ML15061A110

Comment (9) of Nancy L. Ranekon Behalf of Exelon Generation, LLC on Draft Plant-Specific Supplement 54 to the Generic Environmental Impact Statement for the License Renewal of Byron Station, Units 1 and 2

ML15061A110
Person / Time
Site:	Byron
Issue date:	02/13/2015
From:	Ranek N Exelon Generation Co
To:	Cindy Bladey Rules, Announcements, and Directives Branch
References
80FR55 00009, NUREG-1437 S54
Download: ML15061A110 (21)

Text

James, Lois From: Ranek, Nancy L.:(GenCo-Nuc) <Nancy.Ranek@exeloncorp.com>

Sent: Friday, February 13, 2015 9:56 AM To: James, Lois Cc: Gallagher, Michael P:(GenCo-Nuc); Fulvio, Albert A:(GenCo-Nuc); Hufnagel Jr, John G:(GenCo-Nuc)

Subject:

Minor Updates, Corrections, and Clarifications Regarding Draft NUREG-1437, Supplement 54 Attachments: RS-15-072 - Byron-Comments on Draft SEIS.pdf; 2015.02.12

_MinorUpdatesCorrectionsClarifDSEISSupp54.pdf Hi Lois --

As you know, by letter dated Thursday, February 12, 2015, Exelon submitted comments for the record regarding the Draft NUREG-1437 Supplement 54 for the Byron Station License Renewal. I am attaching that submittal for your information.

With this message, I am also forwarding an informal list of additional minor updates, corrections, and clarifications that NRC may want to consider.

Please call if there are questions.

Thanks.

Nancy L. Ranek -

License Renewal Environmental Lead Exelon Generation, LLC "

200 Exelon Way, KSA/2-E .. -

Kennett Square, PA 19348 2 Phone: 610-765-5369  %-n Fax: 610-765-5658 Email: nancy.ranek@exeloncorp.com This e-mail and any attachments are confidential, may contain legal, professional or other privileged information, and are intended solely for the addressee. If you are not the intended recipient, do not use the information in this e-mail in any way, delete this e-mail and notify the sender. -EXCIP SUNSI Review Complete Template = ADM - 013 E-RIDS= ADM-03 Add= /,(--' _ (/,*-ý -)

1

1f Minor Updates, Corrections, and Clarifications on Draft Supplement 54 to the Generic Environmental Impact Statement for License Renewal of Nuclear Plants Regarding Byron Station, Units 1 and 2 Where suggested changes to the SEIS are provided, they are highlighted with bolded italic font for inserted text and ctrikotHro; font for deleted text.

Page Line Section Comment xxi 11 Executive In the Executive Summary, on page xxi in line 11, Summary add "Revision 1" after the words "(GELS) for License Renewal of Nuclear Plants."

xxiii Executive For consistency with 10 CFR Part 51, Table B-i, Summary insert the following parenthetical into the Executive 2 Summary on page xxiii after the words "Water use conflicts with aquatic resources":

"(plants with cooling ponds or cooling towers using makeup water from a river)" to match, xxiii Executive For consistency with 10 CFR Part 51, Table B-i, edit Summary the text in the Executive Summary on page xxiii as 3 follows:

"Threatened, or endangered, and protected species and essential fish habitat' xxvii 21 to 22 Abbreviations & The two definitions for "APE" provided on lines 21 to Acronyms 22 on page xxvii apply only to "APE" as used in the DSEIS Appendix F. In the main body of the DSEIS, 4 "APE" is used as an acronym for "area of potential effect" as applicable to historic and archaeological resources (see pp. 3-65, 4-46, and 4-106). The additional meaning for APE should be added to the list of Abbreviations & Acronyms.

1-1 19to 20 1.1 In lines 19 to 20 on page 1-1:

" Add a space between "NRP-37" and the word 5 "and".

" License[s] for an additional 20 years - license should be plural.

1-7 20 to 21 1.10 In lines 20 to 21 on page 1-7, add the word "applicable" as follows:

6 "Exelon is responsible for complying with all applicable NRC regulations and other applicable Federal, state and local requirements."

2-2 16 to 18 2.1.2 The following sentence is redundant to information earlier in the paragraph. Suggest deleting:

7 "Examples of these activities include, but are not limited to, replacement of boiling-water reactor recirculation piping and pressurized water reactor steam generators."

8 2-4 29 2.2.2 Change "at the end of this section" to "in section 2.3" 2-5 28 2.2.2 As written, the sentence in line 28 on page 2-5 suggests that only ComEd customers receive 9 electricity from Byron. Consider changing the sentence as follows:

"Byron is owned and operated by Exelon and 2/12/2015

2 Minor Updates, Corrections, and Clarifications on Draft Supplement 54 to the Generic Environmental Impact Statement for License Renewal of Nuclear Plants Regarding Byron Station, Units 1 and 2 Where suggested changes to the SEIS are provided, they are highlighted with bolded italic font for inserted text and strkothro font for deleted text.

Page Line Section Comment provides electricity through Commonwealth

-diser-to the ROI through transmission lines owned by Commonwealth Edison".

2-6 11 2.2.2 In line 11 on page 2-6, hyphenate the words 10 "megawatt hours"as follows:

"megawatt-hours" 2-6 2 2.2.2 In line 2 on page 2-6, consider changing the phrase 11 "... procured from adjoining states ..." as follows:

"... procured from Illinois or adjoining states ...

12 2-7 31 to 33 2.2.2 In lines 31 to 33 on page 2-7, "clean coal technology" is mentioned twice. Delete the duplicate.

2-11 35 2.2.2.1 A short citation to "NRC 2011" is provided in line 35 13 on page 2-11, but no corresponding full citation is provided on page 4-126 in section 4.18 (References).

2-12 23 to 24 2.2.2.2 In lines 23 to 24 on page 2-12, consider inserting text as follows:

14 "The technology is cleaner than conventional pulverized coal plants because some of the major pollutants are removed from the gas stream before combustion."

2-12 46 2.2.2.2 In line 46 on page 2-12, consider inserting text as follows:

15 "The IGCC plant will reduce carbon emissions per MWh by nearly half compared to conventionalcoal-firedpower plants (Duke Energy 2013)."

16 2-15 23 2.2.2.4 Delete the words "the environmental impacts of" on line 23 2-16 45 to 49 2.2.2.4 In lines 45 to 49 on page 2-16 and lines 1 to 2 on and and page 2-17, it is not clear how the information is 17 2-17 1 to 2 pertinent to the proposed wind alternative, which does not include interconnecting of wind farms as a firming capacity method.

2-18 30 to 34 2.2.2.5 The discussion of impacts in lines 30 to 34 on 18 page 2-18 seems out of place. Consider moving it to Chapter 4.

2-20 21 to 22 2.3.3 In lines 21 to 22 on page 2-20, consider changing the sentence as follows:

19 "The NRC staff describedevaaueted such a possible combination alternativeesdeernFbed in Section 2.2.2.4."

2/12/2015

3 Minor Updates, Corrections, and Clarifications on Draft Supplement 54 to the Generic Environmental Impact Statement for License Renewal of Nuclear Plants Regarding Byron Station, Units 1 and 2 Where suggested changes to the SEIS are provided, they are highlighted with bolded italic font for inserted text and ikthro

.. font for deleted text.

Page Line Section Comment 2-21 18 to 19 2.3.3.3 In lines 18 to 19 on page 2-21, consider changing the sentence as follows:

20 "The NRC staff describedevaluated such a possible combination alternativea- dcScF*b in Section 2.2.2.4."

2-22 36 2.3.6 In line 36 on page 2-22, correct the name "Electric 21 Power Resource Institute (EPRI)" as follows:

"Electric Power ReseiFeeResearch Institute (EPRI )".

2-27 Table 2-2 Note 9 In Note 9 for Table 2-2 on page 2-27, change the 1st sentence as follows:

"The Purchased Power Alternative could be 22 disproportionately affect low-income populations bybecause of increased utility bills behause-efresulting from the cost of purchased power."

2-27 Table 2-2 Note 3 Modify Note 3 for Table 2-2 on page 2-27 by replacing the words "these populations" with the words "minority and low-income populations". The 23 revised text should read: "Continued operation of Byron would not have disproportionately high and adverse human health and environmental effects on theseminorityand low-income populations."

24 3-1 9 3.1 In line 9 on page 3-1, change "Ogle, Illinois" to "Ogle County, Illinois".

3-5 1 to 2 3.1.1 To ensure clarity in lines 1 to 2 on page 3-5, consider editing the phrase "(Byron Salvage Site; not 25 contaminated by activities at Byron)" as follows:

"... (Byron Salvage Site; not contaminated by activities at-related to the constructionand operation of Byron Station)..."

3-8 42 to 44 3.1.3.3 In lines 42 to 44 on page 3-8, the text indicates that the essential service water system includes two 12-inch pipelines from the river screen house that are 26 dedicated to providing a source of backup makeup water. Consider whether, for completeness, the additional emergency backup water source for makeup to the essential service water from the two on-site deep wells should also be mentioned.

3-10 10 to 11 3.1.4.1 Change the phrase "... these wastes are either released under controlled conditions via the cooling 27 water system or ... " as follows: "... these wastes are eithefreused, released under controlled conditions via the cooling water system, or..."

2/12/2015

4 Minor Updates, Corrections, and Clarifications on Draft Supplement 54 to the Generic Environmental Impact Statement for License Renewal of Nuclear Plants Regarding Byron Station, Units 1 and 2 Where suggested changes to the SEIS are provided, they are highlighted with bolded italic font for inserted text and tkh font for deleted text.

Page Line Section Comment 28 3-13 30 3.1.4.3 In line 30 on page 3-13, change "would" to "will."

3-13 16 to 18 3.1.4.3 Based on the Byron UFSAR section 11.4.2.4, p.

11.4-11, modify the sentence in lines 16 to 18 on page 3-13 as follows:

29 "Byron has a-drumming and storageareas wher twewithin which a total of four remotely operated cranes (two per unit) are used to tra.spe.-t Rd position thestored drums wh0i*ie- R sterage, as well as transport them to trucks for offsite disposal."

3-14 40 3.1.5 In line 40 on page 3-14, replace "1420.104(a)" with "Sections 1420 through 1422 and 1450" because

§ 1420.104(a) addresses only the ban on disposal of 30 PIMW in Illinois landfills, while taken together, Sections 1420 through 1422 and 1450 address requirements applicable to transportation and disposal of PIMW.

3-15 16 to 18 3.1.6.2 Consider revising the sentence on lines 16 to 18 as follows: "Fuel is supplied to each standby diesel generator via the Fuel Oil System, which contains 31 various tanks and fuel transfer pumps thatsized to provide fuel to each engine for a minimum of 7 days efduring post-accident operation without offsite support."

3-15 37 3.1.6.5 Revise the phrase "are with the scope of the NRC's license renewal review" in line 37 on page 3-15 as 32 follows:

"... are withwithin the scope of the NRC's license renewal environmentalreview".

3-15 43 3.1.6.5 In line 43 on page 3-15, change the word "systems" 33 to "system" and change the word "connect" to "connects".

3-15 18 to 20 3.1.6.2 Because there are smaller tanks within the Fuel Oil System for equipment other than the standby diesel generators, the sentence in lines 18 to 20 on page 3-15 would be more accurate if changed as follows:

34 "Byron's Fuel Oil System nensists ef includes four 25,000-gallon (gal) diesel oil storage tanks dedinated-tefor the two Unit 1 standby diesel generators and two 50,000-gal storage tanks dediated efor the two Unit 2 standby diesel generators(2013d)."

35 3-16 1 3.1.6.5 In line 1 on page 3-16, change the phrase "Both switchyards" to "The switchyard" 36 3-17 19 3.2.1 In line 19 on page 3-17, change "Bryon" to "Byron.

2/12/2015

5 Minor Updates, Corrections, and Clarifications on Draft Supplement 54 to the Generic Environmental Impact Statement for License Renewal of Nuclear Plants Regarding Byron Station, Units 1 and 2 Where suggested changes to the SEIS are provided, they are highlighted with bolded italic font for inserted text and 6trkth1--k font for deleted text.

Page Line Section Comment 3-17 20 to 21 3.2.1 The sentence in lines 20 to 21 on page 3-17 could be misinterpreted to mean that Weld Memorial Park is on the Rock River. Instead, it is on Black Walnut 37 Creek. Consider deleting the phrase "on the Rock River," as follows:

"These parks offer such recreational activities to the public as camping, picnicking, hiking, fishing, and boating on the RAck Rivor."

38 3-17 40 3.2.1 Delete "highways" in line 40 on page 3-17.

3-17 46 to 48 3.2.1 The sentence in lines 46 to 48 on page 3-17 is very awkward. Consider dividing it into at least two separate sentences as follows:

"The Oregon Dam, 4 mi (6.4 km) 39 downstream, creates the pool from which Byron draws its circulating water makeup and to whichdim&Ghare its blowdown is discharged.te-and. The Dam also controls the water level in the poolat-thentkake."

40 3-18 33 3.3.1 Change "ft" to "mi" in line 33 on page 3-18.

41 3-18 14 3.2.2 In line 14 on page 3-18, insert the word "above" before the phrase "mean sea level."

3-19 13 3.3.1 Because, as written, the text does not indicate when annual average temperature measurements were 42 taken, consider specifying the beginning and ending years that define the "62-year period" mentioned in line 13 on page 3-19..

3-19 25 3.3.1 Because, as written, the text does not indicate when annual precipitation measurements were taken, 43 consider specifying the beginning and ending years that define the "30-year period" mentioned in line 25 on page 3-19..

3-20 38 to 40 3.3.2 In line 39 on page 3-20, the phrase "and there are no reported violations since October 1, 2011" is unclear because it suggests that a violation of the Byron FESOP permit limitations may have occurred on October 1, 2011. Consider revising the sentence in 44 lines 38 to 40, as follows:

"Byron has been in compliance with the requirements set forth in the air permit, and there-area review of information for a periodbeginning October 1, 2011 indicates no reported violations-swiee

__ _ __tobor, 1*40."

2/12/2015

6 Minor Updates, Corrections, and Clarifications on Draft Supplement 54 to the Generic Environmental Impact Statement for License Renewal of Nuclear Plants Regarding Byron Station, Units I and 2 Where suggested changes to the SEIS are provided, they are highlighted with bolded italic font for inserted text and trikh font for deleted text.

Page Line Section Comment 3-20 23 to 27 3.3.2 The sentence on lines 23 to 25 on page 3-20 states that McHenry County and Kane County are nonattainment areas for PM2.5. The next sentence on lines 26 and 27 on page 3-20 states that McHenry County and Kane County are "also designated 45 maintenance areas for the PM2.5 standard." As such, the two sentences appear to contradict one another because the counties cannot simultaneously be both "nonattainment" and "maintenance" areas for the same pollutant. Consider better-clarifying the attainment status of McHenry and Kane Counties.

3-22 31 3.3.3 In line 31 on page 3-22, insert a space between the 46 comma in the term "(corona discharge)," and the words "relief valve" as follows:

"... (corona discharge), relief valves, 47 3-23 1 3.3.3 In line 1 on page 3-23, replace the word "chipping" with the word "chirping."

48 3-23 5 3.3 In line 5 on page 3-23, change "(9 km)" to "(1 km)"

because 0.6 mi = 0.966 km 3-23 26 to 27 3.4.1 The sentence in lines 26 to 27 on page 3-23 is also 49 used (verbatim) in Sections 3.2 and 3.3, and in each case a different source document is cited. Consider citing the same source document in all cases.

50 3-27 7 3.5.1 Citation in line 7 on page 3-27 should read "(USGS 2013d, 2013e)" rather than "(USGS 2013d, 20113e)."

3-28 25 to 26 3.5.1.2 For clarity, consider revising the sentence in lines 25 to 26 on page 3-28 as follows:

"*hi&The motivation for this operational limit is e*e.*G*beE- bydocumented in Byron's UFSAR.

The change is suggested because the Byron UFSAR Section 2.4.11.5 (PDF page 1721; UFSAR page 2.4-20) states that "The maximum water requirement 51 for the plant is 107 cfs."

The Byron UFSAR Section 10.4.5 (PDF page 6502; UFSAR page 10.4-8) further states that if consumptive demand at full load exceeds 10 % of the river flow, then net withdrawal will be maintained at a level acceptable to the Illinois Department of Conservation, and if necessary, plant power level will be reduced until river flow increases. There is no mention in the Byron UFSAR, however, of limiting withdrawal to 125 cfs.

52 3-29 27 3.5.1.3 Delete the second period at the end of the sentence 2/12/2015

7 Minor Updates, Corrections, and Clarifications on Draft Supplement 54 to the Generic Environmental Impact Statement for License Renewal of Nuclear Plants Regarding Byron Station, Units I and 2 Where suggested changes to the SEIS are provided, they are highlighted with bolded italic font for inserted text and strikethroh font for deleted text.

Page Line Section Comment in line 27 on page 3-29.

3-29 27 3.5.1.3 For clarity, consider inserting the words "not 53 associated with Byron Station" after the words "various upstream sources" in line 27 on page 3-29.

3-32 28 3.5.2 Change the phrase "within and near the Byron" in line 28 on page 3-32 by deleting the word "the" 54 between the word "near" and the word "Byron" as follows:

within and near the-Byron."

3-36 4 3.5.2.2 Change the phrase "to the southwest of the Byron" in 55 line 3 on page 3-36 by deleting the word "the" between the words "of" and "Byron" as follows:

"... to the southwest of the-Byron."

3-36 44 3.5.2.3 To clarify the shift from discussing groundwater contamination from the Byron Salvage Yard Superfund Site to discussing groundwater contamination from the Byron Station 56 intake/discharge pipeline, consider replacing the words "the plant" in line 44 on page 3-36 with the words "Byron Station," as follows:

"... pipeline that runs from the-plaetByron Station to the Rock River."

57 3-39 9 3.6.2 Should be Phleum pratense, not "pretense" 58 3-39 25 3.6.2 Should be Q. palustris, not "palustria" 59 3-39 27 3.6.2 Should be C. ovata, not "ovate" 60 3-41 Table 3-5 Should be Equisetum pratense, not "pretense" 61 3-41 Table 3-5 Should be Luzula acuminata, not "acuminate" 62 3-45 Table 3-8 Should be Myotis sodalis, not "sodalist" 3-47 14 3.6.4 Suggest using the word "restoration" rather than 63 "addition" on line 14 on page 3-47, as follows:

"... and the possible addition restorationof prairie plant habitat on the Byron property ... "

3-47 17 to 18 3.7 In lines 17 to 18 on page 3-47, consider revising the phrase "from which the facility withdrawals and discharges cooling system make-up and blowdown 64 water" as follows:

"... from which the facility wnthdrFiawlwithdraws andfdfie*haw, cooling system make-up water and to which it dischargesblowdown water."

65 3-54 Table 3-11 The scientific name for White sucker should be 65_ _Catastomus commersoni, not "Catostomas" 2/12/2015

81 Minor Updates, Corrections, and Clarifications on Draft Supplement 54 to the Generic Environmental Impact Statement for License Renewal of Nuclear Plants Regarding Byron Station, Units 1 and 2 Where suggested changes to the SEIS are provided, they are highlighted with bolded italic font for inserted text and st"iko..--,,. font for deleted text.

Page Line Section Comment 3-54 Table 3-11 In row 20 of Table 3-11 on page 3-54, "Notropis spilopterus"is listed as the scientific name for "spottail shiner." This is incorrect because the scientific name for spottail shiner is actually Notropis hudsonius (see DSEIS Table 3-12, p. 3-56). It appears that the DSEIS author relied on the Byron Operating License Environmental Report (ComEd 1981) for the entry of "Notropis spilopterus"in Table 3-11 as the scientific name for spottail shiner.

66 However, the Byron Operating License Environmental Report was in error. In 1981, Notropis spilopterus was the scientific name for the spotfin shiner (rather than spottail shiner). Furthermore, the spotfin shiner was reclassified and renamed Cyprinella spilopteracirca 1990. So, it is now impossible to tell which species was actually collected at that time. Consider either deleting the erroneus row 20 from Table 3-11, or adding an explanatory footnote.

3-58 Table 3-13 Several of the names in the "Common Name" column are actually scientific names. Consider correcting this as follows:

• Change "lctiobinae spp." to "carpsuckers 67 and buffaloes."

" Change "Notropis spp." to "shiners."

" Change "Lepomids" to either "sunfish" (a large group that also includes black bass and crappies) or "bream."

3-64 40 to 42 3.8.1 The text in lines 40 to 42 on page 3-64 states that "As discussed in Section 3.7, the Rock River does not contain marine or anadromous fish species."

However, Section 3.7 contains no such discussion, although a reader knowledgeable about the 68 distribution and life histories of all the fish species listed in Tables 3-11, 3-12, and 3-13 might infer that no marine/anadromous species are present. To improve clarity, consider explicitly stating in Section 3.7 that the data in Tables 3-11, 3-12, and 3-13 demonstrate that no marine/anadromous species are present in the Rock River.

3-67 14 to 15 3.9.1 In lines 14 to 15 on page 3-67, consider deleting from 69 the PDF file for the DSEIS the electronic hyperlinks to external web sites for "loway" and "Mascouten."

70 3-68 1 to 2 3.9.2 In lines 1 to 2 on page 3-68, consider explaining why the cultural resource sites identified in Table 3-15 are 2/12/2015

9 Minor Updates, Corrections, and Clarifications on Draft Supplement 54 to the Generic Environmental Impact Statement for License Renewal of Nuclear Plants Regarding Byron Station, Units I and 2 Where suggested changes to the SEIS are provided, they are highlighted with bolded italic font for inserted text and stik....-,,, font for deleted text.

Page Line Section Comment ineligible for the NRHP. This could be accomplished by changing the sentence in lines 1 to 2 as follows:

"All sites are ineligible for the NRHP because 3-86 23 to 24 3.11.1 In lines 23 to 24 on page 3-86, change the word 71 "environmental" to "environment" as follows:

"... in the environmental that may ...

3-87 13 3.11.2 In line 13 on page 3-87, change the phrase "site-72 specific chemical spill" as follows:

"site-specific oil and chemical spill".

3-87 20 3.11.3 On page 3-87, delete the words "Radioactive Waste" 73 from the beginning of line 20, as follows:

"Radioacttiv- Waste Nuclear plants that have 3-90 22 3.12 On page 3-90, delete the words "Environmental 74 Justice" from the beginning of line 22, as follows:

"EAVi-ronmontal J'-stico Under Executive Order (EO) 12898 ... "

3-91 31 to 32 3.12.1 In lines 31 to 32 on page 3-91, consider revising the words as follows:

75 "... composed 23.7 percent of the total twethree-county population (see Table 341-93-22)."

3-102 29 to 34 3.14 The version of the Byron Storm Water Pollution Prevention Plan provided to the NRC in response to RAI WR-SW-1 b [Exelon letter RS-13-282 to NRC, 76 12/19/2013] is dated January 2013 (rather than June 2003). The citation for this document provided in lines 29 to 34 on page 3-102 (i.e., Exelon 2003) should be corrected accordingly.

4-14 15 to 16 4.3.5.1 Revise the sentence in lines 5 to 6 on page 4-14 to indicate that Illinois is included among the states covered by CAIR, as follows:

77 "The CAIR requires 27 states (including Illinois, Indiana, Iowa, Michigan, Missouri, Kentucky, and Wisconsin) to improve air quality, .... "

4-15 41 4.3.5.2 In line 41 on page 4-16, delete the word "construction" as follows:

78 "The NRC Staff concludes that cc~str'-rtopp operation-related noise impacts from the NGCC alternative would be SMALL."

2/12/2015

10 Minor Updates, Corrections, and Clarifications on Draft Supplement 54 to the Generic Environmental Impact Statement for License Renewal of Nuclear Plants Regarding Byron Station, Units 1 and 2 Where suggested changes to the SEIS are provided, they are highlighted with bolded italic font for inserted text and .tik-tho,.h font for deleted text.

Page Line Section Comment 4-15 45 4.3.6 For consistency among the discussions of generating and and capacity for all alternatives, consider using "MWe" 79 4-16 1, 4, & 9 instead of "MW" in line 45 on page 4-15 and lines 1, 4 and 9 on page 4-16, when discussing the generating capacity of the proposed components of the Combination Alternative.

4-16 4 4.3.6 In line 4 on page 4-16, revise the phrase "The NGCC 80 alternative" as follows:

"The NGCC portion of the combination alternative".

4-16 5 4.3.6 In line 5 on page 4-16, revise the phrase "that sites 81 would be located at" as follows:

"... that sitesthe new unit would be located at ... "

4-16 14 4.3.6.1 In line 14 on page 4-16, delete the word "that" as 82 follows:

approximately 10 percent kat-of the NGCC alternative" 4-17 7 4.3.6.1 In line 7 on page 4-17, revise the phrase "the NGCC 83 alternative" as follows:

... the NGCC portion of the combination alternative" 4-17 6 4.3.6.1 On p. 4-16, line 14, the NGCC component of the combination alternative is characterized as having 10 84 percent of the electrical output of the NGCC alternative, rather than 13 percent as indicated here (on page 4-17, line 6). Please resolve the inconsistency.

4-17 9 to 10 4.3.6.1 The possibility that the NGCC component of the Combination Alternative would have multiple units and multiple sites is introduced on page 4-17 in lines 85 9 to 10. In contrast, the text on page 4-16, line 4, section 4.3.6.1, states that the NGCC component of the Combination Alternative would be one 267-MW unit. Please resolve the inconsistency.

4-18 23 4.3.6.2 In line 23 on page 4-18, consider deleting the 86 redundant sentence, as follows:

"M.nor

... of.i*to , o bo pipolino Gurce..could comrofeseor statinns" 4-18 45 4.3.6.2 In line 45 on page 4-18, solar tracking devices are included in a list of potential noise sources for the 87 solar PV portion of the combination alternative.

However, one advantage of PV solar compared to other solar technologies is that direct exposure to sunlight is not necessary for the PV panels to 2/12/2015

11 Minor Updates, Corrections, and Clarifications on Draft Supplement 54 to the Generic Environmental Impact Statement for License Renewal of Nuclear Plants Regarding Byron Station, Units 1 and 2 Where suggested changes to the SEIS are provided, they are highlighted with bolded italic font for text and t-,.u

.inserted

..- . font for deleted text.

Page Line Section Comment function, which eliminates the need for solar tracking.

Accordingly, consider deleting solar tracking devices as a potential source of noise in line 45 on page 4-18.

4-20 17 4.3.8 In line 17 on page 4-20, revise the phrase "... and 88 expected to be SMALL" as follows:

"... and are expected to be SMALL".

4-20 17 to 18 4.3.8 In lines 17 to 18 on page 4-20, revise the phrase

"... from operation of the IGCC, combination, and 89 purchased power are expected ... " as follows:

"... from operation of the IGCC, combination, and purchased power alternativesare expected ... "

90 4-23 Table 4-5 col 1/row 3 In Table 4-5, column 1 and row 3 on page 4-23, Replace the word "patters" with the word "patterns".

4-23 2 4.5.1.1 In line 2 on page 4-23, consider revising the 91 subsection title as follows for better consistency with other subsection titles within section 4.5.1.1:

"Generic Surface Water Resources Issues" 4-25 4 to 5 4.5.1.2 On page 4-25, revise the subtitle on lines 4 to 5 to match the words in Table 4-6, col 1, row 4,as follows:

"Groundwater Use Conflicts (Plants UsiPg 92 With Closed-cycle Cooling T-eweRFs-Cooling Ponds And Withdrawing That Withdraw Makeup Water From a Smell River)"

4-27 11 4.5.3.1 In line 11 on page 4-27, revise the wording as follows:

"NRC staff expects that thatthe State would 93 In addition, since the new nuclear alternative is prohibited in Illinois, consider providing a basis for the expectation that the host state for the new nuclear plant would impose limits on surface water withdrawals similar to those imposed by Illinois on the Byron Station.

4-27 45 4.5.4.1 In line 45 on page 4-27, consider changing "use of 94 the Byron site" to "use of an existing power plant site".

4-28 35 4.5.5.1 In line 35 on page 4-28, consider changing "use of 95 the Byron site" to "use of an existing power plant site".

2/12/2015

12 Minor Updates, Corrections, and Clarifications on Draft Supplement 54 to the Generic Environmental Impact Statement for License Renewal of Nuclear Plants Regarding Byron Station, Units 1 and 2 Where suggested changes to the SEIS are provided, they are highlighted with bolded italic font for inserted text and -- font for deleted text.

Page Line Section Comment 4-29 24 4.5.6.1 In line 24 on page 4-29, consider replacing the words 96 "alternative sites" with the words "another existing power station site".

4-30 35 4.5.7.2 In line 35 on page 4-30, consider replacing the words 97 "for the other alternatives" with the words "for the proposed action as well as the other alternatives."

4-32 15 to 26 4.6.1.2 Since no other Chapter 4 author/section (excluding Cumulative Impacts, Section 4.16) discusses steam generator replacement impacts, consider deleting the 98 text in lines 15 to 26 on page 4-32. Doing so would provide an approach to the impact assessment in section 4.6.1.2 that is more consistent with other sections.

4-38 16 to 18 4.7.1.2 Consider changing the sentence in lines 16 to 18 on page 4-38 as follows:

"Thus Byron useswould have used between 99 0.7 and 1.7 percent of the Rock River's flow each year for the past 12 years, under the conservative assumption that Byron was operating a 100 percent power at all times."

4-38 24 to 26 4.7.1.2 Consider changing the sentence in lines 24 to 26 on 100 page 4-38 to add mussels, as follows:

"The fish and mussel species described in Section 3.7... do not appear to be affected ... "

4-41 18 4.8.1 In line 18 on page 4-41, change the text as follows:

101 "Appendix D4C. 1 contains information on the NRC staff's section 7 ... "

4-50 25 to 32 4.10 The introductory paragraph to Section 4.10

("Socioeconomics") in lines 25 to 32 on page 4-50 is very general and seems out of place. Consider deleting the entire paragraph and replacing it with the 102 following:

"This section describes the potential impacts of the proposed action (license renewal)and alternativesto the proposed action on socioeconomic NEPA issues."

4-53 25 4.10.3.1 Because the reference document (NRC 2008) was not authored by Exelon and does not address an Exelon facility, the sentence in line 25 on page 4-53 103 should be revised as follows:

"EXeIGRlt has been estimated that the construction workforce for a new 2-unit nuclearplant would peak at 3,500 workers (NRC 2008)."

2/12/2015

13 Minor Updates, Corrections, and Clarifications on Draft Supplement 54 to the Generic Environmental Impact Statement for License Renewal of Nuclear Plants Regarding Byron Station, Units 1 and 2 Where suggested changes to the SEIS are provided, they are highlighted with bolded italic font for inserted text and triko font for deleted text.

Page Line Section Comment 4-53 22 to 24 4.10.3.2 Consider including refueling outage workforce 104 increases among the causes of transportation impacts listed in lines 22 to 24 on page 4-53.

4-54 22 to 23 4.10.4.2 In lines 22 to 23 on page 4-54, change the text as 105 follows:

"... the four-unit IGCC power p4aRtplant would consist of..."

4-63 41 4.11.1.2 Because Section 5.3 does not discuss the results of the Staffs SAMA review, delete the sentence in line 106 41 on page 4-63, as follows:

"The rcsults of the review aro diccussedi 4-69 10 4.11.3 In line 10 on page 4-69, change the phrase "two new 107 nuclear power plants" as follows:

"... two new nuclear ,pewe#-f*..antunits 4-69 11 4.11.3 In line 11 on page 4-69, consider changing the 108 phrase "to those ofthe existing Byron" as follows:

"... to those of operatingthe two existing Byron units."

4-69 14 4.11.3 In line 14 on page 4-69, change the words "the operation of two new nuclear plants would be 109 SMALL" as follows:

"... the operation of two new nuclear plansunitswould be SMALL."

4-69 17 4.11.4 In line 17 on page 4-69, verify that the phrase "combustion-based renewable energy" is correct.

110 Other than possibly biomass combustion, Exelon is unaware of any renewable energy sources that are combustion-based, and section 4.11.4 does not address a biomass alternative.

4-69 21 4.11.4 For consistency with the assumption throughout the other sections in Chapter 4 that new construction 111 would be at an existing power plant site that might be either nuclear or coal-fired, consider replacing the words "existing nuclear plant" in line 21 on page 4-69 with the words "existing power plant".

4-69 28 to 29 4.11.4 Note that air pollution control equipment does not generate additional ash. Accordingly, consider changing the words "equipment for controlling air pollution generates additional ash and scrubber 112 sludge" in lines 28 to 29 on page 4-69 as follows:

... equipment for controlling air pollution generate*captures additional ash and produces scrubber sludge, which must be managed as coal combustion wastes."

2/12/2015

14 Minor Updates, Corrections, and Clarifications on Draft Supplement 54 to the Generic Environmental Impact Statement for License Renewal of Nuclear Plants Regarding Byron Station, Units 1 and 2 Where suggested changes to the SEIS are provided, they are highlighted with bolded italic font for inserted text and strikothr" font for deleted text.

Page Line Section Comment 4-83 19 to 41 4.13.4 and 4.13.5 As a clarification, consider noting in sections 4.13.4 and 4.13.5 that the discussions of Waste Management and Pollution Prevention for the IGCC 113 and NGCC Alternatives focus solely on solid waste.

Airborne waste is considered separately, under the sections on Air Quality, but is nevertheless a source of pollution.

4-86 27 4.15.1.2 The acronym "VOC" should be defined in line 27 on 114 page 4-86 as well as in the list of Abbreviations and Acronyms on page xxxvii.

4-89 14 to 15 4.15.3 Because the sentence in lines 14 to 15 on page 4-89 inaccurately suggests that Byron's GHG emissions are linked in some considerable way to climate change, consider revising the sentence as follows:

"The following sections discuss GHG 115 emissions released from operation of Byron Station-and-thep._They also discuss environmental impacts that could generally occur from changes in climate conditions, although the significantcontributory effects would come from other sources independent of Byron Station."

4-89 21 4.15.3.1 The acronym "HFC" should be defined in line 21 on 116 page 4-89 as well as in the list of Abbreviations and Acronyms on page xxxi.

4-92 10 Table 4-22 On page 4-92, in the 2 n, column (labeled "CO 2e") of Table 4-22, the entries in the rows titled "Byron 117 Station continued operation" and "New Nuclear,"

should be changed from "1.363x0 03, to "1.363x1 04 MT/year.

4-104 26 to 29 4.16.4.6 To clarify the conclusions in section 4.16.4.6 (lines 26 to 29 on page 4-104), consider inserting the words

'although the only significant contributory effects in the region would be from projects other than Byron 118 Station" after the words "impacts to terrestrial resources" in line 29, as follows:

"... impacts to terrestrial resources although the only significant contributory effects in the region would be from projects other than Byron Station."

4-111 25 to 27 4.16.11 Consider the following clarifying edits in lines 25 to 27 on page 4-111:

119 "As described in Section 4.15.3.1, operations at Byron Station emit GHG emissions directly and indirectly. Therefore, it is recognized that 2/12/2015

15 Minor Updates, Corrections, and Clarifications on Draft Supplement 54 to the Generic Environmental Impact Statement for License Renewal of Nuclear Plants Regarding Byron Station, Units 1 and 2 Where suggested changes to the SEIS are provided, they are highlighted with bolded italic font for inserted text and &Hrk1tho-k font for deleted text.

Page Line Section Comment GHG emissions from continued Byron Station operation may contribute to climate change, although the incrementalcontributions from Byron Station are insignificantin comparison to the contributionsfrom other sources."

Absent this clarification, the sentence is misleading in terms of the overall impact of Byron Station. For example, the GHG emissions from the NGCC alternative exceed those from the operation of Byron Station by approximately 500 times. As another example, the GHG emissions from Byron employee vehicles are comparable to the remaining Byron Station emissions. If those employees were commuting to a different location, the GHG emissions would be unlikely to change significantly.

4-112 29 to 31 4.16.11 To clarify the conclusions in section 4.16.11, consider inserting the words "although the impacts will be overwhelmingly due to other projects around the world independent of Byron Station" after the word 120 "MODERATE" in line 31 on page 4-112, as follows:

"... would be MODERATE, although the impacts will be overwhelmingly due to otherprojects around the world independent of Byron Station."

2/12/2015

16 Minor Updates, Corrections, and Clarifications on Draft Supplement 54 to the Generic Environmental Impact Statement for License Renewal of Nuclear Plants Regarding Byron Station, Units 1 and 2 Where suggested changes to the SEIS are provided, they are highlighted with bolded italic font for inserted text and rtFkth,ouoh font for deleted text.

... .... .. .. . .. . ...... .... _ ,7 1.. ..... ... . ... .. te x... .

Page Line Section Comment Consider changing the sentence in lines 22 to 24 on page F-1 as follows:

"Exelon submitted all 18 potentially cost-121 F-i 22 to 24 F.1 beneficial SAMAs to the Byron Plant Health Committee for further implementation consideration in accordancewith current Byron processes and proceduresfor evaluatingpossible plant modifications."

To improve clarity, revise the sentence in lines 43 to 45 on page F-1 as follows:

"However, Exelon determined that the other SAMA would not be cost-beneficial if-given Exelon's possible implementation of 122 F-1 43 to 45 F. 1 anotherSAMA that addresses insights from the Fukushima Daiichi accident and which, if implemented, were implemented sincoe it would mitigate many of the largest contributors to the Byron severe accident risk."

In line 16 on page F-2, insert the words "a factor of' between the word "by" and the number "2.5" as 123 F-2 16 F.2.1 follows:

... by multiplying the estimated benefits for internal events by a factor of 2.5."

The sentence in lines 9 to 11 on page F-5 appears to be incomplete. Consider revising it as follows:

"The NRC staff review concluded that, while Exelon did not provide a definition of vulnerability, Exelon identified one 'potential vulnerability' and one enhancement-were."

12 5 F -8 34 F .2 .2 .1 In " line u ii 34 r on o page e " F-8, define the acronym "AP" as "auxiliary power".

To improve clarity, consider revising the sentence in lines 31 to 33 on page F-9 as follows:

126 F-9 31 to 33 F.2.2.1 "This requirement results from SWVs service water being taken from Lake Michigan, the whesepwatt& temperature of which varies throughout the year."

2/12/2015

17 Minor Updates, Corrections, and Clarifications on Draft Supplement 54 to the Generic Environmental Impact Statement for License Renewal of Nuclear Plants Regarding Byron Station, Units 1 and 2 Where suggested changes to the SEIS are provided, they are highlighted with bolded italic font for inserted text and trketho-u-; font for deleted text.

Page Line Section Comment Consider revising the sentence in lines 4 to 5 on page F-10 as follows:

"The Byron IPEEE was submitted in December 1996 (CoinEd 1996), in response 127 F-10 4to5 F.2.2.2 to Supplement 4 of GL 88-20 (NRC 1991),

which requested that each power reactor licensee identify and reportto the NRC plant-specific vulnerabilitiesto severe accidents caused by external events."

Consider revising sentences in lines 34 to 35 on page F-10 as follows:

"The majority of the outliers involved seismic interaction concerns that were resolved through seie appropriatelicensee 128 F-10 34 to 35 F.2.2.2 corrective actions. Others were resolved either by Conservative Deterministic Failure Margin capacity analysis that te showed that the seismic capacity substantially exceeded the-wellbeyeREd review-level earthquake demand, or by maintenance or modifications."

Consider revising the sentence in lines 13 to 16 on page F-16, as follows:

"In response to an NRC staff RAI, Exelon stated that the input for the MAAP cases specified the fission product masses (as opposed to radionuclideactivity values) as recommended by the MAAP Users Group Bulletin, "MAAP-FLASH #68" (Exelon 2014)."

Consider revising the sentences in lines 23 to 27 on page F-20 as follows:

"StandardizedGgeneric economic data inputs that isare applied to the region as a whole were obtained from NUREG-1 150 (as reflected in the MACCS2 Sample Problem A). NUREG-1150 is a seminal,peer-130 F-20 23 to 27 F.2.2.4 reviewed work in PRA performed by the NRC and the nationallaboratoriesthat includes a Level 3 PRA for five different reactorsites. The NUREG-1150-based inputs were rovi-od from the MACCS2 sample problem input in erderadjustedto account for cost escalation since 1986, the year that the inputs waswere first specified."

2/12/2015

18 Minor Updates, Corrections, and Clarifications on Draft Supplement 54 to the Generic Environmental Impact Statement for License Renewal of Nuclear Plants Regarding Byron Station, Units 1 and 2 Where suggested changes to the SEIS are provided, they are highlighted with bolded italic font for inserted text and etd~keh..ueh font for deleted text.

Page Line Section Comment Consider revising the sentence in lines 13 to 15 on page F-22 as follows:

"Exelon also provided in the ER tabular listings of the Level 2 PRA basic events for 131 F-22 13 to 15 F.3.2 the combined LERF categories and the combined Late Release categories, which in total Rentreb'-te account for approximately 95 percent of the estimated population dose risk and OECR.

Consider inserting the following new sentence in line 2 on page F-22 after the first sentence on the page:

"The RRW is the factor by which the risk 132 F-22 1 to 2 F.3.2 would decrease if the component, train, system, function, initiating event, or HEP is assumed to be perfectly reliable (i.e., if its probabilityof failure were zero)."

Consider revising the sentence in lines 42 to 45 on page F-22 as follows:

"Since Exelon already includes providing for portable ventilation in plant procedures and, as discussed further below, is committed 133 F-22 42 to 45 F.3.2 to installing the "no-leak" RCP seals, the NRC staff concludes that this possible alternative SAMA, to provide portable ventilation during maintenance activities, has been adequately explored and is unlikely to be cost-beneficial."

134 F-24 42 F.3.2 In line 42 on page F-24, change "Bryon" to "Byron."

The text in lines 18 to 22 on page F-27 is redundant to the text on lines 4 to 9 on page F-27. Accordingly, consider deleting it, as follows:

"Ewclon's SAA I1- Q process .icuded roiveing insights from the plant specifiG Fisk studies, and rovieWing plant improvomnt 1 35 F -2 7 18 to 2 2 F .3 .2 considered in p. . . . . . . . . n.. .. . .

While explicit treat_;#men U t oVf oxrnal oIVntSin the SAMA identification prcess war, limitod, the NlRC s-taff deter~mined that the prior implementation of plant moedificattaionis aind thle absence of external event vulnerabilite reasonably jUstify examining prim~arilyth

______ ___internal events risk results forF this-purpose."

2/12/2015

19 Minor Updates, Corrections, and Clarifications on Draft Supplement 54 to the Generic Environmental Impact Statement for License Renewal of Nuclear Plants Regarding Byron Station, Units 1 and 2 Where suggested changes to the SEIS are provided, they are highlighted with bolded italic font for inserted text and o font for deleted text.

Page Line Section Comment Consider revising the sentence in lines 24 to 25 on page F-38 as follows:

"Exelon divided this cost element into two 136 F-38 24 to 25 F.6 parts-the averted onsite cleanup and decontamination cost (ACC) alse eeemmcny referred to 3s ACC, and the averted replacementpower cost (RPCJ."

Consider revising the sentence in lines 38 to 40 on page F-42 as follows:

"Exelon has indicated that all 18 potentially cost-beneficial SAMAs will be submitted to 137 F-42 38 to 40 F.7 the Byron Plant Health Committee for further implementation consideration in accordance with current Byron processes and procedures for evaluatingpossible plant modifications."

Consider changing the title of SAMA 16 in Table F-5 138 F-31 STable F- on page F-31 as follows: "16 - Install high flow SAMA 16, sensors on the p RXnon-essential service water SAMA Title system (WS)"

Consider changing the text in Table F-5 describing 139 F-31 SAMA 16, Table F-5 the modeling assumptions for SAMA 16 as follows:

modeling "Completely eliminates all risk associated assumptions with SWWWS flood event scenarios" 2/12/2015

Gallagher, Carol From: James, Lois Sent: Wednesday, February 25, 2015 9:35 AM To: Bladey, Cindy Cc: Gallagher, Carol Subject Submitting Comments to NRC-2013-018 Attachnnents: 017 - Exelon cover memo for informal comments.pdf Cindy, Attached are comments that Exelon submitted on the Byron DSEIS, NRC-2013-018. Can you add this to the Regulations.gov docket for NRC-2013-0178?

Thank you Lois M. James, Senior Environmental Project Manager Division of License Renewal Office of Nuclear Reactor Regulations lois.iames@nrc.gov (preferred method of communication) 301-415-3306 I