ULNRC-06132, Update to License Renewal Application Supplemental Response to Iteam 11 of Reference 2

Update to License Renewal Application Supplemental Response to Iteam 11 of Reference 2

ML14212A801
Person / Time
Site:	Callaway
Issue date:	07/31/2014
From:	Bradley G Ameren Missouri
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
ULNRC-06132
Download: ML14212A801 (8)

Text

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~Ameren Callaway Plant MISSOURI

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July 31, 2014 ULNRC-06132 U.S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555-0001 10 CFR2.101 10 CFR 2.109(b) 10 CFR 50.4 10 CFR 50.30 10 CFR 51.53(c) 10 CFR 54 Ladies and Gentlemen:

DOCKET NUMBER 50-483 CALLAWAY PLANT UNIT 1 UNION ELECTRIC CO.

FACILITY OPERATING LICENSE NPF-30 UPDATE TO LICENSE RENEWAL APPLICATION-SUPPLEMENTAL RESPONSE TO ITEM 11 OF REFERENCE 2

Reference:

1) ULNRC-05830 dated December 15,2011

2) ULNRC-05893 dated August 13, 2012 By the Reference I letter, Union Electric Company (Ameren Missouri) submitted a license renewal application (LRA) including an Environmental Report (ER) for Callaway Plant Unit 1. Enclosure 1 to this letter provides information to supplement the response to Item 11 from Reference 2, related to current plans and expectations for sedimentation lagoons from now through the period of extended operation. Ameren communicates with the Missouri Department of Natural Resources Water Protection Program for future expansion of sedimentation lagoons.

It should be noted that there are no commitments contained within this response .

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........................................................................................................................... PO Box 620 Fulton, MD 65251 AmerenMissouri.com ..............

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ULNRC-06132 July 31, 2014 Page2 If you have any questions with regard to this submission, please contact Sarah Kovaleski at (573) 489-9435 or Roger Wink at (314) 225-1561.

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

Executed on :S . . ._ \ 'j 3 IJ ;;? 0 ttf Greg Bradley Director, Engineering Systems DS/nls

Enclosure:

1) Supplemental Response to Item 11 (ULNRC-05893 dated August 13, 2012)

ULNRC-06132 July 31, 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 Mr. Tam Tran Project Branch 1 Division of License Renewal Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission Mail Stop 0-11F1 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 0-11F1 Washington, DC 20555 Mr. Fred Lyon Project Manager, Callaway Plant Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission Mail Stop 0-8B 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-06132 July 31, 2014 Page4 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 S. P. Banker D. W. Neterer L. H. Graessle B.L.Cox M. A. McLachlan G. S. Kremer S. G. Kovaleski J. S. Geyer S. A. Maglio T. B. Elwood Corporate Communications NSRB Secretary B. C. Daniels R. C. Wink STARS Regulatory Affairs Mr. John O'Neill (Pillsbury Winthrop Shaw Pittman LLP)

Missouri Public Service Commission Ms. Leanne Tippett-Mosby (DNR)

E. A. Blocher (STARS PAM COB)

ULNRC-06132 July 31, 2014 Page 1 of 4 SUPPLEMENTAL RESPONSE TO ITEM 11

{ULNRC-05893 dated August 13, 2012)

Sedimentation Lagoons/Sludge Settling Ponds

ULNRC-06132 July 31, 2014 Enclosure 1 Page 2 of 4 QUESTIONS ABOUT SEDIMENTATION LAGOONS/SLUDGE SETTLING PONDS This information is needed to respond to a comment from the Environmental Protection Agency on the Draft Supplemental Impact Statement. We were asked to describe the fate of existing sludge settling ponds during the period of license renewal and provide additional information on the impacts of building new ponds.

Background

• With the information we have we are uncertain about how many new sludge ponds will be needed from now through the end of the license renewal period. From the information submitted the number of new settling ponds could range from 3 to 10.

• In Section 3.1 (General Plant Information, Water Treatment Plant, page 3 of 14) of the Environmental Report submitted with the application it states that "Up to ten settling ponds could be constructed over the life of the plant, with the next pond potentially being constructed within the next three to four years."

• From a response to a request for more information [attached], "Over the next 20 years, assuming that Callaway will continue to get makeup water from the Missouri River, Callaway will need 3 additional sediment retention ponds."

• Also from the same response to the request for more information, "The average life for the sediment retention ponds is between 6- 8 years." If the license is renewed, it will expire 30 years from now (in 2024 ). Assuming each sediment pond is good for 6-8 years, 4-5 new sludge settling ponds will be needed.

Question 1 From now through the end of the renewal period, how many new sludge settling ponds are estimated to be needed?

Answer 1 From now through the period of extended operation, Ameren expects that Callaway will need 4 to 5 additional sedimentation lagoons. Currently, Callaway is planning the construction of 2 of the additional lagoons with completion expected in 2015.

Question 2 What is the estimated size of a new sludge settling pond?

Answer 2 The new sedimentation lagoons will be approximately 440 ft. x 440ft. with a capacity of about 200,000 cubic yards each.

ULNRC-06132 July 31, 2014 Enclosure 1 Page 3 of 4 Question 3 Will the new sludge settling ponds, be constructed on previously disturbed land or undisturbed land?

Answer 3 The new sedimentation lagoons are to be constructed on previously disturbed land.

Question 4 As sludge settling ponds fill up with sediment, will they be reclaimed or left on site as is until decommissioning of the facility, or will the sediment in old ponds be removed so that the old pond can be reused in place of building a new pond?

Answer 4 The long term plan is to close and cap the sedimentation lagoons and return them to a natural state. Ameren will consult with the Missouri Department of Natural Resources Water Protection Program for best practices and plan approval.

Question 5 What will be done with the top soil at each new pond site? Will it be stored for future reclamation activities? During construction will best practice erosion protection methods be practiced?

Answer 5 The excavated soil is to be placed along the berms of the existing lagoons and may later be used for reclamation activities. Ameren employs a program, "Storm Water Pollution Prevention Plan for Ameren Missouri Callaway Plant," which requires the use of construction best practices for erosion control. Additionally, the design change process at Callaway requires that a final environmental evaluation be completed when excavating more than one acre or when completing large construction projects where land is disturbed outside of the owner controlled area. Storm water runoff and erosion control is to be evaluated during this review and requires the use of best management practices for erosion control. Most large construction projects require a separate storm water pollution prevention plan.

Question 6 Will dust suppression be needed as part of new pond construction activities?

Answer 6 Yes, dust suppression is to be utilized during the construction of new sedimentation lagoons.

ULNRC-06132 July 31, 2014 Page 4 of 4 Question 7 How long [does] is it estimated take to construct a new sludge settling pond?

Answer 7 Typically, the engineering design and planning phase takes about a year to complete. Physical construction of the sedimentation ponds are expected to take an additional six months to complete. Ameren is currently constructing two new sedimentation lagoons and expects them to be complete in 2015.

Question 8 In constructing the new settling ponds how will Ameren protect historic and cultural resources?

Will Ameren follow the formal guidelines for protecting archaeological resources in its cultural resources management plan (CRMP), entitled "A Cultural Resource Management Plan for Residual Lands at the Callaway Plant, Callaway County, Missouri"?

Answer 8 As required by Callaway's design change process, a Final Environmental Evaluation (FEE) is required to be performed which includes a review of potential impacts to historic and cultural resources. If the FEE identifies impacts to potentially significant sites the formal guidelines in the Callaway Cultural Resources Management Plan is to be used to mitigate any adverse impacts. Given that the location of the sedimentation lagoons was previously evaluated for cultural resources and the area was previously disturbed by construction activities, Ameren does not expect any impact to cultural resources.