ML072010117

Susquehanna - Petition for Leave to Intervene, Request for Hearing, and Presentation of Contentions with Supporting Factual Data, Submitted by Eric Joseph Epstein

ML072010117
Person / Time
Site:	Susquehanna
Issue date:	05/11/2007
From:	Epstein E - No Known Affiliation
To:	Office of Nuclear Reactor Regulation
SECY RAS
References
50-387/388, ASLBP 07-854-01-OLA-BD01, RAS 13686
Download: ML072010117 (67)

Text

DOCKETED USNRC May 11, 2007 (7:24am)

OFFICE OF SECRETARY Office of the Secretary RULEMAKINGS AND ADJUDICATIONS STAFF U.S. Nuclear Regulatory Commission Washington, D.C. 20555-0001 Attn: Rulemaking and Adjudications Staff In the matter of PPL Susquehanna LLC Proposed Amendment Requests for the Susquehanna Steam Electric Station's 1& 2 Would Increase Thermal Power to 3,952 Mega-Watts Which Is 20% Above the Original Rated Thermal Power (RTP) 3293 MWt, And Approximately 13%Above the Current RTP of 3,489 MWt, Docket Nos. 50-387 PLA-6110 and 50-388 Eric Joseph Epstein's Petition for Leave to Intervene, Request for Hearing, and Presentation of Contentions with Supporting Factual Data Date: May 11, 2007

I. Introduction.

Eric Joseph Epstein ("Mr. Epstein" or "Epstein"), pursuant to 10 C.F.R. 5 2.309 (d) and (e), petitions for Leave to Intervene, Request for Hearing, and Presentation of Contentions with Supporting Factual Data in response to the Notice of Opportunity for a Hearing relating to PPL Susquehanna LLC's Proposed Amendment Requests for the Susquehanna Steam Electric Station's 1 & 2

("SSES" or "Susquehanna" or "the Company" or "the applicant")

Would Increase Thermal Power to 3,953 Mega-Watts Which Is 20% Above the Original Rated Thermal Power (RTP) 3293 MWt, And Approximately 13% Above the Current RTP of 3,489 MWt, Docket Nos. 50-387 PLA-6110 and 50-388 as published in the Federal Register on March 13, 2007 (Vol. 72, No. 48), pp.

11392-1139.

Mr. Epstein also requests a hearing consistent with 10 C.F.R. 5 2.309(a).

Pursuant to 10 C.F.R. 3 2.309(0), Epstein should be granted leave to intervene because he has standing; and, hereby submits three admissible contentions.

11. History of Proceeding In September, 2005, PPL consummated a contract with General Electric to engage in uprate activities at the SSES:

"A General Electric Co. subsidiary said Sept. 22 that it won a $10 million contract to increase the electric generating capacity of PPL Corp.'s two-unit Susquehanna nuclear plant by about 200 MW combined. This is part of an extended power uprate for the boiling water reactor units at the nuclear plant, near Berwick.

"Pa. PPL Corp. currently lists a generating capacity of 2,360 MW for the facility plant. PPL Corp.'s PPL Susquehanna unit is 90% owner of the nuclear plant. Allegheny Electric Coop. Inc. is a 10% owner. Unit 1 began commercial operation in 1983 and unit 2 in 1985. PPL Corp. will likely file for a 20-year operating license renewal for both units next year.

GE Energy, the plant's original equipment manufacturer, will work with PPL Corp. to prepare for the uprate, which will be implemented in phases during several refueling outages. (1)

PPL's amendment request was initially submitted to the Nuclear Regulatory Commission ("NRC" or "Commission") on October 11, 2006, and supplemented on October 25, November 21, and December 4, 2006.

A notice of opportunity for a hearing, as well as the NRC's staffs review and determination that "processes to determine that the amendment request involves no significant hazards consideration," was published in the Federal Register on March 13, 2007 (Vol. 72, NO. 48), pp. 11392-11395.

111. Timeliness (b) Timing. Unless otherwise provided by the Commission, the request and/or petition and the list of contentions must be filed as follows:

(3) In proceedings for which a Federal Register notice of agency action is published (other than a proceeding covered by paragraphs (b)(i) or (b)(2) of this section). ..

Eric Joseph Epstein's Petition for Leave to Intervene, Request for Hearing and Presentation of Contentions and Supporting Factual Data was submitted to all identified entities in a timely manner as identified by Federal Register postings of March 13, 2007.

1 "Generation Markets Week", GE receives contract to increase output of PPL nuclear unit, September 27, 2005.

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N.Standing (3) The Commission, the presiding officer, or the Atomic Safety and Licensing Board designated to rule on requests for hearing and/or petitions for leave to intervene will determine whether the petitioner has an interest affected by the proceeding considering the factors enumerated in 8 2.309(d)(l)-(2), among other things.

A. Eric Joseph Epstein Has Standing Mr. Epstein meets the criteria of standing on his own behalf . The standing requirements for Nuclear Regulatory Commission (NRC) adjudicatory proceedings derive from the Atomic Energy Act (AEA), which requires the NRC to provide a hearing "upon the request of any person whose interest may be affected by the proceeding." (42 U.S.C. 2239(a)(l)(A). In addition, 82.309 establishes that requests for petitions to intervene must meet the basic standing and "one good contention" requirements of the old 92.714.

This is a substantial departure from the old Subpart L, which required only the articulation of "areas of concern about the licensing activity that is the subject matter of the proceeding."

The Commission believes that this modification better ensures that hearings will cover relevant concerns through the early framing of contested matters and the focusing of litigation on real, concrete issues. In addition, interested parties will now be required to file their contentions as part of the petition to intervene. Consequently, more "upfront" work will be required to prepare the petition to intervene, so the new rules provide additional time (60 days) to prepare the petition.

As the Commission has applied this standard, an individual demonstrates an interest in a reactor licensing proceeding sufficient to establish standing by showing that his or her residence is within the geographical area that might be affected by an accidental release of fission products. This "proximity approach" presumes that the elements of standing are satisfied if an individual lives within the zone of possible harm from the source of radioactivity. See Virginia Elec. And Power Co., 9 NRC 54, 56 (1979) ("close proximity [to a facility] has always been deemed to be enough, standing alone, to establish the requisite interest" to confer standing).

The Commission's "rule of thumb" in reactor licensing proceedings is that "persons who reside or frequent the area within a 50-mile radius of the facility" are presumed to have standing. Sequoyah Fuels Corp., 40 NRC 64. 75 n.22 (1994); See also, Duke Energy Corp., 48 NRC 381, 385 n.l (1998).

Mr. Epstein lives 56 miles from the nuclear power plant, but regularly pierces the 50 mile veil established by NRC case law due to work and familial obligations.

In Georgia Power Co. (Vogtle Electric Generating Plant, Units 1 and 2),

LBP-93-5, 37 NRC 96 (1993), aff'd, CLI-93-16, 3 8 NRC 25 (1993), the Nuclear Regulatory Commission (NRC) approved standing for a petitioner living 35 miles from the plant one week per month.

In the CFC Logistics proceeding, the Atomic Safety and Licensing Board (ASL&B) "hasten[ed] to add ... that the 'obvious potential' aspect of 'proximity-plus' standing is not a concept that can be applied with engineering or scientific precision ..." 60 NRC 475, 485 (2004)~p. 487.

"[A] minor exposure to radiation, even one within regulatory limits, is sufficient to state an injury in fact for standing purposes. Duke Cogema Stone

& Webster (Savannah River Mixed Oxide Fuel Fabrication Facility), LBP-01-35, 54 NRC 403, 417 (2001), rev'd on other grounds, CLI-02-24, 56 N.R.C. 335 (2002) (citing Yankee Atomic Electric Co. (Yankee Nuclear Power Station), CLI-96-7, 43 NRC 235, 247-48 (1996)); see also id. at 420 (standing inquiry does not require precision regarding probability of petitioner receiving unwanted dose of radiation). The asserted harm - injury to the health and safety - is clearly encompassed by the health and safety interests protected by the Atomic Energy Act. Id. at 417; see also 42 U.S.C. 9 2013.

In Pebble Springs, (4 NRC at 614-617. See Infra, 5 11. A.5.) the Commission also held that even if a Petitioner for intervention could not satisfy the strict judicial standing test, intervention could still be allowed as a mater of discretion.

Mr. Epstein routinely pierces the 50 mile proximate rule during his day-to day-actives simply by traveling to Lebanon, Schuylkill and upper Dauphin Counties. As noted during the teleconference, Mr. Epstein is a member of the Board of Directors of the Sustainable Energy Fund of Central Eastern Pennsylvania since its inception in 1999. He is also a director of GreenConnexions, Inc. since 2006 which is based in the same office. Both entities have a 29 county constituency that mimics PPL's residential customer base.

His commute to the office in Allentown, and meetings at off site locations, pierces the fifty mile proximity zone for substantial periods of time on a regular basis. Mr. Epstein's meeting schedule through the Fund's fiscal year (June 30, 2007)~ includes business meetings in Allentown, Conygnham, Fogelsville, Hazleton and Scranton on the following days and evenings:

May 15, 16, 17 and 30. (2)

June 5, 6, 12, 19, 21, 26 and 28.

2 On May 15, 2007 Mr. Epstein will appear with Conocno-Philips in Scranton along with the Pennsylvania Chamber of Business and Industry and the Pennsylvania Environmental Coalition as part of a national dialogue - "A Conversation on Energy." The following day he will travel to Allentown for a SEF meeting.

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Please note additional meetings may be scheduled as necessary in Kingston (28 miles from Berwick) SEF's counsel, Hourigan, Kluger & Quinn, PC is located in Kingston, and as Chair of the Human Relations Committee, Mr.

Epstein must spend time in close proximity to Berwick for legal related matters.

In the Matter of PPL Susquehanna, LLC , Relicensing Application for the Susquehanna Steam Electric Station, Units 1 and 2, Docket Nos. 50-387-LR &

50-388-LR, ASLBP No. 07-851-01-LR, the Atomic Safety & Licensing Board panel held:

"We do, however find that the petitioner Epstein has made a sufficient showing to establish standing for himself under the "proximity presumption."

Mr. Epstein admits that he resides more than fifty miles from the plant.

However, significant contacts with an affected area can be sufficient to establish standing, the regularity of Mr. Epstein's trips to the area around the plant, for a number of years, weighs in his favor. In addition, he resides six miles outside the area in question and can therefore be expected to continue to conduct business there in the future. Because of this pattern of regular contacts within the 50-mile radius around the plant, we find that Mr. ~ p s t e i nhas standing on his own behalf." (3)

Based on case law, precedent and recent ruling relevant to Mr. Epstein and the Susquehanna Steam Electric Station, Mr. Epstein has established standing, and will be potentially adversely affected if the proposed amendment causes the release of radiological emissions or atmospheric releases into the environment, or the proposed uprate increases the likelihood of toxic, caustic or carcinogenic discharges into the environment. (4) 3 Memorandum and Order, (Ruling on Standing and Contentions of Eric Joseph Epstein, USNRC, Docket No's. 50-387-LR, 50-388-LR, ASLBP No. 07-851--

oi-LR, BDoi, pp. 9-10, March 22, 2007.

4 Amendment to Pennsylvania Constitution, Section 27, Article I, 1969:

"The people have the right to clean air, pure water, and to the preservation of natural, scenic, historic and esthetic values of the environment. Pennsylvania's public natural resources are the common property of all people, including generations yet to come. As a trustee of the resources the Commonwealth shall maintain and conserve them for the benefits of all people."

V. Eric Joseph Epstein Submits Three Admissible Contentions A. Legal Standards Proposed contentions must satisfy six requirements of 10 C.F.R. 3 2.309(f)(1). This rule is intended to ensure that "full adjudicatory hearings are triggered only by those able to proffer at least some minimal fachral and legal foundation in support of their contentions." Duke Energy Corp. (Oconee Nuclear Station, Units I , 2, and 3), 49 N.R.C. 328, 334 (1999)(emphasis added). Sections (1) through (6) below summarize the requirements of Section 2.306(f)(1).

Contentions. (1) A request for hearing or petition for leave to intervene must set forth with particularity the contentions sought to be raised ...

(2) Contentions must be based on documents or other information available at the time the petition is to be filed, such as the application, supporting safety analysis report, environmental report or other supporting document filed by an applicant or licensee, or otherwise available to a petitioner. On issues arising under the National Environmental Policy Act, the petitioner shall file contentions based on the applicant's environmental report. ..

(i) Provide a specific statement of the issue of law or fact to be raised or controverted; (ii) Provide a brief explanation of the basis for the contention; (iii) Demonstrate that the issue raised in the contention is within the scope of the proceeding; (iv) Demonstrate that the issue raised in the contention is material to the findings the NRC must make to support the action that is involved in the proceeding;

(v) Provide a concise statement of the alleged facts or expert opinions which support the requestor's/petitioner's position on the issue and on which the petitioner intends to rely at hearing, together with references to the specific sources and documents on which the requestor/petitioner intends to rely to support its position on the issue; and (vi) Provide sufficient information to show that a genuine dispute exists with the applicant/licensee on a material issue of law or fact. This information must include references to specific portions of the application (including the applicant's environmental report and safety report) that the petitioner disputes and the supporting reasons for each dispute, or, if the petitioner believes that the application fails to contain information on a relevant matter as required by law, the identification of each failure and the supporting reasons for the petitioner's belief.

B. Contentions Contention I:

(i) Provide a specific statement of the issue of law or fact to be raised or controverted.

PPL failed to consider the impact of the proposed uprate on certain state and federal water use issues, and the potential impact these regulations will have on water flow, water volume and surface water withdrawal for the SSES's cooling systems. The traditional implications of the Pennsylvania Public Utility Commission ("Pa PUC") policy and regulations relating to "withdraw and treatment" of water, i.e., referred to as "cost of water" under the Public Utility Code, Title 66, have to be factored in this application absent a PUC proceeding as well as Act 220 water usage guidelines. PPL has not established (nor has the NRC reviewed) compliance milestones for EPA's Act 316 (a) or 316 (b) and their impact on power uprates at the Susquehanna Electric Steam Station. (5)

(ii) Provide a brief explanation of the basis for the contention.

State and federal regulations which many impact, constrict or restrict water flow that would adversely impact cooling systems at the plant, and lead to health and safety challenges for local communities.

A basis for a contention can be a reference to a source and an assertion; there is no need to detail evidence in support of it. (6) 5 "NRC boards may without further inquiry accept and utilize in their cost-benefit analysis EPA's determinations under Sections 316 or 402 of FWPCA of the impacts on the aquatic ecosystem of the condenser cooling discharge of a nuclear plant whether or not all parties to NRC proceedings were before the EPA." (Public Service Company of New Hampshire , Seabrook Station, Units 1 and 2), CLI I, 7 NRC I, 23-29 (1978), and later affirmed in New England Coalition on Nuclear Pollution v. NRC, 582 F. ad 87 (1st Cir. 1978).

6 Houston Lighting & Power Company (Allens Creek Nuclear Generating Station Unit 1) ALAB-590, 11 NRC 542, 547-548 (1980); Mississippi Power &

Light Company (Grand Gulf Nuclear Station Units 1 and 2), ALAB-130, 6 AEC 423, 426 (1973).

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(iii) Demonstrate that the issue raised in the contention is within the scope of the proceeding.

Acts of omission by the licensee in the filing of the uprate amendment have produced a fatal flaw that can only be cured through a reevaluation of portions of the proposal. The Company applied a generic scoping brush to water use and aquatic challenges at the SSES that failed to include site specific, regional and indigenous health and safety challenges. Mr. Epstein has requested the submission and evaluation of absent information and data in order to remedy this grave oversight.

PPL also failed to consider several state and federal water use issues, and the potential impact these regulations will have on water flow, water volume and surface water withdrawal for the SSES's cooling systems.

An NRC license must meet Commission regulations, technical specifications, and various requirements in a regulatory scheme where "public safety is the first, last and permanent consideration." Where a contention alleges a deficiency or error in the application, the deficiency or error must have some independent health and safety significance." (7)

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7 In the Matter of Dominion Nuclear Connecticut, Inc.(Millstone Nuclear Power Station, Units 2 and 3) Docket Nos. 50-336-LR, 50-423-LR ASLBP No. 04-824-01-LR July 28, 2004, p. 7. See Private Fuel Storage, L.L.C. (Independent Spent Fuel Storage Installation), LBP- 98-7, 47 NRC 142, 179-80 (1998)~affd in part, CLI-98-13, 48 NRC 26 (1998).

(iv) Demonstrate that the issue raised in the contention is material to the findings the NRC must make to support the action that is involved in the proceeding; Had PPL Susquehanna scratched the regulatory surface in their license application, they would have disclosed the need to coordinate, and perhaps submit an "alternative plan" as a result of Act 220. (8) It is not logical, reasonable or plausible to believe PPL Susquehanna was unaware of water use regulations. (9) The Company simply failed to include this data in their application. (lo)

In March 2008 areas will be identified where water use exceeds (or is projected to exceed) available supplies. If the SSES is designated as an endangered or sensitive area, PPL will have to comply with a "water budget" established by the Regional Water Resource Committee and the Critical Advisory Committee.

8 Act 220 of 2002 mandates that the Department of Environmental Protection update the state water plan by 2008. "The Environmental Quality board will adopt regulations addressing water use registration, period reporting and record keeping (Section 3118), and the DEP is authorized "to enforce the Act.

It also "establishes the duty of any person to proceed diligently in compiling with orders of the DEP." (Section 3133) 9 Susquehanna River Basin Commission:

9801.6 Water supply (b) The Commission may regulate the withdrawal of waters of the basin not regulated by the signatory parties for domestic, municipal, industrial, and agricultural uses if regulation is considered essential to further the aims set forth in the comprehensive plan.

(c) The Commission shall study the basin's water supply needs, the potential surface and ground water resources, and the interrelationships to meet these needs through existing and new facilities and projects. Efficient use and management of existing facilities with emphasis on the full utilization of known technology will be explored in meeting water supply needs for domestic, municipal, agricultural, and industrial water supply before new programs or projects are approved.

1o As a point of reference, please note that he SSES is located in the "West Branch, Upper, Middle Susquehanna and Chemung River Basins" Region.

PPL's Susquehanna Electric Steam Station plans to increase the volume of surface water it removes from the Susquehanna River regardless of seasonal fluctuations, impending water restrictions and during periods of drought.

People and animals who depend on these aquatic resources will also be affected, and it is likely more fish and aquatic life will be harmed as a result of the uprate's impact on the River environment. PPL's planned uprate and application for relicensing will further place pressure on limited water resources.

Surface water consumption (ii), fish kills, thermal inversion and effluent discharges, are not adequately covered or evaluated in the proposed amendment for an uprate at the SSES. During the 2002 drought, water shortages on the Susquehanna reached critical levels, yet these power plants were exempted from water conservation efforts prior to the implementation of Act 220.

A sample of the magnitude of the amount of water used at nuclear power plants is readily evidenced at PPL's Susquehanna Steam Electric Station (SSES) located on the Susquehanna River in Luzerne County. The plant draws 40.86 million gallons per day from the Susquehanna River. For each unit, 14.93 million gallons per day are lost as vapor out of the cooling tower stack while 11 million gallons per day are returned to the River as cooling tower basin blow down. On average, 29.86 million gallons per day are taken from the Susquehanna River and not returned. This data is public information, and can be easily referenced by reviewing PPL's Pennsylvania Environmental Permit Report.

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11 Freshwater water withdrawals by Americans increased by 8% from 1995-2000, and Americans per capita water withdrawal is three times above the international average, "U.S. National Report on Population and the Environment" (2006) published by the Center for Environment and Population, a nonprofit corporation based in Connecticut.

Compliance milestones for the Environmental Protection Agency (EPA)

Act 316 (a) or 316 (b) have been in play since July 9, 2004 when the Agency issued the Final Phase I1 rule implementing Section 316(b) of the Clean Water Act. The was first national standards for reducing fish kills at existing plants.

which predated PPL's current water use permit at the SSES. Now large water consumers, including PPL, are compelled to invetorize mortality rates and identify species of aquatic life affected by water intakes. The regulations were due to take effect on September 7, 2005.

(v) Provide a concise statement of the alleged facts or expert opinions which support the requestor's/petitionerS position on the issue and on which the petitioner intends to rely at hearing, together with references to the speczjk sources and documents on which the requestor/petitioner intends to rely to support its position on the issue; and (vi) Provide sufJicient information to show that a genuine dispute exists with the applicant/licensee on a material issue of law or fact. This information must include references to speczjic portions of the application (including the applicant's environmental report and safety report) that the petitioner disputes and the supporting reasons for each dispute, or, if the petitioner believes that the application fails to contain information on a relevant matter as required by law, the identification of each failure and the supporting reasons for the petitioner S belief.

PPL failed to factor, consider and address numerous water use and indigenous aquatic challenges present and anticipated for the Susquehanna River environs in the Berwick-area. The sufficiency of the uprate evaluation for considering water use is grossly inadequate and fails to anticipate or plan for emerging health and safety challenges as a result of water use regulations and aquatic challenges. The uprate expansion proposed in the Susquehanna Electric Steam Station amendment is inadequate because:

(I) It does not include proactive action plans for water challenges resulting from natural and mechanical adversaries.

(2) It does not recognize that it is initial manifest with the Susquehanna River Basin Commission application has been "grandfathered" and must be resubmitted.

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(3) It does not factor Act 220 into water use considerations , although the rule had been vetted and reviewed prior to the submittal of the uprate amendment.

During the SSES relicensing proceedings, the staff complained that "PPL is under no obligation to anticipate a future law" and further presumes that the grandfathered SRBC Commission is current, assumed that PPL is in compliance, dismissed Asiatic clam and Zebra mussel "concerns", and essentially ignores historic implications of PUC's policy and regulations relating to "withdraw and treatment" of water, i.e., referred to as "cost of water" under the Public Utility Code, Title 66 as well as DEP's Act 220. (NRC Reply, pp. 18-20)

(4) PPL has not established, nor has the NRC reviewed compliance milestones for EPA's Act 316 (a) or 316 (b). For example, PPL Susquehanna failed to investigate or report on the impact of the uprate fragile series of shad ladders.

(5) Nuclear plants occasionally discharge chlorinated water (necessary to minimize bacterial contamination of turbines) or Clamtrol (chemical agent used to defeat Asiatic clam infestation) directly into the River. Asiatic calm infestation has challenged Peach Bottom and Three Mile Island's cooling systems, and it is logical for PPL Susquehanna to submit an action plan to defat both environmental challenges should they migrate upstream. For example, in February 1986, one celled organisms believed to be fungus, bacteria and algae like creatures were discovered at Three Mile Island. These creatures obscured the view of the reactor core, and impeded the cleanup.

DEP recently confirmed that zebra mussel adults and juveniles have been found in Goodyear Lake, the first major impoundment on the Susquehanna River's main stem below Canadarago Lake in New York. Zebra mussels are an invasive species posing a serious ecological and economic threat to the water resources and water users downstream in the river and Chesapeake Bay.

"In 2002, the first report of zebra mussel populations in the Chesapeake Bay Watershed were reported from Eaton Reservoir in the headwaters of the Chenango River, a major tributary to the Susquehanna River in New York. A short time later, zebra mussels also were found in Canadarago Lake, a lake further east in the Susquehanna main stem headwaters.

Now, through DEP's Zebra Mussel Monitoring Network, reports were received that both zebra mussel adults and juveniles, called veligers, have made their way down to the Susquehanna main stem, (Pa DEP, Update, July 16, 2004.)

(5) Water shortages on the Lower Susquehanna reached critical levels in the summer of 2002. During the 2002 drought, the SSES was exempted from water conservation efforts. For the month of August 2002, 66 of 67 Pennsylvania counties had below normal precipitation levels. The SSES did not take any measures or precautions to "conserve" water. Moreover, recent and consistent droughts in Pennsylvania (2002) as well as flooding (2006) have forced state and regulatory bodies to reexamine water as a commodity in the Commonwealth of Pennsylvania.

(6) Last year, despite the fact Columbia County was -3.6 inches below normal precipitation levels and Luzerne County was -3.2 inches under ( a 51-75%

decrease below the norm), the SSES continued to gobble up water as their neighbors conserved. (DEP Drought Watch, April 11, 2006) This behavior will change after 2008 and potentially impact the plant's water use and cooling plans.

Water use must be factored into the application for renewal. This is not an academic issue as evidenced by a recent Pennsylvania court decision guaranteeing the rights of citizens to have access to the Little Juniata River in Huntingdon County for fishing, boating, and other recreation. Furthermore, the Pennsy Supply suit v. the SRBC (December 22, 2006), will have long term implications on the SSES ability to mine water from the Susquehanna River.

Those regulations increased the Commission power to regulate water usage by business and public facilities.

PPL Susquehanna's corporate family has a recent history of fouling water resources. On January 12, 2007 PPL Holtwood was ordered to stop the discharge of coal bottom ash into the the Susquehanna River and was assessed a n $85,000 civil Penalty by the Department of Environmental Protection (DEP). Four days later, PPL announced it has reached a $1.5 million preliminary settlement to end a lawsuit over the 2005 fly ash spill at the Martins Creek power plant into the Delaware River.

In December, 2005 the the DEP issued a notice of violation to PPL for a fish kill that occurred due to a sharp increase in the temperature of the water discharged into the Susquehanna River from Brunner Island. Hundreds of fish from minnows to bass to shad were killed. According to DEP South central Regional Director Rachel Diamond, PPL took a circulation pump off line and that resulted in a rapid and dramatic rise of about 20 degrees in the temperature of the water flowing to the river from the company's discharge channel, PPL exceeded the thermal limits in their discharge permit and violated sections of Pennsylvania's Clean Streams Law.

(uii) Remedies

1) The Company must resubmit and revise its amendment application to analyze the impact of state and federal regulations on the proposed uprate and potential for a "new or different kind of accident from any accident previously evaluated, and the "unanticipated adverse health and steady consequences" this accident may cause on the local environs.

2) PPL must resubmit the amended requests after the SRBC has evaluated PPL's pending water use application to ensure new and unanticipated adverse health and steady consequences have been evaluated.

3) None of these requests present a hardship to PPL Susquehanna. The SRBC is just beginning its due diligence on PPL's combined uprate and relicensing application.

(viii) Conclusion PPL failed to consider the coordination of water use issues with state and federal agencies, and the potential impact these regulations will have on water flow, water volume and surface water withdrawal for the SSES's cooling systems.

PPL's inability, unwillingness and resolute refusal to coordinate with new and emerging regulations from the EPA and the SRBC and Act 220 are self-inflicted hardships. The NRC can not excuse PPL's omissions and failure to submit an action plan on these state regulations. These regulations have been enacted, and were in the implementation stages for several years prior to PPL's filing. PPL, through its own haste to uprate the Susquehanna Electric Steam Station, left these obligations off of their amendment matrix.

Contention 2:

(i) Provide a speciJic statement of the issue of law or fact to be raised or controverted.

PPL failed to disclose damaging information included in a hastily filed Application for Surface Water Withdrawal (11)."[W]hen a party has relevant evidence within his control which he fails to produce, that failure gives rise to an inference that the evidence is unfavorable to him." (12)

(ii) Provide a brief explanation of the basis for the contention.

PPL Susquehanna actually references the NRC filings in the Susquehanna River Basin Commission ("SRBC") application, yet their amendments (and the NRC's subsequent review) fails to include action plans to repair faulty and corroded piping identified by the applicant in another venue. (13) 11 Request to Modify Application 19950301 EPUL-0578 PPL's Letter to the Susquehanna River Basin Commission was filed on December 20, 2006, p. 2)

Please refer to Exhibit 1.

12 Public Service Company of New Hampshire, Seabrook Station Units 1 and 2), ALAB-471, 7 NRC 477, reviewed as to other matters, CLI 14, 7 NRC 952 (1978) 1 3 "In order to fulfill its regulatory obligation, the NRC is dependent on all of its licensees for accurate and timely information ...[Lllicensees are the first line to ensure the safety of the public." (Petition for Emergency and Remedial Action, CLI-78-6, 7 NRC 400, 418 (1978). See also Consumer Power Co. (Midland Plant, Units 1 and 2), CLI-74-3, 7 NRC 7, 11 (1974)

iii) Demonstrate that the issue raised in the contention is within the scope of the proceeding.

PPL failed to address, correct and analyze the problems associated with a faulty river intake valve "significantly reduces the margin of safety" at the SSES, and undermines the Company's generic evaluation of water related components and systems and the potential impact an uprate would have on those systems.

(iv) Demonstrate that the issue raised in the contention is material to the findings the NRC must make to support the action that is involved in the proceeding; (v) Provide a concise statement of the alleged facts or expert opinions which support the requestor's/petitioner's position on the issue and on which the petitioner intends to rely at hearing, together with references to the specific sources and documents on which the requestor/petitioner intends to rely to support its position on the issue; and (vi) Provide su.cient information to show that a genuine dispute exists with the applicant/licensee on a material issue of law or fact. This information must include references to specific portions of the application (including the applicant's environmental report and safety report) that the petitioner disputes and the supporting reasons for each dispute, or, if the petitioner believes that the application fails to contain information on a relevant matter as required by law, the identification of each failure and the supporting reasons for the petitioner's belief.

The most disturbing admission contained in PPL's report to the Susquehanna River Basin Commission relates to corroding and poorly performing piping which PPL did not "discover" until after the submission of the uprates amendment on October 11, October 25, November 21, and December 4, 2006. PPL has known about this problem, yet failed to share the data with the NRC or disclose the damaging information during the uprate amendment process.

The River Intake Structure flow meters to measure withdrawal.

However, metering of the withdrawal has been inaccurate due mainly to corrosion and fouling of the intake pipes. The intake pipes are made of carbon steel, and PPL is evaluating replacement of sections of this pipe with stainless steel pipe to minimize flow measurement meter error...

If the pipe replacement project proceeds and withdrawal quantities determined by the two methods are comparable, then PPL will use the metered withdrawal to periodically verify the calculated withdrawal based on the sum of cooling tower water loss, cooling tower blow down, and emergency spray makeup. If the metered withdrawal is significantly different from the calculated withdrawal, PPL will discuss with the Commission the appropriate next steps for measuring withdrawal. PPL will keep the Commission apprised of these activities. (14)

PPL failed to address, correct and analyze the problems associated with a faulty river intake valve "significantly reduces the margin of safety" at the SSES, and undermines the Company's generic evaluation of water related components and systems and the potential impact an uprate would have those systems.

The NRC should not excuse PPL's omissions or failure to submit an action plan to address these health and safety challenges.

(vii) Remedies PPL has publicly announced a significant technical problem with health and safety implications that needs to be investigated prior to issuing an uprate amendment. A power uprate submittal need not cover inspections of components or systems containing radioactively contaminated water, unless the power uprate changes the volume, pressure, or temperature of said water.

(15) This amendment, at a minimum, will affect both water volume and temperature.

Since the River Intake Structure flow monitors the volume of water, the Company's current application is deficient and does not provide for adequate inspection of systems and components that may contain radioactively contaminated water, and there is not adequate monitoring in place to determine if and when leakage from these areas occurs. Some of these systems include underground pipes and tanks which the current aging management and inspection programs do not effectively inspect and monitor.

---

14 By October 11, October 25, November 21, and December 4, 2006, PPL recognized that Act 220 could not be ignored during a uprate amendment, yet this data was not filed with the SRBC until December 2 0 , 2006.

15 PPL acknowledged during their 2001 uprate application the water temperatures would be increased:

The licensee indicated that an increase in the cooling tower air flow rate will compensate for the slight increase in condenser outlet circulating water temperature, such that no perceptible change in the temperature of the cooling tower basin blowdown to the Susquehanna River is expected. Therefore, the temperature effects on the river will be insignificant. Existing administrative controls ensure the conduct of adequate monitoring such that appropriate actions can be taken to preclude exceeding the limits imposed by the National Pollution Discharge Elimination System permit. No additional requirements or other changes are required as a result of the power uprate. No other non-radiological impacts are associated with the proposed action. [Federal Register:

June 25, 2001 (Volume 66, Number 122)] [Page 33716-337171 PPL can no longer assure the NRC that reliable administrative controls are in place to "ensure the conduct of adequate monitoring."

22

PPL has admitted that the River Intake Structure flow meters to measure withdrawal are "inaccurate due mainly to corrosion and fouling of the intake pipes." Therefore there is no procedure, mechanism or equipment currently in place that can accurately determine water use. If the quantity of water is an unknown variable, then the amount of water passing through the plant's cooling system can not be accurately gauged for consumptive and cooling and discharge purposes.

The power uprate will significantly increase the amount of waste heat discharged from the main condenser and dissipated to the environment via the SSES cooling towers. Consequently, more water will be evaporated through the towers by the higher heat rejection amount and more makeup water will be needed from the river to maintain the desired water levels in the cooling tower basins. Therefore, the power uprate will exacerbate SSES's current intake structure flow meter inaccuracy problems.

The water variable undermines the ability of PPL to affix .the appropriate chemical dosage needed to defeat unanticipated thermal aquatic invasions that were not planned for or anticipated in the original license or the Present amendment. Additionally, the variable presents increased safety challenges by undermining and disrupting the SSES's borated water formula. The NRC has asked PPL to revise their assumptions during the 2001 request in part due similar concerns raised by Mr. Epstein in the Present application:

50.62. PPL performed a safety assessment of the SLC systems ability to inject the borated solution consistent with the assumptions of the ATWS analyses. In response to the inspection findings, PPL modified the design of the SLC system for Unit 2 by replacing the flanges of the two SLC pumps with higher rated flanges and by increasing the SLC pump discharge relief valve setpoints to 1500 psig. In addition, the licensee committed to perform similar SLC system design changes for Unit 1 during the spring 2002 refueling outage. (16) 16 Correspondence to Mr. Robert G. Byram , Senior Vice President and Chief Nuclear Officer, PPL Susquehanna, LLC from Robert G. Schaaf, Project Manager, Section 1, Project Directorate I, Division of Licensing Project Management Office of Nuclear Reactor Regulation (July 6, 2001).

Power uprate also entails additional steam flow dumped into high pressure environments, e.g., turbine, has caused turbine stress cracks at Dresden.

Turbine blade cracking led to serious and costly events at Fermi Unit 2 and Salem.] (Please refer to Exhibits 2, 3 and 4). These precursor events need to be applied as a "steam flow" yardstick during the present amendment proposal.

The Company's current application is deficient and does not provide for adequate inspection of all systems and components that may contain radioactively contaminated water, and there is not adequate monitoring in place to determine if and when leakage from these areas occurs. Some of these systems include underground pipes and tanks which the current aging management and inspection programs do not effectively inspect and monitor.

The power uprate evaluation failed to adequately screen structures and components that may be affected by the uprate, and assumes existing programs are appropriate and calibrated. The Company has undermined its credibility and veracity to make assumptions based on their admission of a chronically ailing River Intake Structure.

PPL did not take a proactive "hand's-on" approach to evaluating subsets and subset samples; and, therefore, reduced the actual amount of aging equipment that was physically tested. PPL has undermined their ability to accurately predict the impact an uprate will have on aging equipment operating in harsh and corrosive environments.

The impact of aging equipment is fluid, and should require in-depth pre-and post-examination of equipment, e.g., safety systems not used day-to-day and on stand-by, e.g., coolers and emergency diesel generators, to avoid encountering a safety grade challenge like the Quad Cities stream dryer issue (17).

1 7 Quad Cites, like the Susquehanna Electric Steam Station, a General electric boiling water reactor. During an extended power uprate test at Quad Cities Nuclear Generating Station in March 2005, the plant began to "vibrate."

On March 29 the plant was manually shut down due to high vibrations causing leaks in the main turbine control system, and it was subsequently discovered the vibrations broke a main steam pipe drain line.

24

I) The Company must resubmit and revise its application to address issues related to corroding and poorly performing piping. PPL must analyze potential for a "new or different kind of accident from any accident previously evaluated, "and the unanticipated adverse health and safety consequences this accident may cause on the local environs.

2) PPL must resubmit the amended requests after the SRBC has evaluated PPL's pending water use application to ensure new and unanticipated adverse health and safety consequences have been evaluated.

3) None of these requests present a hardship to PPL Susquehanna. The SRBC is just beginning its due diligence on PPL's combined uprate and relicensing application.

(viii) Conclusion The Company's current amendment application is deficient and does not provide for adequate inspection of all systems and components that may contain radioactively contaminated water, and there is not adequate monitoring in place to determine if and when leakage from these areas occurs. Some of these systems include underground pipes and tanks which the current aging management and inspection programs do not effectively inspect and monitor.

Contention 3:

(i) Provide a specific statement of the issue of law or fact to be raised or controverted.

The proposed change involves a significant increase in the "consequences" of an accident than previously evaluated, and the amount of radioactivity in the reactor core (and thus available for release in event of an accident) is significantly more at 120% power than at 100% power.

(ii) Provide a brief explanation of the basis for the contention.

PPL and the NRC are overly reliant on compliance with NRC's regulations, without examining the "consequences" of an accident caused by the proposed uprate. The amount of radioactivity in the reactor core (and thus available for release in event of an accident) is significantly more at 120% power than at 100% power.

(iii) Demonstrate that the issue raised in the contention is within the scope of the proceeding.

The proposed change involves a significant increase in "consequences" of an accident than previously evaluated, and the amount of radioactivity in the reactor core (and thus available for release in event of an accident) is significantly more at 120% power than at loo% power.

(iv) Demonstrate that the issue raised in the contention is material to the findings the NRC must make to support the action that is involved in the proceeding.

The proposed change involves a significant increase in the "consequences" of an accident than previously evaluated, and the amount of radioactivity in the reactor core (and thus available for release in event of an accident) is significantly more at 120% power than at 100% power.

(v) Provide a concise statement of the alleged facts or expert opinions which support the requestor 's/petitioner 's position on the issue and on which the petitioner intends to rely at hearing, together with references to the specz$ic sources and documents on which the requestor/petitioner intends to rely to support its position on the issue; and (vi) Provide sufficient information to show that a genuine dispute exists with the applicant/licensee on a material issue of law or fact. This information must include references to specific portions of the application (including the applicant's environmental report and safety report) that the petitioner disputes and the supporting reasons for each dispute, or, if the petitioner believes that the application fails to contain information on a relevant matter as required by law, the identification of each failure and the supporting reasons for the petitioner's belief.

PPL and the NRC pursue a "consequences argument" when evaluating the amount of radioactivity in the core present after the uprate. PPL neglected to evaluate the amount of radioactivity in the core, and thus available for release in event of an accident is significantly more at 120% power than at 100% power.

By way of analogy, consider a commercially-licensed bus that is licensed for a maximum capacity of 20 persons, including the driver. If its owner modifies the bus (perhaps taking out an onboard rest room facility and replacing it with seating) to re-license the bus for a maximum capacity of 24 persons, it is a 120% update. The probability of that bus having an accident may be insignificantly affected by the additional passengers (despite any higher weight) if the dominate accident causal factors are driver performance, road conditions, and external factors like other vehicles. But the consequences of an accident are significantly higher if the accident occurs with 24 souls on-board vs. only 20 souls.

In the bus case, one might justify the additional consequences with the argument that the alternative to the bigger bus, is running two trips with the smaller bus. More trips with the same accident rate per trip equates to more accidents. Overall, the risk might be the same, e.g., more accidents with smaller buses equals fewer accidents than with larger buses in terms of fatalities.

But PPL made no such case, nor did the Company conduct new analyses to anticipate changing core conditions. PPL's review was limited to static compliance with existing conditions without identifying or accounting for increased accident "consequences."

(vii) Remedy

1) PPL must resubmit portions of its amendment and evaluate the amount of radioactivity in the reactor core, and thus available for release in the event of an accident is significantly more at 120% power than at loo% power, and the consequences posed by the increase.

2) PPL must evaluate the impact and "consequences" of Highly Enriched Uranium fuel and High Thermal Performance Fuel on the proposed uprate on Reactor Coolant System Pressure and Temperature Safety Limits.

2) PPL must evaluate the impact and "consequences" of Highly Enriched Uranium fuel and High Thermal Performance Fuel on water flow, water volume and ultimate heat sink temperatures.

(viii) Conclusion The proposed change involves a significant increase in the probability or consequences of an accident previously evaluated, and the amount of radioactivity in the reactor core (and thus available for release in event of an accident) is significantly more at 120% power than at 100% power.

VI. Conclusion 5 2.309 Hearing requests, petitions to intervene, requirements for standing, and contentions.

(a) General requirements. Any person whose interest may be affected by a proceeding and who desires to participate as a party must file a written request for hearing or petition for leave to intervene and a specification of the contentions which the person seeks to have litigated in the hearing. Except as provided in paragraph (e) of this section, the Commission, presiding officer or the Atomic Safety and Licensing Board designated to rule on the request for hearing and/or petition for leave to intervene will grant the requestlpetition if it determines that the requestor/petitioner has standing under the provisions of paragraph (d) of this section and has proposed at least one admissible contention that meets the requirements of paragraph (f) of this section ...

(1) Factors weighing in favor of allowing intervention--

(i) The extent to which the requestor's/petitioner's participation may reasonably be expected to assist in developing a sound record; (ii) The nature and extent of the requestor's/petitioner's property, financial or other interests in the proceeding; and (iii) The possible effect of any decision or order that may be issued in the proceeding on the requestor's/petitioner's interest.

Eric Joseph Epstein has met all for the requirements stated in "2.309 Hearing requests, petitions to intervene, requirements for standing, and contentions," and his Petition to Intervene should be granted and all three contentions accepted.

4Ha~ isburg, o ~ i lP ~ s @ ~ l ~ 1 2 (717)-541-110 Phone Dated: May 11, 2007

EXHIBIT I Susillichanna Rivcl- R a s i r ~Commission PROJECT INFORMATION

1. Applicant Information:

Applicant Name or Registered Fictitious Name PPL Susquehanna, LLC Parent Corporation Name, if d~fferent PPL Corporation Mailing Address Two North Ninth Street GENPL5 City Allentown State PA Zip 18101-1179 Contact Person Jerome S. Fields, REM Title Sr. En\lironrnental Scientist - Nuclear Telephone 16 10 ) 774-7889 Fax ( 6 10 )774-7782 E-Mail isfieids@pplweb.com

2. Preparer (Hydrogeologist/Engineer):

Name Jan C. Phillips, P.E.

Title Company Jan C. Phillips, P.E. /.&:

, r c Address 261 1 Walnut Street . Y

,- --

- -

Allentown, PA 18104-0160 4 -'

Phone (610) 821-0160. . -1 Fax (610) 821-0160 d

Signature , k-~r.Q--.

Date #L. I %

J t -i E-Mai124ddress jcphllps@enter.net J

3. Project Engineer:

Name N/A Title Company Address Phone ( 1 Fax (

Signature Date E-Mail Address e

SRBC #72 06/02

4. Location of proposed source@),if applicable:

State Pennsylvania County Luzerne Municipality Salem Township Latitude N41°05'12.4" Longitude W 76" 07' 53.2"

5. State, county, or other regulatorylpermitting contacts:

Agency NIA Department Name Position P e d h of Concern:

Address Phone E-Mail Agency Department Name Position P e n n i t l h of Concern:

Address Phone E-Mail Agency Department Name Position PermittArea of Concern:

Address Phone E-Mail K:\DATAUPAIN\WORD\FORMS\S~72Roject Information .doc

PPL Susquehanna, LLC Two North N~nthStreet Allentown, PA 18101-1179 Tel 610.774 7889 December 20,2006 Mr. Paul 0. Swartz, Executive Director Susquehanna River Basin Commission 172 1 North Front Street Harrisburg, PA 17102-2391 Attn: Project Review Coordinator PPL SUSQCTEHANNA, LLC APPLICATION FOR SURFACE WATER WITHDRAWAL REQUEST TO MODIFY APPLICATION 19950301 EPUL- 0578

Dear Mr. Swartz:

Enclosed for the Susquehanna River Basin Commission's (Conlmission's) approval please find an application to increase the existing maximum daily surface water withdrawal at the Susquehanna Steam Electric Station (SES) from approximately 58 million gallons per day (MGD) to 66 MGD. This application includes a proposed water use monitoring plan. In addition, PPL Susquehanna, LLC hereby requests modification of Application 19950301 dated March 9, 1995 to eliminate the 30-day average consumptive water use limit of 40 MGD at the Susquehanna SES.

Background

The Susquehanna SES is a two-unit, baseload, boiling-water-reactor electric generating station. U n ~ t 1 and Unit 2 each have a present electrical capacity of 1,190 MWe. Ownership of the Susquehanna SES is shared by PPL Susquehanna, LLC, Berwick, PA (90 percent) and Allegheny Electric Cooperative Inc., Harrisburg, PA (1 0 percent). PPL Susquehanna is a subsidiary of PPL Generation, LLC, which in turn is an indirect subsidiary of PPL Corporation. PPL Susquehanna (hereinafter "PPL") is the licensed operator of the Susquehanna SES.

The Susquehanna SES is located on the west bank of the Susquehanna River, in Salem Township, Luzerne County, PA. The largest community within 10 miles is the Borough of Berwick, PA located approximately five miles southwest of the station. Susquehanrla SES property (owncd by PPL and Allegheny Electric) is 1,574 acres in area; 1 , I 73 acres lie to the west of U.S. Route 11 and contain most of the station facilities, and 401 acres lie between 1J.S.Route I 1 and the river and comprise the Susquehanna Riverlands Recreation Area. The Susquehanna Riverlands Recreation Area lncludes

natural and rccreat.icmal arcas. Also, iSP1, o.wns an additi~nal717 acres of lnostiy il.ndovelopsd property nn the cast side of tl~eriver.

in September 2006, BPI, su.bmittcd tan application to the 1.l.S. N~iclearR.egulalory Ctrrrrrr~ission (tl'SNKC:') lo rerlcw the fhsqueha~itlnaSES operaling iicctlses f,:rr an additiotlal 20 years (Unit 1. to 2042 and tltlit 2 to 2044). .It1 Oct.oher2(,H)b, PPL, su.brnitted to the IJSNKC: an iipplicatioxl for an Exlcnded I?ower Upratc (EPLJ) for both .units. The EPI.J will occur between the second qnarter 2008 and the secotld quarter 2010 and will i.ncrcaseelectrica.1generalion up to a.pproxirnately 1,300 MWe for each unit.. M@or EPU tnodificatiorzs associateii with thc station systerns will be initiated during the March 2008 or subsequent rcfkeling outages; the river water :rnakc-up, circutating walcr, and blowdown systerns will not be m d i i k d for the EPLJ.

The Susquehamria SES witilsirawrs water from the Susquehanna River through a river intake (Rivcr Intake Structure) along ttzc west b;mk of the rivcr adjfjaccrlt to the stat.ic~n.

The 'River I.ntakeStructure includes fo~u:apcrating pumps, each with an individual, design capacity of 1.3,500 gallons per ininute (gpn~).The operational combined capacity of the four pumps is approxio~atcly45,000 gpm but can vary depending on river conditions and the conditions of the putnps. E3lowdown from. the station's cooling water systctn is discharged back to the river though a difTuscr pipe lcxated on the river botto~.n downstretarn of th.e river intak.e.

Appfjcation tu 1:nereaseSurface Water Withdrawal from the Susquthanua .River The estimated maximum daily rate of river water withdrawa.1 for the existing srat..ionis approxirnatcly 58 .M.CiD. This wit;hdrawal preceded the e.fYectivc date (Novert~ber1995) of the Can~nrission.'ssu1rfiic.e water withd.rawa1 reguh~t.ionsand, therefore, did not recluirc thc approval of the Cornmission. PPL estiimatcs that the ,maximum &lily post-EPU witfidrawal will bc no greater than 65.35 MGD. Accordingly, PPL strbrnits the cnclosud t~pplicationfi,r t.1 surfi3ce water withdrawa.1of 66 MGD.

Inhnnaticm on tlzc enviroi.~~-r~ental irnpact of the EPtJ may be .Liziuld i.n two repc~rts prepared by PPL atld submitted to the IJS'NRC, copies of which were giver) lo Comtnission stn.fTat '3 rl~cetingon Novcmber 13,2006:

"Supplemental Environmental Rt?port- Ex.tended Power Uprate" ciatecl March 2006; and c 'Tnvironment~tl'Report Operating I,icensc :Renewal Stage - A.ppcntfix E" (Scction 3.1.2 --, Cooling and Auxiliary Water Systetns) da.tcd Septerrlbcs 2006; see the fcdlowing website for the entire report:

Water Use Mtr~rituringPlan AT!"ACHMGNT (1' to the ellclosed itpplication is a. prt~pnsedWater IJsc Monitoring 'Plan.

f)PT..,will corltinuc using thr: cooling tower pwformartce diagram to est.ima.te coolirrg tower evirporation. 'l+otalcooling tower water loss will bc estimated by adcling arl allowance :for ccboling' tower drift loss to the cooling tower evapnratiorl. Total surface water witl~drawalwill be dete:nnined as the suin of (it) th.c total ccsol.ing lower watcr loss, (h) the cooli~lgtower blowdown, anci (c) the ma.kcup flow to tklc ern.e.rgencyspray pcmd.

Daily vt:)l.umesof coc~lir~g tower water loss and tukil surfiicc water wi.thdrawii1 will be reported to the Ccsn~~niusic~n qua:rtcrly.

'The .R.ivcr Intakc Stn1ct;urc i~lcludesflow meters to r~~easrtre withdrawal. Ilowever, tlleterit~gof' the withdrawal has bee11 inaccnrat.~clue nlainiy .to conosiorr and fouling n,f thc intake pipes, ltc i.tltake pipes arc made of' carbon st.cel, auld PPL is evaluating rcplacerncnt of sections of this pipe with stainless stecl pipe to minimize flow meter meelsurcrnent error. Foilo~k-tgrepltrcct~~ent of secticms of pipe from two of thc four rrtake-up pumps, it may bc possible during one-unit oulagcs to operate the station with those two pumps and lo conxpare the rnetercd withdrawal l o w to .the calculated sunr of ctmling tower wai;et loss, cooiing tower blowdown, and ernsrgen.cy spray pond makcup.

Ifthe pipc rcplacccment projject proceecis arld withdrawal yudntities determined by [he two methods arc comparable, then PPL, wi!t usc the r.z~eteredwithdrawal to periodically verify the calculated withdrawal based on the sum of cooling tower water loss, cooling tower blowdown, and crnergency spray pond makeup. If the metered withdrawal is sigrzificantly diffcrcnt from the calcula.ted withdrawal, Pi)%, will discuss with the Corntnission the appropriate ncx.t steps for measu.ring withdrawal.. I>P.C.,will kccp the Clon~l~~ission r+.pprisedof these activities.

Modification of Consumptive Water Use Application :tY950301 On March 9, 1995 (:Applicalion No. 19950301), the C:ommissiun approvccf the cotlsumptive water use a.t the Susquch~fi~~l~a SES up tcs a 30-day averagc: of 40 MC:i.XJ),not to cxceed a daily usage of 48 MC31). As tiiscu.sscd with Cornmission staff at. the Novctnber 13, 2006 meeting, PPL requests a modificat.ion to this approval to elim.inale thc 40 .MGD 30-day average liit~it. 'i-his i s c;onsist.cnt.wit11 other recent cortsrimpt:ive watcr use ;~pplicationn~odificstions.

Comments PPT.. docs not, expect the maxinlurn dai1.y river watur w.ithdra.wa1 to exceed 85.35 MCiD. For purposes of this a.pp\ication,Pf31, is recluesting approva.1of a ~ ~ ~ a x i t n u m daily river water withcimwal of h6 M(31). Also, PPL does not expect tflc maximum daily colzsumptive water use to cxceed the currently appruvcd 48 .MC;D. It1 thc event (3.f an apparenl.exceedimce, PP1, reqtlests an opport:unilyb evafuai.~the prt:,blern and to disc~tss it with the SR.HC?staff"prior to the C::lorn.mlssionissuii~ga 11.0ticeo f vin1;ition.

Bascd on the Cornrnissinn's Project Fce Schedule cffcct.ive through Dccerllber 3 1, 2006,

].he fccs for the Susquehalu~aS'ES pcn71ittin.giictivities rcqtiestcd hcrein arc :is fi>llows:

Surface Watcr Withdrawal Application (66 MCjD): 9; 186,000.00 I'rqject Moditication (eiirl~inatiot~of 30-day average consnmptivc water use limit of 40 MGT)): S2,SOO.OQ Total $1 88,500.00 Pa.yment of these fics is bcirlg sent tc.1 the Commission under scparatc corrcspondcnce.

Public Notjec PfrL is proceeding to issue pirblic notice of' this application in accordance with the Cot~u.l~ission's rep~la.~ions. Notifications will be rllade LC) I-WZC~I~CCountyl Saletn Township, a lcscal newspaper, md property owners in Salcm Township either contiguou.~

to or nearby the 3usyueh.nna SES.

PPZ, req:yucst;sthc C~ot~xnission's pronzpt review arrd approval of the enclosed s~xrf:lce water withdrawal application and the request Tor nludificatio~~of thc approved consumptive water use. Should you or your skiff have any questions. ple;~qecontact me at (:6J0) 774-7889 or by e-mail at: jsficlds(ii~lwe'b.cn~~~.Thank you f i x your considc.ra.tian.

Sincerely, Jcrome S . Fields, ]?.EM Senior Etivirotxmental Scientist --- Nuclear

Enclosure:

SKBC Surfhce Watcr Withdriiwal Applic:it.t.ion Clc DeI.ivered via clcctronic mail to:

Ms. B. A. Hallarotl SRBC Mr. 'I. W. Heauduy SRBC Mr. M.0.Brownell SR.BC Mr. A. 'D. DcFioff SRBC

Surface Water Withdrawal Application for up to 66 MGD at the existing Susquehanna Steam Electric Station (SES) on a maximum day, in conjunction with the Extended Power Uprate (EPU). ATTACHMENT C to this application is a proposed Water Use Monitoring Plan.

1. Applicant Information:

Company Name: PPL Susquehanna, LLC (PPL)

Mailing Address: Two North Ninth Street - GENPLS Allentown, PA 18101-1 179 Contact Person: Jerome S. Fields, REM, Senior Environmental Scientist-Nuclear Telephone: (6 10) 774-7889 Fax: (6 10) 774-7782 E-mail: jsfieldsG~up1web.com

2. a. Location of sources:

State: Pennsylvax~ia County: Luzerne Municipality: Salem Township

b. You must attach a copy of a USGS 7 1/2 Minute Quadrangle map indicating location of proposed intake(s), all existing project sources, and any water storage facilities.

ATTACHMENT A to this application is an electronically formatted copy of adjoining USGS quadrangles :Bewick (PA) and Sybertsville (PA) showing the locations of the facilities. water resources and discharges associated with this application.

3. Purpose of withdrawal: The Susquehanna Steam Electric Station (SES) is an existing, two unit, 2,380-megawatt electrical (MWe), nuclear-fueled electric generating station.

An Extended Power Uprate (EPU) is planned for the Susquetlanna SES to be implemented in stages from the second quarter 2008 through the second quarter 2010.

The EPU is expected to increase the station output to approximately 2,600 MWe.

The Susquehanna River is thc primary source of water for the Susquchanna SES and provides essentially all of the cooling water associated with the generation of electricity The withdrawal of surface water from the Susquehanna River for commercial operation of the Susquehanna SES began in 1983. Water is pumped from the river at an intake

adjacet~tto lhc stat:iot~.'l'hc R.ivcr I n u k e Str~tcturect?nI;lirrs four ~ L I I I I ~ci.ich S , r'ateri at 13,500 gprr1. 'Ihe e s h a i e d ~naximi~m daily wi1.l-rd~awalby thc clcist.ing station is approximately 58 MGf). "l'he maximum daily withdrawal Iiom the river is expcct.cr1to gradually incr'eat;~to approxin~alely65 MGL) as thc EISU is implemented; however, .this application is being subrnit.ied fix h0 MCi'l), Thc increased \vithdrawal will not .ncluire rnc~dificat~on to I11c int.a.ke,the pumps or the cooling system,

4. Source(s) frortl which withdrawal is being rsqucsted:

• .

Safe Yield or Quantity of Withdrawal Q7-to LOW

~E~!!!!E! _.- How2 Drainage Location of Maximum Maxlmum at Point of Area Taking Name of Source 30-Day Day, Taklnp (square Point Averaye (mad ) oWJd 1 miles) (Iatitude/longituda)

-.,,,8. . - m,, z.= 0-.=. i J i h - ...-........l.r m*;;:.:: -- .

Sirsy~rehannaIZivar NA 06 MGII Nrstc 4 Approx, [at: N4'Io05' 12.4" Notc 3 10,200 sq. long:

~nilcs W7(i087'53.2"

._."-".___l.._.._.,- . -.- ,,.,..,,.v.. - -- -. ..-.--l_l-.-- _.....,,.

",

Note 5 NA 66 MGlI Note 4 "l'otal Note 3 A 1

.mgd== nlilliorl gallons per day 2 Use acceptable hydrologic practices in detcmirzir~g7-day, I.(:)-yearlow flow.

3 Quanti.ties sllown do not include allowance for measurement error.

%

A Q7-10 flow o.(' 8 14 cf's f 525 MGD) at the USGS gage at Wil'kcs-Bnrrc ('No. 0 1530500) has heen used by the C~onanissionin determining [.henced for consunlptivs ust compcnsa.tiot1 selcascs lioxrr Cowanesque R.csccvoir. vFhe Wilkcs-Warre g:ge is sl~proxim~tefy 20 rx~ilesupstrt!arn fronl h e SSES river intak:. At 1:treWilkcs-B:~rrcgage, Ihe 90-pcrcerit. cxceedanct: .flow is 1,670 cfs, thc mir~irnutnseven-day low flnw is 546 cfs (Sepfcmber I964), and the ~ninilnurncla.ily flnw is 532 cf$ ((Seyntember 1964).

5

'Yhe drainagc area at the 'Wi1k.t.s-Ramt.gage is 9,900 sq. rnilcs. *Ihe drakagc area at the t..iSC,'rSgagc at l>anville (No.01540500), approximat.cly 30 tniles downstrc;rl~~. Is 1 1. 200 scl. miles.

5. 'Prior or perrcling stat,e or fedcral permits:

r" 1 Permit Issue I p_

".m=~- = I ?3tatus3 I__ Agency --&J.wc2z!~. Permit Number

_.__..._I_--~,~72m--~-z=

-ng Water Pcnni t I'rior [.)aT)Ef) 2/17/89 2400994 iL 12/4/85 2400905

' 6 i 12/4/85 24OOI199

-

LC iL 1

-... 2/4/85 2400335 T)a~*t.~s Penni t. N/ A

..-.--..,.,,,.-,,L..~..,.--.,-"---.--,~.,- . -

Encsonchmeni or Wa.ter ~ n o ~ . r.lSAC:OE O! I 3/06 C:ENA.H-OP-RT'A C)bsttucr.ionPermit (intrtk.~ & Psl")El:' 06- 10 107-1'12; E40-and cfischarge diff"uscr) 195

.Prii:)r .L X/3 1 /8X C::ENAII.~OP-III'<87-

" " - \,.,.,,..,.

17(i7-4;1'.40-1!>2

,,,,...-

W a.t.er Prior SR.RC' 3/9/95 1095030 1 Al'tocatior~/Aj~propri;~.t.lc~~i . , ..,... .. Note .. ... 3-

....... ......... ........ ........................ ........

I'cnni 1

............ ............... .-- ..................... .- ..........................

('thcr [NPf)ES) 9/1/05 NPl:):SiS

... ,.. ... .. . ....

P.A-0047325 ....

Otller (Opsrating li.ceoi;a) 7 / 17/82 NI'F-14 3/23/84 ;NPT:-22 Note 2 NW" 14 i

N 1'1.2-22 1

If not ;~~)plicablle list (NA); iSpendi.r-rg,(:I"; if recluircd but. nor applicd fur, (R.)

h h n epplicalion was subluitt.cd to thc US Nuclcrtr Regulatory Commission on Scpt. '13, ?OO(i to rer~cwoper:~.tinglicerrses NPF- 14 and NPF-22 for 2111 additio~~al 20 years.

.3 See also contract between the Commission iuld Pctlr~sylvaniaPower cYr I.,ighl Cornpa~~y Sbr development of water supply storage in Cnwa~iasqueRcscl-voir, dated June 30, 1986.

6. Sltow by cakrtlntk,n how the "Quantity of Withtlrawal 'Rcqt~ested"was dr\terrninc.d, I:)csa.ibehow surficicnt this allacal.ion will k xSn nlccting the fut~ireneeds of this project.

Ilescribe nltct'nativc soilrces of supply considered in lieu of requcs~.ir~g a new or increased rtllocat.ion fiom the sources listed ill Apglicatiol-r Sectiork 4. (Attnch additio.nal sheets, as r~ecessary.)

See AI*'TACE.iMENTB.

7. Existifig and projec1:edtotal water use:

I, Total Project Water usage'

---

z=zhwmr=+ -. ...------- Existing (mgdj2

='i-dr.uI;Xr-;Xr--

for Design Yaar 2008 and

--l=--mx*-

Projected (rngd13 b e '~rr?F='='='='='

-- ILC- nd I

42 MGD Notc S 46 .M.C;Dit1 2008 Avcri4ge I2ni 1y Writer 1)emarid 44 MGI:) in 2009 52 MGD in 2010 and bcycilrd

-.-,-..-- --,.-.-.- -..,.a-.v-.-- ......-...,,- ....Notcs 7 and-d."d-,",".-"..,-........ 8 5 8 MCII: N o ~ eli 60 MC;D in 20f)8 Maxirrtutt~Ilaily Watcr Ilcmand 64 MCjD in 2005) 65.35 MGL) in 2010 and bcy011i.1

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'I'hc river ir~takcI1a.s four Thc exi.st:ingsystcrrl capacity i s pumps, each rcztcd at 1 3,500 adcqriate and will not nccci to gpm. flowever-, tllc system be i trc.rec?secifor the t'.Pl..J.

capacity with all .Pr>urp'u.tnps operaling is ilpj~roxirnately 45,000 gprn hut ca.n w r y depcl-rdi.ngor) rivcr conditions and thc condiliorls of thc

{,uttlps. -

' I)rc>jeclwater ilsagc sho~ildbe on an arnlual basis, i~nlesstl~c;q>plicarior:1is for i:l scasnnal c~pcration. Fold seasailal ilses, indicate [.tie dura:t.ion or t t ~ cusc (the i.lui~tber.of months on whic'h tl~cavcrage is basccl').

For new prqjccts, the existing use should bc the proposcd use during thc first year ol'opcration.

3?+

She prujccteci use sllc~rrldbe for 25 ycars in the future (design yew). Xf [..hepiAc!ject dla:.itiurr is Iess than 25 yeius, indicate the year for which projections were madc.

1-t~cexist.ingsystem capacity shoulti not includc the proposed sources u.nlcss thc apy1icat:ion is ['or a new prc~jccthaving no prior withrlrawal.

"vsr;ige usa.ge,years 2002-2005: cooling iowcr .wat.erloss (29.5 MGI), :from coolit~gtuwer pcrli~n~liulcc diagram) .+ average cooIir~gtower bluwdown (1.1.8 MGD,rnctered) ,-I- etnsrgency sprny pond makeup (0.4 MGI), csticnated) =: 4 1. -7 MGZI.

s ~ usa.ge, yeiirs 2002-2005: cooling towcr water loss (40 MGD, h a x i ~ n r n tlaily liwu coc?l.ingtower perfi~rniat~cc ctiagran~)+ tna.xirn~1111 cooling t;owerblowdowtl

('17.3 MOD, ~-tlcrcred) emergency spray porld makcup (0.4 MGSI, estimttted) =

57:7 MC;I).

' Estirrrafcs cio not include allowaricc fbr measurer~zcnterror.

' Ann~ralavcrage cc>ns~m~ptive water ,use upon conrplction o f the EPlJ Is expe~led to be 37 MGD.

%axirnilm daily consumpti~vcwater use upon con~pictionof the EPI..J is expected to be 48 'MG.D.

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b. Other sources of water (stream intakes, interconnections, reservoirs, springs, etc.):

1 indicate if source is used on Regular (R), Auxiliary (A), or Emergency (E) basis,

' Indicate purpose such as potable supply, process water: nun-contact cooling, or irrigation.

tfgavify-fed, give maximum hydraulic capacity and label as such.

d Provide method of conlputrttion f o 7-day,

~ 10-year low flow for run-of-stream saurce.s.

9. Raw water ponds, lakes, intake dams, and storage dams (existing and/or proposed):

Year of Last Name Year Sedimen- Storage Surface Drainage Release Constmcted tation Capacity Area Area works' Survey (mg) (acres) (sq mi) (yes) (no)

Lake Took-A-While 1978-1979 March Est. 30 Est. 30 Estimated Note Note 2 1999 Note 3 0.53 4

' ~ o e the s dam have facilities to provide a release of water to the stream when water is not flowing over the spillway or top of dam? If yes, describe length, diameter, depth, valving, etc.

Lake Took-A-While is located within the Riverlands Recreation Area and is solely a recreation facility.

3 Surface area has varied in different reports fiom 24 to 35 acres. For the License Renewal environment report 30 acres was used for area.

4 The spillway has stop logs that can be removed and replaced manually to control lake level.

10. Preparer:

Name: Jan C. Phillips, P.E.

Address: 26 11 Walnut Street Allentown, PA 18104-6230 Date: ~ecern* 19,2006 %-mail Address: jcohllos@enter.net

11. Applicant:

& Chief Nuclear Officer Date: December 20,2006

Attachment A Topographic Map SSES

PPX.,S,uscpeh.an:na,L,IK

.Appl.iciitiortto SRBC for Surfgcc Water Withdrawal 1)ecernber 2006 Application Section G Determination of ~ u a n t i ot f~Witl~drawalKrquested Thc Quantity o f Wittldrawal Requested is 00 MCjD on a t x ~ a x i ~ n clay. u ~ ~ r'i"his arnount. is tlw su.tn, .to ihc. ~ ~ chigher xt MGU, of(:a)the astir.rtnted maximum daily watcr loss from the cooling towers {cvaporation plus drift a.llowatkcc) following V1111 irnplctnentation ofthe Exttnc:led Power Uprate, (b) the cooling towcr blnwdau\rn rate associ:ited with ,L~IL' cstimatecl maxim.um daily cool.itig tower loss, and (c) the estimated.

rnakeup flow lo t l ~ ectnergency spray pond, less (d) ri srna1.lcontribution o f wel'l walcr to

!he cci~rjlingwater flow. The Qt~imlityof Withdrawal Requested does tiot include an allowance I'or fl.ow measurcrnent, error.

(Zoolirlg tower evaporation is deternlil.~cdfrcril-, the designer's cooling tower pcr.r'orm;znce diagram (Ex.hibil A 11crct.o). Coc)ling tower cva,poratiorl a.s a pe~cer~tage of t.he cooling tower watcr flow is a function of wet-bulb temperature, re1ati.v~humidity a:nd cooling rarrge. ':The post-EP1-l maxinium dai1.ycc~nsurt~ptivc water use 113sbeen dcton~~ined assum.i.ngthe :T{>llowingcorrd,itions:

Wet-bulb tcmperalurc (WR7'): 77.OUI' IZclativc h~rl-rlidity (R.'["1):40 percant Cloolir~grrtnge: 35.7 F clcgrces Cooling towcr water flo'w: 5 1 1.,000 gprrl pc r tower

':i"hesetectccl etlvironmental conditions (WBT a:nd RH) arc consid.erec1to hc co~lscrvative f'or est.imati.ngt:tlemaxirrrurrl daily ev:lpc>rativc loss.

'I'hc coolir~gtower watcr Ilow comhirlcs circulaking watos flow (484,000 gpm) anti sclvicc water flow (27,000 gpfn). TIE ecc)oling range (35.7 F dcgrccs) was calcularcd based oil the cortlbind heat cor1lriIrutio1-r~ of the circttfsting arld scrvicc water flows.

Frorrl Exhibit A, fix the assurncd WU'I', KH and cooling range, tfrc rate of cvaporation cxp:ressed as a percentage o l'thc cooling tower wntcr flow is 3.22 perccnl.

'I'hus, the evaporative loss pcr cooling towcr cxprcsseci in b ~ n is: l Evr.rporal:lvctoss per hwer - 5 1 1,000 gpnz x 0.0322 =: 16,454 gptn.

T'hc cot>lil~g u r ~ r ' s (>I'Lhcratc c>fcootingtowcr drift loss II)WCC ~ ~ i ~ . n u d $ . ~ tcstitnat.~"

is 0.02 perccr~tof't.hc cootirlg tower water [low. 'I'i-rus, thc drift fuss per coolirlg t.ower expresseti in gprxl is:

f:)rift. loss pcr tower .:-: 5 1 I,OOO gpm x 0.11002 -- 102 g7m.

Thus, thc cstim;~ludpost-EI'U maxirr.lutn daily water toss Iiom the two cooling towers combined, cxprcsseti in MCiL), 1,s:

2 x (16,454 $~>t'r~ -I-. 102 ~ ~ T T xI )0.CtO 144 MGI)/g,rn -- 47.68 MGD.

C'ooli,rrgtowel- I~lowclowncoll~prisesmost of the .nc.,n-consunlpt.ivr:water tlsc a1 ttlc S~lsqucha.nni~ SES. 'I'llc blowtlowtz ratc is a, funcliori ol'waler c h e ~ ~ l i s l am.ong r y ~ ot.her

,.-

things. S hc cooling towcr blowclow~tratc is approxi~natcdas:

Elowclown per towcr --- [evilporalion / (:concci~tr;~tion f;tctur - I.)] -.-drift.

Asst.aning a coi~oe~xtralion factor of 3.7, the blowdown rale per tower cxprcssed in gprn is:

116,454 gprri / (3.7 -- 1 ):I 102 gpm = 5,992 gpnl.

'I'hus, tY~acstirnatecl b.lowduwn rate corresponding to thc maximurn daily evaporative loss .for t1.1~two towers corrlhitied, cxpresscti in MGD, i s :

2 x 5,902 gp111x 0.00144 MG'D/gptn .cL 1 7.26 'MGT).

The t.nnkcul>flow to the emergency spray pond is estiinated to be 300 83r-n

-

Expressed in 'MC;.L),the estin.r;itted cmergcncy spray pond maketlp is:

300 zprn x 0.00144 MGD/grn 0.43 MGD.

A flow of approximately 0.02 MGD originating from thc station wells is added .to the coc:)Iingwater system.

'I'hus. thc iota1 post -EPl J rnaxirnu~udai I y sitrfiice walei- wi lItcll':~wat IS csti malecl as: -,--- ,.

I Chu1.in.atower c;vanorat.ior~an0 cirifl 1 r . m 1

"

47.68 MGn 1 -t. 17.26 MGD 1 CIooling tower blowdown I i I

.-I...0.43 MGD Emergency spray pond J I I ~ ~ C U ~

% ., ,-

,,,.,.. ..., ..

- 0.02 M.GD Flow fkrn station wells ...

-;:? 65.35 MGL),,,., .- Maxitrluil~dai.lysul.f;icc water withdrawal d

. ".,.,,,, ---

or 06 MCjl'I, to the next higher h4(:;D.

'lhc "Qtianlity of W ithdrawol Iieq.~iesteci" showrz irr thc tablc of' Ilem No. 4 o:lthe

ipl~licationi s the 66 M.til:) estimated maximun~daily surfiice water witlldrawal ratc. l't1i.s (it; MGD is anticipated to be adequate Ibr the htcsceable lik ol'thc S~isquch;ll.~nn S.ES.

N o aItcrnative svurccs for d ~ amounl e crfadditiol~alwater r~ccdcdby the Suscluchan.na S'ES fol.iawing the EPU were consirlcrcd, [.lorwo!~ldany be practicable.

P'B'L Su.squet~ani~a, LLC A.pplication to SRBC fur S.urhce 'Water Withdrawal I)ecem.ber 2006

.P.roposed Si~squehannaSES Water Usc Moilitorirlg Plan

-l'tli.s 1?1a1>provides for the rnctcring an.cl measurcincnt of data ticcessary to cictarrnirrc, for rcporling io thc Commission, tl~cfollowing watcr quantitics at thc Susqucbanna SES:

Daily cooling tower watcr toss (:evaporationand drifl loss) hiit.caclr generating unit; and r I:lai.lysuk~*f'acc the Suscluch;u~naR.iver.

wa.tcr withdrawal fi-c~~l~

Exhibit A to this T'lai~is a sla.tion water flow schematic diagram ("SSES Wntcr Ft'lnw iliagrarn .- Post-ET'l ...J Maxirnu11-1") showii~grhc fitcilities and flows it-rdicatedIlercin.

The daily surface water witl~clrawalis delen~~il~ed .Ii:om t;lx es~imdeddaily cooli~lgtower watcr loss, the rrictercd cooling tower blowclown, and the estimated n~akcupflow to the emergency spri1.ypond.

C 0 0 L l ' N G TOW.EK W,A"TERLOSS F'PI.., r-rrain.ttzinsand ope.ratesa ~neteorologiclzlstation on tirc Susquct~annaSES site, 'Wet-bulb ternperaturc (WB'I') and K.clative11umidi.t~ (:RH)arc caIcula.terlusir~gtcn~:pcratu.re anci dew p0in.t. 'Daily avwages of hourly tanperaturn and dcw point. readings arc used to calc~rlatedaily WZ3.T' and IPH. Ternperaturc is accurate within &O.C)"Fatlcl dew poi111 to

-+2.7"F.

']:'he t.ot;tI watcr flow to each ctloiixlg .tower is the sum o:f'the respective generating urlit's circufating wntcr flow (a.pprc-,.xinratelyBS percent) cud the unit's servicc water flow (approxirnat.ely5 percent). '3"hcratc of c:irculalirtgwatcr :flow is measurcd conti~~uously, by ultrasonic metering at Iln.it;1 and Isy mctcrhg power in:tlow to .the circrilatirlg water pumps at I..ln.it2. The rate o f sc.rviccwater flow is ass~lnlcdlo be a constant 27,000 gptn at each unit. .Mc;lstacmcnt of tllc circulaling water flow i s a.ccuratcto within 4-2.5 percent.

'X'l~ccooIing range is the dil'ferei~cchelwccn lhc hot-water tc~rq:,claturcand llie ccjld-water in the ~001j11g tar.iper;ll.r.~.rc wi~tcsflow. The cooling range a.t S~.~squchnt~.nc? SES i s t1eta:rnincd From thc hot-.wa.i.erterrtpcraturc 21nd the cold-water tei~~pefiit~trc in l.hc circulntitlg w;:iterIlow; this a.ssl.imesthat thc tt"mpcratl.iredil'krence in (.he cir-culnting water 17ow is .~*cpresa.itativc of thc tcmperatutx d.iffcrcnce in tile scrvice water flow. Thc hot-wa:tertempc.ratt~re;rut1 llic cold-water tc~nperaturein the ci rculitling water flow are rncasured canrit~uausiy..AccOrclirrgto m;~~~l.~f;lcturcr spcciflcations, thc tcrnperiitture mensure.mentsart: accurate t.o wilhirr 22 pcrcent.

PI?!.,believes that the niost accurate way to estirnatc cooling tower cvapuration a1 i.he Susyuchn~irtaSES i s by use oI'thc coo1in.gtower performance c1iayrarr.1(.Exhib:itA to ArT"I'ACHME:NTB of this application). The cc,olin~tower perfnrmancc diagram w r ~ ~

prc~.~iucd by [he coc~lit~gtower dcsigtlcr and upd.at.edby I'PL t.0 iix1dica:te the expcclcd pns.1-EPil maximum cooling towcr water flow rate (5 1 1,000 gpm per generating unit). 'I'tle diagrarz.1 pcrm.it.sconling tower evaporation (gpxn) to he estimated from the values of WHT, R.1.-1, cooling range and cooling water flow rate. To asliarate daily evaporation, t l ~ c daily averaye Wi:3'T,KFI, coo1in.grange and cooling water flow ratcs u l r c used.

The cooli.ng tower rnarlufacturcr estin~atesthat drifl loss rate is cc).uaXto 0.02 percct~ttrf the coalins towcr wal.er flow rate. The nominal EYtf cooling tower' watcr !low rate is 5 1.1,OOO gpm PC" L I I ISO~ ~that

, tkc est,ixnatecldri Tt rate i s 102 gpni per tower. Il'or purposes of*cstix?lat.ingactual, loss, i t will llc sufficiently accurate trs assume a constant drift loss of 100 gptn or 0.1 5 MGL) per t.owelawlrcn thc rcsl~cclivcgcncroting unit is or1 I.inc.

'flhe total coolirlg tower watcx loss h r eacl~gcncrat:ingi~nitwhen operating i s thus rhc estimated cva.porabion loss plus an1 ;LI lowarlce of 0.15 MGD for dri.f"tloss.

COOL,lN(: TOWER R1,OWI)C)WN Coolirlg tower blowdowr~rcprese~ltsr~carlyalt c3.F tlic rion-consnmp~tivewater usc at the Si1sq~tclla1ti.aS'ES. Klowdown from each cooling tower is rnctcrecl continuously.

Coolitrg ta.wer b1owciowr.l flaw rncteririg i s accuratc to within 22.5 pcrccnt. Coo'lin~

tower blowdown is d.isc.t~argerl to the river clownstrcarn j?om tba station.

l-hc cn.lct.genoy sprq pond h.as a scirhcc area o f apprdoxin.xalclycigl.it (8) acrcs. 'I'htr:

cstimal.ed rnakeup flow to the cmcrgency spray pond i s 300 gpn, or approximately 0.43 MGD. Most of this flow is discha.rged kern the pond to thc coo1itlg tc:)wcr blowdown line downstream uf'thc cooling t.nwct Erlcjwdown melers. F~rircrgcncyspray pond Icvcls are monitorcd, and discharge con be monitorcd at at1 c~verflowweir. A sma.ll portion of the emergency spray pond makcup rcpla.cesevaporatiot~fron~.tht" potid.

SURFACE WATER W1'l'I.I 1)RAWAL Each genera:tit.~gunit's total water usagc is the sum o,l:'itscooling [.owcrwatcr loss (consutnptivc water use) and cooling tower blowciow~i(non-consurnptivc watcr use). 'The iota1 stat'ion surf;lce watcr withdrawal is cstir~raterlas thlc combined water usagc of'tfic two generatirlg units plus an allowance 01'0.4 MGD fix the ccmrgency spray pond mtkeup.

'Data monitor~duncler this Plan art. contint~c~nsl y cntcrcd in the Snsrluelza.ni~aSES Plant Integrated Compu'ter Systcm and reacl.ily irltcgrated inlo daily averages. Final daily y~ianlitiesof the data Lo bc recorded i t ~ ~rgorlcti d (bclow) arc arga.nized anci/ar dcrivod by sp~;ccadsheel.The rcfatjonshipstlepicted on thc caolitlg lower perl~ormi~ncc diagnnl arc programmed. in sprcaclsheet fonrr.at to frrci.litaleestirrlatin.gcooling towcr cvapor;~t.ion fron.1 ttlc relevant drtily. average data.

RECORD-KEKPiNI; AND REPORTING I'PI., wi1.I kccp daily rccords d ( a ) the cooling tower watcs loss for each geirctating ux~it, (b) the cooli.ngt.owcr b.lowdown for each generating tinit, and (c) .the total station surface water withdrawa.1,all es'titnatetf or rncasureci ns dcscnhed hcreiri, and wi.ll rep01-t the daily cooling towcr water loss x i c t tile daily totill station surface watcr withd:r:iwal an~ourits, cxprcsssd in million gi:iIlts.ns,to the c~ommissianeach quarter.

EXHIBIT 2 Exelon Generation Company. LLC Dresden Nuclear Power Station www.exeloncorp.com Nucl ea.r 6500 North Dresden Road 10 CFR 50.73 Morris, IL 60450-9765 U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001 Dresden Nuclear Power Station, Units 2 and 3 Facility Operating License Nos. DRP- 19 and DPR-25 NRC Docket Nos. 50-237 and 50-249

Subject:

Licensee Event Report 2004-006, "Units 2 and 3 Main Turbine Generator Rotor Cracksn Enclosed is Licensee Event Report 2004-006, "Units 2 and 3 Main Turbine Generator Rotor Cracks," for Dresden Nuclear Power Station. These events are being reported as a Voluntary Licensee Event Report in accordance with the guidance contained in NUREG 1022, Revision 2, "Event Reporting Guidelines 10 CFR 50.72 and 50.73."

Should you have any questions concerning this report, please contact Pedro Salas, Regulatory Assurance Manager, at (815) 416-2800.

Dresden Nuclear Power Station Enclosure cc: -

Regional Administrator NRC Region Ill

-

NRC Senior Resident Inspector Dresden Nuclear Power Station

r-

~NRC FORM 366 U.S. NUCLEAR REGULATORY COMMISSION 1 APPROVED BY OMS: NO. 3150-0104 EXPIRES: 06/30/2001 Estimated burden per respanse to comply wlth this mandatory collectior request: 50 hours5.787037e-4 days <br />0.0139 hours <br />8.267196e-5 weeks <br />1.9025e-5 months <br />. Reported lessons learned are lncwporated Into UN licensing process and fed back to Industry. Send comments re ardin buider I estimate lo the Records and FOlAmrtvacy Selvlce Branch (8-5 F&), U.S LICENSEE EVENT REPORT (LER) NuclearRe ulatory Cammlsslon, Wasbngton, DC 20555-0001, or hteme e-mail to ~nfocol~ects@nrc. ov, and to the Desk Officer. Office of l#ormatior and Regulatory Affalrs. NE~B-10202,(315W104), of Management am Budget, Washington, DC 20503. Ifa means used to Impose an lnforrnatlo~

I 1. FACILITY NAME (See reverse for required number of digitslcharacters

- for each block)

. collection does nd display a currently valid OMB mntrd nunber, the NRC ma!

not conduct or sponsor; and a person Is not requlred to respond to, thi lnfomlinn dleclinn.

2. DOCKET NUMBER 13. PAGE Dresden Nuclear Power Station Unit 3

4. TITLE Units 2 and 3 Main Turbine Generator Rotor Cracks

5. EVENT DATE 6. LER NUMBER 7. REPORT DATE 8. OTHER FACILITIES INVOLVED S\\fBzL FACILITY NAME

r DOCKET NUMBER MONTH DAY 'YEAR .YEAR MONTH DAY YEAR Dresden Unit 2 05000237 2004 - 006 - 00 01 FAClLlrY NAME DOCKET NUMBER 10 31 2004 19 2005 I I I I I I I I I I

9. OPERATING MODE I 11. THIS REPORT IS SUBMITIED PURSUANT TO THE REOUIREMENTS OF 10 CFRS: (CheckaN that apply) 20.2201(b) 50.73(a)(2)(i)(C) 0 50.73(a)(2)(vii) 5 20.2201(d) 50.73(a)(2)(ii)(A) 50.73(a)(2)(viii)(A) 0 20.2203(a)(1) Ll 50.73(a)(2)(ii)(B) 50.73(a)(2)(viii)(B) 20.2203(a)(2)(0 50.73(a)(2)(iii) .50.73(a)(2)(i)(A) i0. POWER LEVEL 20.2203(a)(2)(ii) 50.36(c)(I)(lr)(A) 50.73(a)(2)(iv)(A) 50.73(a)(2)(~)

20.2203(a)(2)(iii) 50.36(~)(2) a 50.73(a)(2)(v)(A) 73.71(a)(4) 20.2203(a)(2)(iv) 50.46(a)(3)(ii) 50.73(a)(2)(v)(B) 73.71(a)(5) 000 1 20.2203(a)(2)(v) 0 50.73(a)(2)(i)(A) 50.73(a)(2)(v)(C) OTHER 0 20.2203(a)(2)(vi) 50.73(a)(2)(1)(B) a 50.73(a)(2)(v)(D) specify In ~bstractbelow or In NRC Fnm -A

12. LICENSEE CONTACT FOR THIS LER FACIUW NAME TELEPHONE NUMBER (Indub, Area Code)

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Dresden Nuclear Power Station George Papanic Jr. (815) 416-2815

13. COMPLETE ONE LINE FOR EACH COMPONENT FAILURE DESCRIBED IN THIS REPORT MANU- REPORTABLE CAUSE MANU- .REPORTABLE CAUSE SYSTEM COMPONENT SYSTEM COMPONENT FACTURER TO EPlX FACTURER TO EPlX X TB GEN GO80 Y . NA i

14. SUPPLEMENTAL REPORT EXPECTED 15. U(PECTED MONTH ' DAY ' YEAR SUBMISSION YES (If yes, complete 15. MPECTED SUBMISSION DATE) . Lg NO DATE ABSTRACT (Limn to 1400spaces, Le., approximately 15 single-spaced lypewritten lines)

Dresden Nuclear Power Station, Units 2 and 3, had been experiencing increasing trends in vibration levels on both Main Turbine Generators, bearings 9 and 10 since May 2004. Numerous efforts and reviews during the summer and fall of 2004 were not successful in resolving the vibration. Dresden Unit 3 entered a refueling outage in October 2004 and as part of the outage scope, the Main Turbine Generator was inspected. On October 31,2004, the inspection identifiedthat the Unit 3 Main Turbine Generator Rotor had a crack in the shaft near the rotor coupling. This finding resulted in the decision to remove Unit 2 from service and conduct an inspection of its rotor shaft. On November 1,2004, a crack was identified on the Unit 2 rotor shaft. The Unit 2 crack was in the same general location and similar configuration as the Unit 3 crack.

These events are being reported as a Voluntary Licensee Event Report in accordance with the guidance contained in NUREG 1022, Revision 2, "Event Reporting Guidelines 10 CFR 50.72and 50.73."

The root cause of these events was determined to be intermittent oscillating torsional loading on the generator rotor, which produced a torsional fatigue failure mode. The cause of the intermittent oscillating torsional loading is indeterminate. The cause and source of the intermittent oscillating torsional loading will be investigated through analytic modeling and data acquisition during plant operation.

L I MIC FORM 3@8 (6-20W) PRIMED ON RECYCLED PAPER

I I NRC FORM 366A U.S. NUCLEAR REGULATORY COMMISSION (1-2001)

LICENSEE EVENT REPORT (LER)

T FACILITY NAME (1) DOCKET 121 LER NUMBER (6) PAGE (3)

RNlSlO SEQUENTIAL N YEAR NUMBER NUMBE Dresden Nuclear Power Station Unit 3 05000249 2004 -- 006 -- 00 2 OF 3 I

NARRATIVE (If more space is required, use additional copies of NRC Form 366A) (17)

Dresden Nuclear Power Station Units 2 and 3 are General Electric Company Boiling Water Reactors with a licensed maximum power level of 2957 megawatts thermal. The Energy Industry Identification System codes used in the text are identified as [XX].

A. Plant Conditions Prior to Event:

Unit: 03 Event Date: 10-31-2004 Reactor Mode: 5 Mode Name: Refueling Power Level: 0 percent Reactor Coolant System Pressure: 0 psig ,

B. Description of Event:

~resdenNuclear Power Station, Units 2 and 3, had been experiencing increasing trends in vibration levels on both Main Turbine Generators r A ] r B ] , bearings 9 and 10 since May 2004. The Main Turbine Generator bearing 9 is located between the electric generator and the low-pressureturbine.

Bearing 10 is located between the electric generator and the exciter FL]. Numerous efforts and reviews during the summer and fall of 2004 were not successful in resolving the vibration.

Dresden Unit 3 entered refueling outage D3R18 on October 26,2004. As part of the outage scope, the Main Turbine Generator was internally inspected. On October 31,2004, the inspection identified that the Unit 3 Main Turbine Generator Rotor had a significant crack in the Main Turbine Generator Rotor shaft near the turbine end coupling. The crack was approximately 13 inches in length. This finding resulted in the decision to remove Unit 2 from service and conduct an inspection of its rotor shaft. On November 1,2004, a crack was identified on the Unit 2 rotor shaft. The Unit 2 crack was approximately 10 inches in length, in the same general location and similar configuration as the Unit 3 crack. These cracks resulted in a change in the Main Turbine Generator Rotor shaft stiffness, which caused the increasing trend in bearing vibration.

'These events are being reported as a Voluntary Licensee Event Report (LER) in accordance with the guidance contained in NUREG 1022, Revision 2, "Event Reporting Guidelines 10 CFR 50.72 and 50.73.'

C. Cause of Event:

The root cause of the rotor cracks was determined to be intermittent oscillating torsional loading on the generator rotor, which produced a torsional fatigue failure mode. The cause of the intermittent oscillating torsional loading is indeterminate.

Dresden Unit 2 and Unit 3 have identical Main Turbine Generators manufacturedby General Electric Company. The Main Turbine Generator Rotors are NiMoV alloy steel forgings that were fabricated to GE Specification 850A375A70-S4 in the mid-1960's.

I

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NRC FORM 3BM(1-2001)

I NRC FORM 366A U.S. NUCLEAR REGULATORY COMMISSION (1.mol)

LICENSEE EVENT REPORT (LER)

-

L F A C l L m NAME (1) DOCKET (21 LEU NUMBER (6) PAGE (3)

RNISlO SEQUENTIAL N YEAR NUMBER NUMBE Dresden Nuclear Power Station Unit 3 05000249 2004 -- 006 -- 00 3 OF 3 NARRATlVE (If more space Is required, use additionalcopIesof NRC Form 366A) (1 7)

The Unit 2 and Unit 3 cracks initiated in one of the two generator rotor shaft keyways under the turbine end coupling. The coupling is an interference fit to the shaft. The assessment of the metallurgical examination identified that each crack propagated at a 45-degree angle in a spiral fashion around the shaft with approximately 200 beach marks. The beach marks are indications

'

where the cracks stopped and started again. 'The assessment concluded that intermittent oscillating torsional loads above the material fatigue endurance limit caused the crack propagation.

Dresden sent both Main Turbine Generator Rotors offsite for the inspections and to have the cracked end of the rotor shaft replaced with a new stub-shaft. A contributing cause to the reduced shaft material fatigue endurance limit was fretting. The ability of the shaft material to withstand fretting has been significantly increased by a redesign of the shaft keyway to eliminate stress risers and to increase shaft torsional capacity by an improved coupling shrink fit.

D. Safetv Analvsis:

1 The safety significance of the event is minimal. The Main Turbine Generator is not a safety related component and it is not credited in any Dresden accident analyses. Additionally, an engineering assessment concluded that Main Turbine Generator vibration levels would have exceeded '

operational limits prior to reaching critical crack size and the generator would have been removed from service prior to potential rotor failure. Therefore, the consequences of this event had minimal impact on the health and safety of the public and reactor safety.

E. Corrective Actions:

Dresden sent both Main Turbine Generator Rotors offsite for the inspections and to have the cracked end of the rotor shaft replaced with a new stub-shaft. A contributing cause to the reduced shaft material fatigue endurance limit was fretting. The ability of ,the shaft material to withstand fretting has been significantly increased by a redesign of the shaft keyway to eliminate stress risers and to increase shaft torsional capacity by an improved coupling shrink fit.

I F. Previous Occurrences:

A review of Dresden Nuclear Power Station LERSidentified no similar events. Additionally, a review of LERs from other nuclear plantsdid not identify any similar events.

I G. Component Failure Data:

GE Main Turbine Generator Rotor shaft r

NRC FORU 3EM (1.2001)

.

EXHIBIT 3 Interim Sum Report Independent Root Cause Anatysis Assessment of the Detroit Edison

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Fenni 2 Turbine Generator Event on December 25,1993 Prepared by; Principal Investigators:

Mr.Do~d Kidder Mr. Ralph Onolano Dr.MS.M o d Reviewed by:

Dr q o n g Chiu _. -._.. r. '

i .

., .. -4 9603030066 9 5 1 2 1 4 3 ,.

PDR F O I A K E E G A N ~ ' ~ - A - - ~ PDR THIS REPORT WAS PREPARED BY FPI IN'fERNATIONAL FOR THE DETROIT ED1SOI';

COMPANY, FERMl2 NUCLEAR POWER STATION AS A PROPRIETARY REPORT ANY RELEASE.TO - -

A TKlRD- PARTY

- - - - - REQUIRES WRITTEN

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APPROVALS FROM BOTH DETROIT

~ ~ ~ - ~ R ~ ~ ~ A I L C L P ~ 1994~ ~ P . ~ ~ F Table of Contents IlI Coedusions IV Recommendations V Event and Analysis Xnformation A Significant Time Line Events B. AnJysis Data

1. F m i Independent rioot Cause Analysis Engagement Plan 2 Fault Analysis Tree Matrix

3. Timeline of Events 4, Turbine Vibration Alarm List

EXHIBIT 4

.*..

Dacku No, 50-311 1

, Mr. SIcvlcrr & MU-F:. ,

ViaePWbtr#lC)ridNuckuCMW

( .

1. Public~I&bctrlcmdCkrCompny P. 0. Bca 236 H u r c o c b ~ N e w m ~a 5,

Deu Mr. U i k i h g a 1.

Subjeu: NRC I Aqmenasd lnrpaction Taun (Am Review of the Nonrnber 9, 1991 $Ilnn Unit 2 Ttubiw-Gmcmw Ovarpabd and Fire Evcnk TlrtATTEIllrcluka~tbc~mrte~ofrhiseur;ntrmrhehtlurtMth~rmr+.b

~ v 8 h m ~ o p a u ~ d ~ t d ~ r a d c t l e d h . l b Asa i n ~ t r i ~ .

-dddldhctb, h f k w i n q r m trip, # u a w u d m i t b c x l tohe

~wbicbwll.wl*--unitcorDvnrpbad. m-eardition d ~ ~ b ~ b l V ~ ~ d ~ l b d h l ~

pmmw, i d d u g 8 byrtcqOan and dl fin. Contributing mum includbd insufRCiart pIcvlanthec ndalcnrna md n v v d l b of tbe rd#rdd vdve-lletuuad turbine corrml an C M h r 220, 1991 that I

a Public Service Electric and Gas Company Within thirty days of reccifl of this letter, please respond to the findings in Section 7.0 of this report rhar are denoted as 'Contributing Causal Factors.' Your response should address an assessment of these items, including any actions t a b or planned. Additionally, pltasc provide the linal results and recurnrnenbtions of the event investigation effort as performed by your own Significant Event Response Team. You will be informed of any NRC enforcement action relative to this matter in scpamtc cornspondem.

In accordance with 10 CFR 2,790 of the NRC's "Ruksof Practice," a copy of this letter and the enclosure will be placed in the NRC Public Document Room. The response directbd by this letter is not subject to the clearance p d u x s of the Offiw of Management and Budget as required by the Paperwork Reduction Acl of 1980, Public Law No. 96-5 11.

We acknowledge and appreciate your excellent cooperation with our AIT during this period.

Charles W. tlehl, Director Division of Reactor Projects

Enclosure:

NKC Region I inspection Report $0-3 1 1/91-81 cc wkncl:

S . LaBruna, Vice Presidtnt, Nuclear Operations

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C. Schaefer. External Operations Nuclear, Dclmama Power & Light Cu.

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C . Vondra, General Manager Salcm Opcmtions F. 'lhcnnson, Manager, Licmsing and Regulation L. Keiter, General Manager - Nuclear Safety Review J. Robb, Director, joint OwMr Affairs A. 'Tapen, Program Administrator K. Fryling, Jr,, Esquire M. Wetttrhahn, Esquire J . Irabclla, Director, Generation Projects Department, Atlantic Electric Company D. Wersan, Assistant Consumer Advocate, Office o f Consumer Advocate lawer Alloways Creek Township K. Abraham, PAO, (24 copies)

Public Document Room (PDR) lllcal Public Documen1 Room (LPDR)

Nuclear May Cnfomahn Center (NSIC)

NRC Rtridcnt L~XXCW Shtc of New Jency

CERTIFICATE OF SERVICE I hereby certify that on May 11, 2007, a copy of Eric Joseph Epstein's Petition for Leave to Intervene, Request for Hearing, and Contentions regarding the matter of the PPL Susquehanna LLC Proposed Amendment Requests for the Susquehanna Steam Electric Station's 1 & 2 Would Increase Thermal Power to 3,952 Mega-Watts Which is 20% Above the Original Rated Thermal Power (RTP) 3293 MWt, And Approximately 13% Above the Current RTP of 3,489 MWt, Docket Nos. 50-387 PLA-6110 and 50-388 was sent via electronic mail and by overnight delivery with tracking numbers to:

Office of the Secretary U.S. Nuclear Regulatory Commission 16th Floor One White Flint North 11555 Rockville Pike, Rockville, Maryland 20852 Attn: Rulemaking and Adjudications Staff Office of the Secretary of the Commission U.S. Nuclear Regulatory Commission Washington, D.C. 20555-0001 Attn: Rulemaking and Adjudications Staff Office of the General Counsel US NRC Washington, DC 20555-0001 David Lewis, Esquire PPL c/o Pillsbury, Winthrop et a1 2300 N. Street, NW Washington, DC 20037 Bryan A. Snapp, Esquire Assoc. General Counsel PPL Services Corporation 2 North 9th Street Allentown, PA 18101-1179

May 11, 2007 Office of the Secretary U.S. Nuclear Regulatory Commission Washington, D.C. 20555-0001 Attn: Rulemaking and Adjudications Staff Office of the Secretary U.S. Nuclear Regulatory Commission 16th Floor One White Flint North 11555 Rockville Pike, Roclzville, Maryland 20852 Attn: Rulemaking and Adjudications Staff Re: PPL Susquehanna LLC Proposed Amendment Requests for the Susquehanna Steam Electric Station's 1 & 2 Would Increase Thermal Power to 3,952 Mega-Watts Which Is 20%Above the Original Rated Thermal Power (RTP) 3,293 MWt, And Approximately 13%Above the Current RTP of 3,489 MWt, Docket Nos. 50-387 PLA-6110 and 50-388

Dear Sir or Madam:

Please find enclosed for filing in the above-stated matter Eric Joseph Epstein's Petition for Leave to Intervene, Request for Hearing, and Contentions in the above-captioned matter.

Thank you for your attention to this matter.

~ a r r i s b u r g , u17112

~~

(717)-54.1-1101 Phone cc: Certificate of Service Exhibits 1, 2, 3 & 4