Person / Time
Site:	South Texas
Issue date:	07/05/2011
From:	Gerry Powell South Texas
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
G25, NOC-AE-11002691, STI: 32893021, TAC ME5122
Download: ML11193A074 (5)

Text

Nuclear Operating Company South Texas Pmject Electric GeneratingStation PO. Box 289 Wadsworth, Texas 77483 -A/vA- m July 5, 2011 NOC-AE-1 1002691 10CFR54 STI: 32893021 File: G25 U. S. Nuclear Regulatory Commission Attention: Document Control Desk One White Flint North 11555 Rockville Pike Rockville, MD 20852-2746 South Texas Project Units 1 and 2 Docket Nos. STN 50-498, STN 50-499 Response to Requests for Additional Information for the Review of the South Texas Proiect License Renewal ADDlication (TAC Nos. ME5122)

Reference:

1. STPNOC Letter from G. T. Powell to NRC Document Control Desk, "License Renewal Application", dated October 25, 2010 (NOC-AE-1 0002607) (ML103010257)

2. NRC letter, "Request for Additional Information for the Review of the South Texas Project License Renewal Application", dated June 17, 2011 (ML11167A113)

By Reference 1, STP Nuclear Operating Company (STPNOC) submitted the License Renewal Application (LRA) for South Texas Project (STP) Units 1 and 2. By Reference 2, the NRC staff requested additional information for the review of the STP LRA. STPNOC's response to the request for additional information is included in Enclosure 1 to this letter.

There are no regulatory commitments in this letter.

Should you have any questions regarding this letter, please contact either Arden Aldridge, STP License Renewal Project Lead, at (361) 972-8243 or Ken Taplett, STP License Renewal Project regulatory point-of-contact, at (361) 972-8416.

I declare under penalty of perjury that the foregoing is true and correct.

Executed on D3a-te . Zell Da~e '

G. T. Powell Vice President, Technical Support & Oversight KJT

Enclosure:

STPNOC Response to Requests for Additional Information 4IA7

NOC-AE-1 1002691 Page 2 cc:

(paper copy) (electronic copy)

Regional Administrator, Region IV A. H. Gutterman, Esquire U. S. Nuclear Regulatory Commission Kathryn M. Sutton, Esquire 612 East Lamar Blvd, Suite 400 Morgan, Lewis & Bockius, LLP Arlington, Texas 76011-4125 Balwant K. Singal John Ragan Senior Project Manager Catherine Callaway U.S. Nuclear Regulatory Commission Jim von Suskil One White Flint North (MS 8B1) NRG South Texas LP 11555 Rockville Pike Rockville, MD 20852 Ed Alarcon Senior Resident Inspector Kevin Polio U. S. Nuclear Regulatory Commission Richard Pena P. O. Box 289, Mail Code: MN116 City Public Service Wadsworth, TX 77483 C. M. Canady Peter Nemeth City of Austin Crain Caton & James, P.C.

Electric Utility Department 721 Barton Springs Road C. Mele Austin, TX 78704 City of Austin John W. Daily Richard A. Ratliff License Renewal Project Manager (Safety) Alice Rogers U.S. Nuclear Regulatory Commission Texas Department of State Health Services One White Flint North (MS 011-Fl)

Washington, DC 20555-0001 Balwant K. Singal Tam Tran John W. Daily License Renewal Project Manager Tam Tran (Environmental) U. S. Nuclear Regulatory Commission U. S. Nuclear Regulatory Commission One White Flint North (MS 011 F01)

Washington, DC 20555-0001

Enclosure NOC-AE-1 1002691 Page 1 STPNOC Response to Requests for Additional Information SOUTH TEXAS PROJECT LICENSE RENEWAL APPLICATION REQUESTS FOR ADDITIONAL INFORMATION REGARDING THE ANALYSIS OF CULTURAL RESOURCE IMPACTED ENVIRONMENT Issue:

The Environmental Report (ER) contains statements referring to missing records of cultural sites, requiring clarification.

Background:

Additional information is needed for the staff review of the cultural resource affected environment associated with license renewal related activities, pursuant to the review criteria in Environmental Standard Review Plan, Supplement 1, Sections (ESRPISIs) 2.2.8 and 4.4.5 and in accordance with the rule (10 CFR 51).

NRC Requested Information:

Provide the following cultural resources information in accordance with information submittal guidelines for cultural resources location information (e.g., exclusion of map details of site locations).

1. The ER states that the third site is missing from the records. Describe the process that was used to identify all three sites located at 3.85 and 4.40 miles from the northeast boundary of the South Texas Project (STP) property. Describe what the statement regarding the third site is referring to regarding the missing record.

STPNOC Response:

During the preparation of ER Section 2.14, an error was made in the interpretation and description of the three sites (Sites 41MG48, 41MG49, and 41MG112). The form for the "missing record" site (Site 41 MG49) was stapled to another site's form and was missed.

Corrected and augmented descriptions of the three sites are provided below (distances to the three cultural sites were measured from a spot measured equal distance between Units 1

& 2):

Site 41 MG48 was originally described as a boat wreck in the License Renewal ER.

However, the site form for this site does not mention a boat wreck. The site is located 5.17 miles northeast of the South Texas Project (STP) site and is a late 19th century artifact scatter associated with homesteading. Local informants reported that the homestead was erected in the 1890s and torn down in 1946. Ceramic, glass, and metal artifacts were recorded, most with manufacturing dates between 1890 and 1910. No subsurface features were identified during shovel testing, and the site was severely disturbed at the time of recording. The investigators who recorded the site recommended that the site was not significant and that no further work on the site was needed.

Enclosure NOC-AE-1 1002691 Page 2 Site 41MG49 was originally reported in the License Renewal ER as having no site form.

However, upon revisiting the information provided by the Texas Archaeological Research Laboratory, the missing site record form was discovered. This site is located 3.97 miles northeast of the STP site and is a shell midden with no associated artifacts. The shell midden consists of oyster (95%) and freshwater clam (5 %) shells. Shovel tests were excavated at the site, but no artifacts were identified. The investigators who recorded the site recommended that the site was significant and that further work should be conducted if it would be impacted.

Site 41MG112 is 4.65 miles northeast of the STP site and is a dismantled historic farmstead dating to the mid-20th century. According to maps, this site once contained at least three structures. At the time of recording, the site consisted'of a scatter of historic artifacts associated with a farmstead (wire nails, asphalt shingles, window and bottle glass, metal cans, white ware ceramics, etc.) and remains of one structure (foundation posts, lumber debris, etc.). Shovel tests were excavated at the site, but no additional features were identified. The investigators who recorded the site recommended that the site was not significant and that no further work on the site was needed.

Formal concurrence by the Texas State Historic Preservation Officer on National Register of Historic Places eligibility for any of the three sites could not be found.

NRC Requested Information:

2. The ER states that a historic grave is located on the STP site. Describe the potential ground disturbing activities (if any) that may take place in this area of the STP site associated with license renewal, Units I and 2, or combined license, Units 3 and 4 (i.e., cumulative impact), activities. Describe the process that STP will follow, if ground disturbing activities occur in this area in the future, for mitigation of adverse impact to cultural resources.

STPNOC Response License renewal for STP Units 1 and 2 will not involve any ground-disturbing activities.

The site was originally planned for four reactors. STP Nuclear Operating Company (STPNOC) submitted comprehensive information on the site and surrounding area to NRC in its application for a combined operating license (COL) (Reference 1). NRC reviewed the COL application and prepared a Final Environmental Impact Statement (Reference 2), which analyzed the impacts on the surrounding communities and natural resources to determine if the STP site is suitable to support additional nuclear power generation. In the FEIS, NRC also evaluated the cumulative impacts of the four units on the surrounding environment.

NRC's cumulative impact analysis considered the possible life extension of Units 1 & 2 by 20 years (Section 2.15 of the License Renewal Application ER - Reference 3).

The COL ER (Reference 1) concluded that Unit 3 & 4 construction activities would not impact the grave site since all ground disturbing activities would occur several miles from the grave site and would be conducted in accordance with STP site environmental compliance procedures.

Enclosure NOC-AE-1 1002691 Page 3

References:

1. South Texas Project Units 3 and 4 COLA (Environmental Rpt), Rev 4. (ML102860592)

2. U.S.NRC, "Environmental Impact Statement for Combined Licenses (COLs) for South Texas Project Electric Generating Station Units 3 & 4, Final Report, NUREG-1 937, Vol.1, February 2011. (ML100770015)

3. STPNOC Letter from G. T. Powell to NRC Document Control Desk, "License Renewal Application", dated October 25, 2010 (NOC-AE-1 0002607) (ML103010257)