View source for L-08-365, FENOC Comments to NUREG-1437 Supplement 36, Bearer Valley Power Station Draft Environmental Impact Statement

{{Adams
| number = ML083440163
| issue date = 11/24/2008
| title = FENOC Comments to NUREG-1437 Supplement 36, Bearer Valley Power Station Draft Environmental Impact Statement
| author name = Sena P
| author affiliation = FirstEnergy Nuclear Operating Co
| addressee name = 
| addressee affiliation = NRC/Document Control Desk, NRC/NRR
| docket = 05000334, 05000412
| license number = DPR-066, NPF-073
| contact person = 
| case reference number = L-08-365, NUREG-1437, TAC MD6595, TAC MD6596
| document type = Letter type:L
| page count = 6
| project = TAC:MD6595, TAC:MD6596
| stage = Draft Supplement
}}

=Text=
{{#Wiki_filter:Beaver Valley Power Station P.O. Box 4 I--%                                                                       Shippingport,PA 15077 FirstEnergyNuclear OperatingCompany Peter P. Sena II                                                                                      724-682-5234 Site Vice President                                                                             Fax: 724-643-8069 November 24, 2008 L-08-365                                                    10 CFR 54 ATTN: Document Control Desk U. S. Nuclear Regulatory Commission Washington, DC 20555-0001

==SUBJECT:==

Beaver Valley Power Station, Unit Nos. 1 and 2 BV-1 Docket No. 50-334, License No. DPR-66 BV-2 Docket No. 50-412, License No. NPF-73 NUREG-1437 Supplement 36, "Generic Environmental Impact Statement for License Renewal of Nuclear Plants: Regardinq Beaver Valley Power Station, Units 1 & 2 (Draft For Comment)" (TAC Nos. MD6595 and MD6596) (ML082600147)
The attachment provides FirstEnergy Nuclear Operating Company (FENOC) comments on NUREG-1437 Supplement 36, "Generic Environmental Impact Statement for License Renewal of Nuclear Plants: Regarding Beaver Valley Power Station, Units I & 2 (Draft.
For Comment)" (TAC Nos. MD6595 and MD6596) (ML082600147).
There are no regulatory commitments contained in this letter. If there are any questions or if additional information is required, please contact Mr. Clifford I. Custer, Fleet License Renewal Project Manager, at 724-682-7139.
I declare under penalty of perjury that the foregoing is true and correct. Executed on November,&j., 2008.
Sincerely, Peter P. Sena III

Beaver Valley Power Station, Unit Nos. 1 and 2 L-08-365 Page 2

==Reference:==

NUREG-1437 Supplement 36, "Generic Environmental Impact Statement for License Renewal of Nuclear Plants: Regarding Beaver Valley Power Station, Units 1 & 2 (Draft For Comment)" (TAC Nos. MD6595 and MD6596) (ML082600147).

==Attachment:==

FirstEnergy Nuclear Operating Company (FENOC) Comments on NUREG-1437 Supplement 36, "Generic Environmental Impact Statement for License Renewal of Nuclear Plants: Regarding Beaver Valley Power Station, Units 1 & 2 (Draft For Comment)" (TAC Nos. MD6595 and MD6596) (ML082600147) cc:  Mr. K. L. Howard, NRC DLR Project Manager Mr. S. J. Collins, NRC Region I Administrator cc: w/o Attachment Mr. B. E. Holian, NRC DLR Director Mr. D. L. Werkheiser, NRC Senior Resident Inspector Ms. N. S. Morgan, NRC DORL Project Manager Mr. D. J. Allard, PA BRP/DEP Director Mr. L. E. Ryan, PA BRP/DEP

ATTACHMENT Beaver Valley Power Station (BVPS), Unit Nos. I and 2 Letter L-08-365 FirstEnergy Nuclear Operatinq Company (FENOC)
Comments on NUREG-1437 Supplement 36, "Generic Environmental lmoact Statement for License Renewal of Nuclear Plants:
* Regarding Beaver Valley Power Station, Units I & 2 (Draft For Comment)"
(TAC Nos. MD6595 and MD6596) (ML082600147)
Page 1 of 4 EDITORIAL Page      Line       Comment xiii      30       Change tense to 'The NRC staff held two public meetings...'
1-2      25        'appendixes' should be 'appendices' 1-6      43        Change tense to '...the NRC staff held two public meetings...'
Insert the following clause after 'existing OL,' "or be operating pursuant to the 1-7      24        timely renewal provisions of 10 CFR 2.109(b) pending completion of the NRC's review of a license renewal application, the possession...."
1-7      36       A space is need between '(AEA)' and 'of' 2-1       9        'river' should be 'River' 2-2      28        Change 'tunnel' to 'culvert' 2-2      33        Un-hyphenate 'Duquesne-Light-owned' The sentence beginning on Line 42 and continuing onto the next page appears to be incomplete. Seems that text has been left off the page.
Section 2.1.4 is where we first encounter the description of any hypothetical steam 2-10       5     ,generator replacement's "interaction with the environment." Potential resulting interactions should be made more conditional in nature e.g., "would" vs. "will" usage.
2-10      10       'federal' should be 'Federal' 2-13       39       Update the Barnwell June 2008 discussion.
2-13       40       Remove the comma between 'June' and '2008' 2-14       36      'An' should be 'A' 2-17        1       Lines 1 through 7 contain extraneous bullets.
2-18       3       Insert comma after 'FENOC aging management review' 2-18       26      Change 'conclude' to 'concluded' 2-23        2       Insert comma after the 'U.S.'
Change system to be possessive, '...in the nuclear steam supply system's primary 2-24               and secondary...'
2-26               Table 2-2, include a footnote with the meaning of the acronym NDR.

Attachment L-08-365 Page 2 of 4 EDITORIAL (Continued)
Page      Line'     Comment Table 2-2, change formatting of the 'Source Name' and 'Source Type' columns to 2-26               clarify labels.
2-29              Table 2-3, include a footnote for the meaning of the acronym NLR.
2-30       25      Hydrazine should be lowercase Rearrange sentence to read, 'The facility must provide reports to PADEP that 2-30       35     describe the quantities of unrestricted radioactive material released in effluent discharges.'
2-38       12     Change 'semienclosed' to 'semi-enclosed' 2-38       20     Change 'mostly consists' to 'consists mostly' 2-39       15     Change 'mostly consists' to 'consists mostly' 2-41       12     Move '(FENOC 2007a)' to be before the period 2-42       12     In Table 2-5, change 'Molluscs' to 'Mollusks' Section 2.2.6.3 should include discussion on the plants contained in Table 2-6 2-45       6      similarly to the discussion of birds, mammals and reptiles.
2-46      29      Add a space between 'FWS' and 'confirmed' Section 2.2.8.2 does not contain the definition of "MGD" used in section text and 2-52        4      table 2-9.
The sentence beginning on line 23 lacks a reference to verify the noise level of 55 2-57       23      decibels.
2-65       36      Remove the sentence that is related to 'PPL Susquehanna' 2-67       40      Sentence beginning on line 40 does not end in a period on line 42.
2-70       31      Remove the word 'is' after 'above,'
Use of "would" vs. "will:" Given that the Unit 2 steam generator replacement is not a foregone conclusion, use of the term "will" throughout sends a message different 3-3        1      from that conveyed by "would." Change Section 3.1     to be consistent with the language used in Section 3.2.2, page 3-9, Line 4, to ensure a consistent message throughout this chapter, and an accurate portrayal of the conditional nature of the project.
4-4       28      Put acronym in parentheses (NPDES), not the complete term 4-12       32      Insert 'with' after 'consulted' 4-14        1     ,Mixed indentation in the formatting on this page 4-14        5      Add blank line after line 5 4-26       24      Insert an additional space after line 24 4-33       36      Change 'formally' to 'formerly' GEBetz Powerline 3627 is no longer used. Remove the specific product name 4-39       44      and leaving only the generic name of "quaternary amine-based nonoxidizing molluscicide" 4-44        5      Change 're-licensing' to 'license renewal' 6-6       12      Change 'This development do' to 'This development does' 8-36        7      Change 'European Pressurized Reactor' to 'Evolutionary Power Reactor' Include the estimated MWe output of the European Pressurized Reactor and the 8-36        7      US- Advanced Pressurized Water Reactor.
8-40       36      Add space between line 36 & 37

Attachment L-08-365 Page 3 of 4 EDITORIAL (Continued)
Page      Line       Comment 8-41        7      Add space between line 7 & 8 8-41       24      Add space between line 24 & 25 8-41       38      Add space between line 38 & 39 8-45       32      Spell-out acre and hectare versus using "a" and "ha" respectively.
ERRATA Page      Line       Comment Remove the word "dedicated" regarding waste minimization team. Waste 2-16        39      minimization is a function of the FENOC Environmental Peer Group /
Environmental Team, but waste minimization is not its sole or primary function.
Table 2-2, change the following 'Evaporation' values:
* Main Intake Structure 2006: from "NDR" to 10,233,513,828
* Midland Municipal Authority 2004: from 2,684,000 to 2,364,000 "Midland Municipal Authority 2005: from 2,795,000 to 2,454,500 "Midland Municipal Authority 2006: from "NDR" to 2,437,547 Table 2-2, change the following 'Offsite Disposal' value:
                       " Midland Municipal Authority 2006: from "NDR" to 830,300 2-26 The apparent discrepancy is due to the fact that between 2004 and 2006, the PA DEP changed reporting formats. Beginning in 2006, DEP reports no longer separated evaporation from each source name/type, and reported only as one facility. The above data to be input into the table per this comment was submitted to the PA DEP and copies were submitted to NRC as "Supplemental Information" from the environmental audit.
2-30        4      Change '(005)' to '(006)'
Re-word sentence to read, 'According to the "Annual Radiological Environmental 2-31       38      Operating Report," tritium and radionuclides were not detected in samples taken from the Ohio River of water released during normal plant operations.'
It is more accurate to state that there are five (5) standby emergency power diesel generators... (2 @ Unit 1, 2 @ Unit 2, and the ERF EDG) OR say ... four (4) 2-34       25      standby emergency power supply diesel generators, and one (1) emergency response facility generator (because there is only one Emergency Response Facility diesel generator).
The sentence beginning on line 7 states, "According to the Pennsylvania Natural Heritage Program, five aquatic species listed by the Commonwealth of 2-42        7      Pennsylvania as threatened or endangered may occur in the vicinity of BVPS (PNHP 2008)." Table 2-5 list more than five (5) threatened or endangered species in the vicinity of BVPS.
Section 2.2.6 does not include the bald eagle in discussion of wildlife (pg 2-43, 2-43        1      line 34) or threatened species (pg 2-45, line 6 and Table 2-6).

Attachment L-08-365 Page 4 of 4 ERRATA (Continued)
Page      Line      Comment 2-44      30       FENOC does not conduct the transmission line flyovers. The work on transmission lines should be attributed to FirstEnergy rather than FENOC 2-53       19      It should be stated that the NRC's data gathering yielded the same results.
2-70       11      Change 'Two Archaeological Sites...' to 'Three Archaeological Sites...'
Delete sentence stating FENOC is currently collecting additional information in regards to Shippingport Atomic Power Station. Nothing more is needed for 4-25      21       license renewal and any work at Shippingport Atomic Power Station is now captured in BVPS procedures and practices and is beyond the scope of license renewal.
4-25      30       Change 'Two Archaeological Sites...' to 'Three Archaeological Sites...'
Include a statement that the identified radionuclide levels do not exceed regulatory 4-32      13       limits. Line 40 states as such, but would beneficial to state with text in line 13.
4-38        2       Bruce Mansfield is a FirstEnergy plant, not a FENOC plant 4-38        6       W.H. Sammis is a FirstEnergy plant, not a FENOC plant Change 'From 1970 until present...' to 'From 1970 until 1995...' Line 35 an 37 4-38       33       state that FENOC discontinued icthyoplankton and impingement surveys in 1995.
Add 'asiatic clams and' between 'nonnative' and 'zebra mussels' (as invasive 4-40       25       species of impact).
Section 8.2.5.11: Recently enacted state laws in both Pennsylvania and Ohio establish energy conservation targets for both states. These laws do not require 8-48       36       or envision net reductions in overall energy use in the future. Rather, they require that certain amounts of energy savings occur from what would otherwise have been used, i.e., overall energy usage will still be such that BVPS Unit I will still be necessary to meet customer loads.
Section 8.2.6: Recently enacted state laws in both Pennsylvania and Ohio establish energy conservation targets for both states. These laws do not require or envision net reductions in overall energy use in the future. Rather, they require that certain amounts of energy savings occur from what would otherwise have been used, i.e., overall energy usage will still be such that BVPS Unit I will still be necessary to meet customer loads.}}