ULNRC-06112, Comment (13) of Sarah Kovaleski on Behalf of Ameren Missouri on Draft Supplement 51 for NUREG-1437
| ML14113A372 | |
| Person / Time | |
|---|---|
| Site: | Callaway  |
| Issue date: | 04/07/2014 |
| From: | Kovaleski S Ameren Missouri |
| To: | Division of Administrative Services, Document Control Desk |
| References | |
| 79FR10200 00013, NUREG-1437, ULNRC-06112 | |
| Download: ML14113A372 (10) | |
Text
wlAmeren MISSOURI Callaway Plant April 7, 2014 ULNRC-06112 U.S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555-0001 I) 1~~)
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Ladies and Gentlemen:
10 CFR 2.101 10 CFR 2.109(b) 10 CFR 50.4 10 CFR 50.30 10 CFR 51.53(c) 10 CFR 54 LA DOCKET NUMBER 50-483 CALLAWAY PLANT UNIT 1 UNION ELECTRIC CO.
FACILITY OPERATING LICENSE NPF-30 REVIEW OF THE DRAFT SUPPLEMENT 51 FOR NUREG-1437
References:
- 1) ULNRC-05830 dated December 15, 2011
- 2) Notice of Availability of the Draft Plant-Specific Supplement 51 to the Generic Environmental Impact Statement for License Renewal of Nuclear Plants Regarding Callaway Plant, Unit 1, dated February 12, 2014 By the Reference 1 letter, Union Electric Company (Ameren Missouri) submitted a license renewal application (LRA) for Callaway Plant Unit 1. Reference 2 dated February 12, 2014 transmitted the Notice of Availability of the Draft Plant-Specific Supplement 51 to the Generic Environmental Impact Statement (GELS) for License Renewal of Nuclear Plants Regarding Callaway Plant, Unit 1. The Accession Number for draft Supplement 51 to the GEIS is ML14041A373.
SUNSI Review Complete Template = ADM - 013 E-RIDS= ADM-03 Add= //.-,.
PO Box 620 Fulton, MO 65251 AmerenMissouri.corn
ULNRC-06112 April 7, 2014 Page 2 We have reviewed the Draft Supplemental Environmental Impact Statement (SEIS) for accuracy and are providing comments (refer to Enclosure I-Comments on Draft Supplement 51 to NUREG-1437) for your consideration.
It should be noted that there are no changes to commitments contained within this response.
If you have any questions with regard to this submission, please contact me at (573) 489-9435 or Roger Wink at (314) 225-1561.
Sincerely, Sarah Kovaleski Director, Engineering Design DS/adl
Enclosure:
- 1) Comments on Draft Supplement 51 to NUREG-1437
ULNRC-06112 April 7, 2014 Page 3 cc:
Mr. Marc L. Dapas Regional Administrator U. S. Nuclear Regulatory Commission Region IV 1600 East Lamar Boulevard Arlington, TX 76011-4511 Senior Resident Inspector Callaway Resident Office U.S. Nuclear Regulatory Commission 8201 NRC Road Steedman, MO 65077 Ms. Carmen G. Fells Project Branch I Division of License Renewal Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission Mail Stop 0-1 IF1 Washington, DC 20555 Mr. John Daily, Senior Project Manager Project Branch 1 Division of License Renewal Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission Mail Stop 0-1 IFI Washington, DC 20555 Mr. Fred Lyon Project Manager, Callaway Plant Office of Nuclear Reactor Regulation U. S. Nuclear Regulatory Commission Mail Stop O-8B 1 Washington, DC 20555-2738 Mr. Gregory A. Pick U. S. Nuclear Regulatory Commission Region IV 1600 East Lamar Boulevard Arlington, TX 76011-4511
ULNRC-06112 April 7, 2014 Page 4 Index and send hardcopy to QA File A160.0761 Hardcopy:
Certrec Corporation 4150 International Plaza Suite 820 Fort Worth, TX 76109 (Certrec receives ALL attachments as long as they are non-safeguards and may be publicly disclosed.)
Electronic distribution for the following can be made via Tech Spec ULNRC Distribution:
F. M. Diya C. 0. Reasoner III D. W. Neterer L. H. Graessle B. L. Cox J. S. Geyer S. M. Maglio T. B. Elwood Corporate Communications NSRB Secretary B. C. Daniels M. A. McLachlan G. S. Kremer S. G. Kovaleski R. C. Wink STARS Regulatory Affairs Mr. John O'Neill (Pillsbury Winthrop Shaw Pittman LLP)
Missouri Public Service Commission Ms. Leanne Tippett-Mosby (DNR)
A. J. Burgess G. P. Gary
ULNRC-06112 April 7, 2014 Enclosure I Page 1 of 6 CALLAWAY PLANT UNIT 1 LICENSE RENEWAL APPLICATION COMMENTS ON DRAFT SUPPLEMENT 51 TO NUREG-1437
ULNRC-06112 April 7, 2014 Enclosure I Page 2 of 6 No.
DSEIS Location Comment Suggested Resolution Page Line Section General Ameren is in the process of There are numerous Comment constructing an ISFSI with completion locations in the report expected in 2015. The water filled indicating that the excavation that was made for existing spent fuel Callaway Unit 2 is being filled in, in pool will reach preparation of ISFSI construction.
capacity by 2020.
Prior to the spent fuel pool reaching capacity the ISFSI facility will be available to store spent fuel assemblies.
Also, there are several locations in the report indicating that the excavation previously completed for Callaway Unit 2 is water filled. This excavation has been drained of standing water and is in process of being filled to facilitate construction of the ISFSI project.
2 General The Chamois Power Plant ceased There are numerous Comment operation in September 2013.
references in the report describing the operation of the Chamois power plant.
Since it has ceased operation consider whether the report needs to reflect this change.
3 2-1 30 - 32 2.1 The prior excavation referred to in Consider revising this this section was from initial site sentence to clarify construction in the early 1980s.
that the prior excavation was from initial construction.
ULNRC-06112 April 7, 2014 Enclosure I Page 3 of 6 4
2-8 28 2.1.2.1 Callaway does not use reverse Remove reference to osmosis as a treatment method for reverse osmosis.
liquid radioactive waste.
5 2-9 1 - 4 2.1.2.2 Line 1-4 states "Offgases from the Revise paragraph to main condenser are the major source state "The major of gaseous radioactive waste. Other source of gaseous radioactive gas sources collected by radioactive waste is the system include leakage from purging of the volume steam piping and equipment in the control tank and reactor building, turbine generator discharge of tank building, and radioactive waste vents and other building." This is not correct. In fact, equipment in the the major source of gaseous containment, radioactive waste is purging of the radioactive waste, and volume control tank and discharge of auxiliary buildings."
tank vents and other equipment in the containment, radioactive waste, and auxiliary buildings.
6 2-18 30 2.1.6.1 A statement is made that most of the Consider deletion or water in the circulating system is lost revising as follows:
to the atmosphere, this is misleading "Although small in as only about 1% is lost through comparison to the evaporation, total volume of water in the circulating water system, the largest loss is to the atmosphere."
7 2-18 42 - 46 2.1.6.1 Should state the water flowing down Revise the paragraph the discharge pipeline and discharged as follows: "The to the Missouri River has a maximum temperature of the temperature near 901F. Cooling water flowing down tower blowdown temperatures the blowdown (Outfall 002) vary with season and pipeline and range from about 60-900F. The discharged to the current NPDES Permit does not Missouri River usually contain an upper temperature limit has a maximum or stipulate that the discharge must temperature of not cause the temperature of the approximately 90 °F mixing zone (or the area where the (32 C) (Ameren discharge water meets and mixes 2011d). The-NPDE8 with the river) to increase by more pcrmfiit for l.a..
than 50F (2.80C).
,tabli+*khc the uppc.
liFmit of allowb t
- mp.raturc impc by Callaway on the
ULNRC-06112 April 7, 2014 Enclosure I Page 4 of 6 stipulates that-"h diseharge must not caiuse the tempcraturc of the mixing zone (OF the arca whcrc th:
d~shaged wate meets And mimc; with the riFer) to icrEease by more than 5 *F (2.8
- G) (MDNR 2010a)."
8 2-19 32, 33 2.1.7.1 Incorrectly estimates the volume of Suggest revising water returned to the river. Over the paragraph to state past three years the volume of water that approximately returned to the river has averaged 25% of the water near 4400 gpm with the losses to withdrawn is returned evaporation near 11,000 gpm.
to the river.
Therefore, approximately 25% of the water withdrawn is returned to the river.
9 2-21 10, 11 2.1.7.2 The unit 2 prior excavation hole is in Consider revising this the process of being filled in and will text to match page 2-be completely filled in by 2015. The 37 lines 17 & 18.
GWS pump is used to dewater the structural fill area underlying the power block.
10 2-33 14 Concerning the 401 Water Quality Consider revising.
Certification, Ameren did receive a response letter from the Missouri DNR (dated October 8, 2013) stating that the department considers the permit to provide appropriate environmental protection under the Missouri Clean Water Law and compliance with the Clean Water Act.
11 2-68 Table 2-Number of Callaway employees does Consider reconciling 16 not match what is listed on page 2-57 the two numbers.
12 4-44 18 - 29 4.12.3.1 The Chamois Power Plant ceased Recommend removing operation in September 2013 and is reference to the no longer a cumulative effect on the Chamois Power plant aquatic resources.
or revising to state that it no longer impacts the aquatic resources.
ULNRC-06112 April 7, 2014 Enclosure I Page 5 of 6 13 4-45 29 4.12.3.5 The sentence appears to be misleading. Sentence inappropriately implies that the "license renewal" contributes to the "LARGE" cumulative impact when in fact other major factors outside of existing or future operation of Callaway result in this impact.
Consider revising the text as follows:
"Because of the noticeable destabilization of aquatic resources within the Lower Missouri River as a result of USACE intervention with reservoir construction and channel stabilization, independent of Callaway's existing or future operation, the NRC staff concludes that the cumulative effects have the potential to be LARGE."
14 5-4 17 5.3.2 The fire PRA CDF number has been reduced from 2.OE-5 to 1.68E-5 since the original LAR was submitted.
The current fire CDF is 1.68x10-5. Given that the fire CDF has been reduced since the original LAR, no SAMAs have become more cost-beneficial and therefore changes to the SAMA analysis performed for this application are not needed.
15 8-26 33 8.2.9 The Missouri-Kansas-Texas Railroad Consider removing the in central Missouri is now a state discussion of the rail hiking trail (Katy Trail State Park),
spur to the Callaway with no rails remaining. The Callaway site.
rail spur could not be reconstructed to provide rail access.
16 F-10 8
The stated CDF of 7.6x1OE-6 has an Correct to state a CDF incorrect exponent of 7.6xlOE-5.
17 F-18 11 Safety related water system is Change to essential incorrectly listed as emergency service water.
ULNRC-06112 April 7, 2014 Page 6 of 6 18 H-6 4
Appendix H Two additional sedimentation ponds are currently being designed with installation planned during 2015 as the existing treatment lagoons are approaching capacity.
19 H-6 13, 14 Appendix H The current NPDES Permit does not Consider removing contain a temperature limitation for this sentence.
discharge such that the discharge must not cause the temperature of the mixing zone (or the area where the discharged water meets and mixes with the river) to increase by more than 5°F (31C). Temperature is required to be monitored.
20 H-6 15 Appendix H The statement in the Draft SEIS that Consider revising the "All plant outfalls except one connect section to state:
into a single pipeline..." is not "NPDES outfalls 001, completely accurate.
002, 003, 007, 009, and 016 all connect to a single discharge pipeline that discharges to the Missouri River. Storm water outfalls 010, 011, 012, 014, and 015 each flow to separate area creeks. Note that outfall 009 has never been used."
21 H-9 H.4.3.2 This section fails to acknowledge the Consider revising.
buoyancy and strong photopositive response of pallid larval as mentioned in Section H.4.1 in contrast to the water intake opening of the Callaway intake that may preclude larval impingement and/or entrainment. Emphasis should also be added to note relative small component of river water extracted due to minimal amount of water required by a cooling tower verses a once through cooling water system, i.e., mitigating factor/impacts.