ML090830248

Environmental Site Audit Regarding Cooper Nuclear Station Unit 1 License Renewal Application (TAC MD9763 and MD9737)

ML090830248
Person / Time
Site:	Cooper
Issue date:	04/03/2009
From:	David Pelton License Renewal Projects Branch 1
To:	Minahan S Nebraska Public Power District (NPPD)
Sayoc, Manny, NRR/DLR/RLRB 415-1924
References
TAC MD9737, TAC MD9763
Download: ML090830248 (14)

Text

April 3, 2009 Mr. Stewart B. Minahan Chief Nuclear Officer, Vice President -

Nuclear Cooper Nuclear Station Nebraska Public Power District 72676 648A Ave Brownville, NE 68321

SUBJECT:

ENVIRONMENTAL SITE AUDIT REGARDING COOPER NUCLEAR STATION UNIT 1 LICENSE RENEWAL APPLICATION (TAC NO. MD9763 AND MD9737)

Dear Mr. Minahan:

The U.S. Nuclear Regulatory Commission (NRC) staff has reviewed the Environmental Report submitted by Nebraska Public Power District, in support of its application for license renewal for the Cooper Nuclear Station (CNS) Unit 1 and plans to conduct its environmental site audit at Beaver Valley Power Station (BVPS) during the week of March 30, 2009. To develop the Supplemental Environmental Impact Statement for CNS license renewal, the NRC staff requests that the tours, interviews, or information described in the enclosed list be made available to the extent possible during the CNS environmental site audit. The NRC staff transmitted this list to members of your staff informally by e-mail on March 2, 2009.

If you have any questions, please contact Emmanuel Sayoc at 301-415-2989 or by e-mail at emmanuel.sayoc@nrc.gov, or Tam Tran at 301-415-3617 or by e-mail at tam.tran@nrc.gov.

Sincerely,

/RA/

David L. Pelton, Chief Projects Branch 1 Division of License Renewal Office of Nuclear Reactor Regulation Docket No. 50-298

Enclosure:

As stated cc w/encl: See next page

ML090830248 OFFICE LA:DLR PM:DLR:RPB2 PM:DLR:RPB1 BC:DLR:RPB1 NAME I. King E. Sayoc T. Tran D.Pelton (E. Sayoc for)

DATE 04/01/09 04/01/09 04/01/09 04/03/09

Letter to S. Minahan from D. Pelton Dated April 3, 2009

SUBJECT:

ENVIRONMENTAL SITE AUDIT REGARDING COOPER NUCLEAR STATION UNIT 1 LICENSE RENEWAL APPLICATION (TAC NO. MD9763 AND MD9737)

HARD COPY DLR RF E-MAIL:

PUBLIC [or NON-PUBLIC, if appropriate]

RidsNrrDlrResource RidsNrrDlrRpb1 Resource RidsNrrDlrRpb2 Resource RidsNrrDlrRer1 Resource RidsNrrDlrRer2 Resource RidsNrrDlrRerb Resource RidsNrrDlrRpob Resource RidsNrrDciCvib Resource RidsNrrDciCpnb Resource RidsNrrDciCsgb Resource RidsNrrDraAfpb Resource RidsNrrDraApla Resource RidsNrrDeEmcb Resource RidsNrrDeEeeb Resource RidsNrrDssSrxb Resource RidsNrrDssSbpb Resource RidsNrrDssScvb Resource RidsOgcMailCenter Resource

---

T. Tran E. Sayoc F. Lyon D. Roth (OGC)

A. Jones (OGC)

N. Taylor (RIV)

E. Collins (RIV)

C. Casto (RIV)

B. Maier (RIV)

V. Dricks (RIV)

D. Chamberlain (RIV)

A. Vegel (RIV)

W. Walker (RIV)

G. Miller (RIV)

G. Pick (RIV)

S. Burnell (RIV)

Cooper Environmental Audit Needs List March 30, 2009 - April 3, 2009 Terrestrial Ecology - Richard Bulavinetz Tours Needed:

o Visit several transmission line crossings of wooded areas and one stream/wetland area.

They are as follows:

o The transmission line crossing the wooded bluffs < 200 yards west of Nemaha Co. Rd 648A Avenue, located immediately west of the entrance to Cooper Nuclear Station (CNS).

o The transmission line crossing the small stream/wetlands area one mile west of Rte. 677 and two miles west of Rd 648A Ave.

o The transmission line corridor from the west side of the river, which crosses the river and traverses the wooded wetlands on the east side of the Missouri River, in Missouri. (This crossing may me out of scope - need to verify with Nebraska Public Power District (NPPD)).

o Visit following terrestrial/wetland habitats:

o The five wetlands (based on the Fish and Wildlife Services (FWS) NWI maps) on site on the west side of the Missouri River. (The environmental report (ER) notes only three wetlands. I would like to resolve this discrepancy.)

o The shoreline stabilization projects (levees) on both shorelines in order to categorize the habitat and dynamics. (It appears that much erosion is occurring on the western shoreline on the landward side of the levee system.)

o The wetlands on the east side of the river and the farm field that cuts through it.

(Other resource agencies have expressed an interest in viewing the eastern shoreline and eastern wetlands as possible sites for habitat restoration for endangered species and mitigation.)

Interviews Needed:

o CNS staff or consulting biologist available that is familiar with the transmission line maintenance regime and the shoreline/wetland items mentioned above.

o Two hour meeting to discuss Aquatic and Terrestrial issues with agents from the FWS, Nebraska Game and Parks Commission, and Missouri Dept. of Conservation. This is the same meeting in Aquatics.

Required Documents for Inspection/Questions:

• Please provide an overlay of the in scope transmission line corridor(s) with the Nebraska counties that are being traversed, in addition to a separate list that states the same.

Aquatic Biology - Dennis Logan Tours Needed:

o Tour of intake screen house and discharge structures ENCLOSURE

o If possible, boat tour of intake and discharge as well as nearby marshes and wetlands or areas under discussion for endangered species. If a boat tour is not possible, we would like to see these structures habitats from land.

Interviews Needed:

o Please have CNS staff or consulting biologist available.

o Two hour meeting to discuss Aquatic and Terrestrial issues with agents from the FWS, Nebraska Game and Parks Commission, and Missouri Department of Conservation.

This is the same meeting in Terrestrial.

Required Documents for Inspection/Questions:

• Please gather information about the Missouri River in the vicinity of CNS: depth, average flow throughout the year, substrate types and distribution, cross section, etc.

Radiological - Stephen Klementowicz Tours Needed:

o Tour covering 1) Radioactive waste storage, 2) Radioactive effluent release points, 3)

Representative sample of radioactive effluent monitoring systems,

4) Representative sample of radiological environmental monitoring stations (including any co-located State monitoring stations).

Interviews Needed:

o Radiological effluent and environmental personnel Required Documents for Inspection:

• Information on any abnormal, unusual spills or leaks in accordance with 10 CFR 50.75(g) or Nuclear Energy Institute Groundwater Protection Initiative reports.

• Information on the on-site disposal (10 CFR 20.2002) of radioactive material.

• Information regarding the radiological groundwater monitoring program.

Hydrology - Dennis Beissel Tours Needed:

o Tour of the circ water system, intake, discharge, National Pollutant Discharge Elimination System (NPDES) and other outfalls, ground water monitoring network, sewage treatment plant (in addition to general site tour).

Interviews Needed:

o Plant environmental staff, people who do NPDES monitoring/sampling or other water sampling.

Required Documents for Inspection:

• NPDES permit compliance records, any notice of violations, etc.

Air Quality - Ekaterina Lenning Tours Needed:

o Tour of meteorological tower(s)

Interviews Needed:

o None Required Documents for Inspection/Questions:

• Please provide copies of all applicable air permits (past 5 years) including open burning or fire permits if such activities take place at CNS.

• Please, list all emission sources and materials emitted, if air permit does not contain this information.

• How does CNS dispose and/or re-use burned diesel oil and lube oil?

• Are there any incinerators onsite?

• As stated in CNS ER:

In 2008, a new 100-meter tower is being erected and fully instrumented approximately 2,000 feet northwest of the original 100-meter meteorological tower erected in 1981. The equipment and monitoring system for the new 100-meter tower is nearly identical to that currently operational on the original 100-meter tower. The meteorological monitoring system associated with the new 100-meter tower is to become fully operational in April 2009 and is described below.

• Is this project on schedule? Any changes to the plans that would significantly modify the outcome?

• Is the description of the Cooper Nuclear Station Meteorological Program, meteorological tower(s), description of instrumentation and description of the review and data quality assurance process for meteorological data presented in CNS ER most recent?

Non-Radiological Waste - Ekaterina Lenning Tours Needed:

o None Interviews Needed:

o None Required Documents for Inspection/Questions:

• CNS ER states that: Bacteria that occur naturally in the Missouri River may contribute to the growth of biological film fouling of the main condenser tubes. The station is proceeding with a study to determine if routine chemical injection (chlorine, bromine, etc.) will be effective in eliminating the microbiological film on the interior walls of the

condenser tubes. Is this study completed? If yes, what are the conclusions and decisions: will CNS inject chemicals routinely? If yes, please specify which ones.

• Please, briefly describe how CNS industrial and wastewater streams are treated.

• Copies of all applicable waste permits.

• Please provide copies of the Section 312 (TIER II) annual reports to EPA with a list of hazardous and toxic chemicals.

• Does CNS produce any low-level mixed wastes?

• Does CNS produce any medical wastes? What quantity and how is it handled?

• Table 3.2-1 in CNS ER specifies quantities of nonradioactive waste generation for years 2003 - 2007. Please, provide brief explanation on the causes of the increases in quantity of the nonradioactive waste in following years:

o For used oil there was substantial increase in quantities in 2004 - 2007 with a pick of 306,361 pounds in 2006.

o Electronic waste increase in 2007.

o Universal waste batteries increase in 2006.

o Hazardous waste increase in 2006-2006.

Alternatives - Allison Travers Tours Needed:

o Nothing specific to alternatives Interviews Needed:

o CNS or contractors that wrote the alternatives section of the ER.

Required Documents for Inspection/Questions:

• Nothing specific to alternatives Archaeology - Jennifer Davis Tours Needed:

o Archaeology onsite and immediate area, based on findings of the CNS site Archeology study. (the State Historic Preservation Officer (SHPO) may come along)

Interviews Needed:

o CNS or contractors that wrote Archaeology sections of the ER.

Required Documents for Inspection/Questions:

• The ER makes no mention of surveys being conducted prior to plant construction. Were any other surveys/investigations conducted prior to construction of CNS (other than the Dawson survey)? If so, I need to see copies of all of the reports. Need map of sites and would like to visit those sites at the audit.

• Would like a copy of the 2007 and 2008 Phase 1A Literature Review and Archaeological Sensitivity Assessment.

• Would like a copy of the William Dawson House (Site # NH00-69) study.

• Would like a copy any reports or papers associated with the Whitten Archaeological Survey (Archaeological Survey No. 25NH4).

• Provide information associated with the historical land use of CNS site (land use of the site prior to the construction of CNS). The ER mentions 2 farmsteads. Did those farmsteads comprise the total acreage of the site?

• Who owned the land prior to NPPD? When was it purchased? Land use history of the site prior to power plant.

• Would like to see any photos that show the plant site pre - during - and post construction.

• Would like to see any old maps of the site prior to plant construction.

• Has Nebraska and Missouri SHPOs reviewed onsite procedures re: cultural resources?

Would the SHPO be contacted in the case of an inadvertent discovery? Will a cultural resource professional be called in to evaluate inadvertent discoveries?

• Would like to have copies of any correspondence with the Nebraska and Missouri SHPOs that were not included in the ER.

• What training does the Environmental Coordinator have in relation to Section 106 guidelines?

• Would like to review maintenance procedures for t-lines. Do they take into account the protection of cultural resources?

• While the procedures do include a high probability archaeological site map, please provide a land disturbance map that identifies areas of heavy, moderate, low, and undisturbed areas of plant property.

• Please provide a map that clearly delineates the plant property boundary.

Environmental Justice, Socioeconomics - Jeffrey Rikhoff Tours Needed:

o none Interviews Needed:

o CNS or contractors that wrote Environmental Justice, Socioeconomics sections of the ER.

Required Documents for Inspection/Questions:

• Environmental Justice To help address the provisions of Section 4-4 Subsistence Consumption of Fish and Wildlife in Executive Order 12898, the NRC needs information about current or past wildlife sampling and testing of game animals such as deer, squirrel, turkey, pheasant, duck, and other game birds and animals that may have been conducted in the vicinity of the CNS by the state and/or the owner/operators of the plant. Wildlife sampling and testing may have been conducted at CNS by either the applicant or the state before, during, and after plant construction in the early days of plant operation.

• Socioeconomics In addition to the PILOT, retail, and miscellaneous tax payment information presented in Section 2.7 of the ER, please describe any other significant (sizable) agreed to annual payments, recent one-time payments, and other forms of compensation (if any) provided to local organizations, communities, and jurisdictions (e.g., county, municipality, townships, villages, incorporated places, and school districts) on behalf of CNS.

Also, please provide any information about recent and anticipated adjustments to these payments due to re-assessments and other actions (including legal actions) that resulted in or could result in notable increases and/or decreases in payments.

Other State and Federal Agencies in Attendance:

Robert Harms - Fish and Wildlife Service Charlie Scott - Fish and Wildlife Service Frank Albrecht - Nebraska Game and Parks Commission Larry Shepard - EPA Region 7

Tour Participation General Aquatic Terrestrial Hydrology Radiological Air Quality Archaeology Tam Tran X (NRC)

Dennis X X X X Beissel (NRC)

Richard X X X Bulavinetz (NRC)

Jennifer X X Davis (NRC)

Stephen X X X Klementowicz (NRC)

Ekaterina Lenning (NRC)

Dennis Logan X X X (NRC)

Jeffrey X X Rikhoff (NRC)

Allison X X X X Travers (NRC)

Bo Pham X X (NRC)

Robert Harms X X X Charlie Scott X X X Frank X X X Albrecht Larry X X X Shepherd

Travel Restrictions:

Stephen Klementowicz - Present Tuesday and Wednesday Only Jennifer Davis - Present Tuesday and Wednesday Only

Cooper Nuclear Station cc:

Mr. Ronald D. Asche Mr. H. Floyd Gilzow President and Chief Executive Officer Deputy Director for Policy Nebraska Public Power District Missouri Department of Natural Resources 1414 15th Street P.O. Box 176 Columbus, NE 68601 Jefferson City, MO 65102-0176 Mr. Gene Mace Senior Resident Inspector Nuclear Asset Manager U.S. Nuclear Regulatory Commission Nebraska Public Power District P.O. Box 218 P.O. Box 98 Brownville, NE 68321 Brownville, NE 68321 Regional Administrator, Region IV Mr. John C. McClure U.S. Nuclear Regulatory Commission Vice President and General Counsel 612 E. Lamar Blvd., Suite 400 Nebraska Public Power District Arlington, TX 76011-4125 P.O. Box 499 Columbus, NE 68602-0499 Director, Missouri State Emergency Management Agency Mr. David Van Der Kamp P.O. Box 116 Licensing Manager Jefferson City, MO 65102-0116 Nebraska Public Power District P.O. Box 98 Chief, Radiation and Asbestos Brownville, NE 68321 Control Section Kansas Department of Health Mr. Michael J. Linder, Director and Environment Nebraska Department of Environmental Bureau of Air and Radiation Quality 1000 SW Jackson, Suite 310 P.O. Box 98922 Topeka, KS 66612-1366 Lincoln, NE 68509-8922 Ms. Melanie Rasmussen Chairman Radiation Control Program Director Nemaha County Board of Commissioners Bureau of Radiological Health Nemaha County Courthouse Iowa Department of Public Health 1824 N Street Lucas State Office Building, 5th Floor Auburn, NE 68305 321 East 12th Street Des Moines, IA 50319 Ms. Julia Schmitt, Manager Radiation Control Program Mr. Keith G. Henke, Planner Nebraska Health & Human Services R & L Division of Community and Public Health Public Health Assurance Office of Emergency Coordination 301 Centennial Mall, South 930 Wildwood P.O. Box 95007 P.O. Box 570 Lincoln, NE 68509-5007 Jefferson City, MO 65102

Cooper Nuclear Station cc:

Mr. Art Zaremba, Director of Nuclear Garry Young Safety Assurance License Renewal Manager Nebraska Public Power District Entergy Nuclear P.O. Box 98 1448 S.R. 333, N-GSB-45 Brownville, NE 68321 Russellville, AK 72802 Mr. John F. McCann, Director Alan Cox Licensing, Entergy Nuclear Northeast License Renewal Technical Manager Entergy Nuclear Operations, Inc. Entergy Nuclear 440 Hamilton Avenue 1448 S.R. 333, N-GSB-45 White Plains, NY 10601-1813 Russellville, AK 72802 Steward Minahan Dave Lach Vice President LRP Entergy Project Manager Nuclear and Chief Nuclear Officer Entergy Nuclear Cooper Nuclear Station 1448 S.R. 333, N-GSB-45 72676 - 648A Avenue Russellville, AK 72802 Brownville, NE 68321 Jerry Perry Mike Boyce 500 S. Main Street Cooper Strategic Initiatives Manager Rock Port, MO 64482 Cooper Nuclear Station 72676 - 648A Avenue Yolanda Peck Brownville, NE 68321 1008 Central Ave.

Auburn, NE 68305 Dave Bremer License Renewal Project Manager Kendall Neiman Cooper Nuclear Station 830 Central Ave.

72676 - 648A Avenue Auburn, NE 68305 Brownville, NE 68321 Annie Thomas Bill Victor 1522 I Street License Renewal Project Licensing Lead Auburn, NE 68305 Cooper Nuclear Station 72676 - 648A Avenue John Chaney Brownville, NE 68321 1101 17th Street Auburn, NE 68305 Jim Loynes License Renewal Project Engineer Darrell Kruse Cooper Nuclear Station 2415 McConnell Ave.

72676 - 648A Avenue Auburn, NE 68305 Brownville, NE 68321 Daryl J. Obermeyer 64381 727A Road Brownville, NE 68321

Cooper Nuclear Station cc:

Sherry Black, Director Mark Miles Auburn Memorial Library State Historic Preservation Officer 1810 Courthouse Ave. Department of Natural Resources Auburn, NE 68305 P.O. Box 176 Jefferson City, MO 65102 Board of Brownville, NE Attn: Chairman Marty Hayes Michael J. Smith P.O. Box 67 State Historic Preservation Officer 223 Main Street Nebraska State Historical Society Brownville, NE 68321 P.O. Box 82554 Lincoln, NE 68501 Bob Engles Mayor of Auburn, NE Robert Puschendorf 1101 J Street Nebraska State Historical Society Auburn, NE 68305 1500 R Street, P.O. Box 82554, Jo Stevens Lincoln, NE 68501-2554 Mayor of Rock Port, MO 500 S. Main Street Rock Port, MO 64482 John Cochnar U.S. Fish and Wildlife Service Ecological Services Nebraska Field Office 203 West Second Street Grand Island, NE 68801 John Askew Regional Administrator U.S. EPA Region 7 901 N. 5th Street Kansas City, KS 66101 Joann Scheafer, Director Nebraska Department of Health & Human Services 301 Centennial Mall South Lincoln, NE 68509 Doyle Childers, Director Missouri Department of Natural Resources P.O. Box 176 Jefferson City, MO 65102