ML14112A315

Davis-Besse Nuclear Power Station, Unit 1 - Review of Draft Plant-Specific Supplement 52 to the Generic Environmental Impact Statement for License Renewal of Nuclear Plants Regarding

ML14112A315
Person / Time
Site:	Davis Besse
Issue date:	04/21/2014
From:	Lieb R A FirstEnergy Nuclear Operating Co
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
L-14-146, TAC ME4613
Download: ML14112A315 (17)

Text

FENOCc 5501 North State Route 2FirstEnergy Nuclear Operating CompanyRaymond A. Lieb 419-321-7676Vice President, Nuclear Fax: 419-321-7582April 21, 2014L-14-146 10 CFR 54ATTN: Document Control DeskU.S. Nuclear Regulatory CommissionWashington, DC 20555-0001SUBJECT:Davis-Besse Nuclear Power Station, Unit No. 1Docket No. 50-346, License Number NPF-3Review of Draft Plant-Specific Supplement 52 to the Generic Environmental ImpactStatement for License Renewal of Nuclear Plants Regarding Davis-Besse NuclearPower Station, Unit 1 (TAC No. ME4613)By letter dated August 27, 2010 (Agencywide Documents Access and ManagementSystem (ADAMS) Accession No. ML1 02450565), FirstEnergy Nuclear OperatingCompany (FENOC) submitted an application pursuant to Title 10 of the Code of FederalRegulations, Part 54 for renewal of Operating License NPF-3 for the Davis-BesseNuclear Power Station, Unit No. 1 (Davis-Besse). By letter dated February 24, 2014(ML14050A078 (LTR), ML14050A523 (PKG), ML14050A521 (FRN)), the NuclearRegulatory Commission (NRC) issued the Notice of Availability of Draft Plant-SpecificSupplement 52 to the Generic Environmental Impact Statement for License Renewal ofNuclear Plants Regarding Davis-Besse Nuclear Power Station, Unit 1.FENOC has completed its review of Draft Plant-Specific Supplement 52 to the GenericEnvironmental Impact Statement for License Renewal of Nuclear Plants RegardingDavis-Besse Nuclear Power Station, Unit 1. The Enclosure provides FENOC commentson the document.There are no regulatory commitments contained in this letter. If there are any questionsor if additional information is required, please contact Mr. Clifford I. Custer, FleetLicense Renewal Project Manager, at 724-682-7139.Sincerej,aym nd A. Liegb Davis-Besse Nuclear Power Station, Unit No. 1L-14-146Page 2Enclosure:FirstEnergy Nuclear Operating Company (FENOC) Comments Related to DraftPlant-Specific Supplement 52 to the Generic Environmental Impact Statement forLicense Renewal of Nuclear Plants Regarding Davis-Besse Nuclear PowerStation, Unit 1 (DSEIS)cc: Ms. Cindy Bladey, Chief, Rules, Announcements, and Directives BranchNRC DLR Environmental Project ManagerNRC DLR Project ManagerNRC Region III Administratorcc: w/o EnclosureNRC DLR DirectorNRR DORL Project ManagerNRC Resident InspectorUtility Radiological Safety Board

Enclosure

Davis-Besse Nuclear Power Station, Unit No. I (Davis-Besse)Letter L-14-146FirstEnergy Nuclear Operating Company (FENOC) Comments Related toDraft Plant-Specific Supplement 52 to theGeneric Environmental Impact Statement for License Renewal of Nuclear PlantsRegarding Davis-Besse Nuclear Power Station, Unit 1 (DSEIS)14 pages follow FirstEnergy Nuclear Operating Company (FENOC) CommentsRelated to Draft Plant-Specific Supplement 52 to theGeneric Environmental Impact Statement for License Renewal of Nuclear PlantsRegarding Davis-Besse Nuclear Power Station, Unit 1 (DSEIS)L-14-146Page 1 of 14DSEISItem DSEIS Page / CommentNo. Section LnesLine(s)1. General -- Although the DSEIS discusses the revised GElS and theComment related final rule, FENOC believes that the discussionshould be further clarified to confirm that, as applicable toDavis-Besse, the NRC has considered each of theCategory 1 issues in the revised rule and determined thatthere is no new and significant information and theCategory 1 determinations remain valid for Davis-Besseand/or provided a justification for any differences betweenwhat is in the DSEIS versus what is in the revisedGElS/final rule.2. Abstract iii / FENOC notes that the description of the combinationsLines 9-10 alternative on this page does not match the similardescription on page xix, Line 7.3. Executive xv / FENOC suggests changing "Nuclear Power Plant" toSummary Line 5 "Nuclear Power Station".4. Executive xvi / FENOC recommends changing "is" to "are", since theSummary Line 30 topic is "environmental impacts".5. Executive xix The DSEIS concludes that its "preliminarySummary recommendation is that the adverse environmentalimpacts of license renewal for Davis-Besse are not great1.5 enough to deny the option of license renewal for energy-planning decisionmakers." Consistent with 10 CFR§ 51.95(c)(4) and Section 9.4 of the DSEIS, thisconclusion should be revised to read as follows: "theadverse environmental impacts of license renewal arenot so great that preserving the option of licenserenewal for energy planning decision makers wouldbe unreasonable."6. Abbreviations xxii FENOC suggests that the word "million" following MMBtu& Acronyms should be in the right-hand column in front of "Britishthermal unit".

FENOC Comments Related to Draft DSEISL-14-146Page 2 of 14DSEISItem DSEIS SINo. Section Page / CommentLine(s)7. 1.4 1-4 / This background sentence on the 2013 rulemaking statesLines 10-13 that the new Category 1 issues set forth in the revisedGElS and Part 51 rules "include geology and soils,Appendix B B-1 / exposure of terrestrial organisms to radionuclides,last exposure of aquatic organisms to radionuclides, humanparagraph health impact from chemicals, and physical occupationalhazards." A similar statement appears in Appendix B.This list does not appear to be comprehensive. The finalrule (78 Fed. Reg. at 37,283) states: "New Category 1issues were added: geology and soils; effects of dredgingon surface water quality; groundwater use and quality;exposure of terrestrial organisms to radionuclides;exposure of aquatic organisms to radionuclides; effects ofdredging on aquatic organisms; impacts of transmissionline right-of-way management on aquatic resources;employment and income; tax revenues; human healthimpacts from chemicals; and physical occupationalhazards." and "Several issues were changed fromCategory 2 to Category 1: Offsite land use, air quality,public services (several issues), and population andhousing."FENOC requests that the DSEIS be revised to add all ofthe new Category 1 issues to this background sentence orto specifically clarify that this sentence is not intended tobe comprehensive or to match the scope of new issuesevaluated in the DSEIS.Relatedly, and as proposed below regarding thesubstantive evaluations in Chapters 3 and 4, FENOCwants to ensure that all new Category 1 issues are fullyand clearly addressed, or a justification be included forthose not otherwise addressed in the DSEIS.

FENOC Comments Related to Draft DSEISL-1 4-146Page 3 of 14Item DSEIS DSEISNo. Section Page / CommentLine(s)8. 1.4 1-4 / This background sentence on the 2013 rulemaking statesLines 13-15 that "Radionuclides released to groundwater, effects onterrestrial resources (non-cooling system impacts),Appendix B B-1 / minority and low-income populations (i.e., environmentallast justice), and cumulative impacts were added as newparagraph Category 2 issues."This list appears to be inconsistent with the final rule (78Fed. Reg. at 37,283), which states: "New Category 2issues were added: Radionuclides released togroundwater, water use conflicts with terrestrialresources, water use conflicts with aquatic resources, andcumulative impacts." and "One uncharacterized issue wasreclassified as Category 2: Environmental justice/minorityand low-income populations."FENOC requests that the DSEIS be revised to include allof the new Category 2 issues to this background sentenceor to specifically clarify that this sentence is not intendedto be comprehensive.9. 1.4 1-4/ This paragraph discusses the effectiveness of the finalLines 16-22 rule with regard to the new or revised Category 1 and 2issues, and explains that the NRC must consider them.FENOC recommends that the NRC add a brief discussionproviding additional details, explaining how the NRCconsidered the Category 1 and 2 issues.10. 1.5 1-6 / Similar to Comment 5, above, the sentence should beLines 6-7 revised to read as follows: "... Commission that theadverse environmental impacts of license renewal arenot so great that preserving the option of licenserenewal for energy planning decision makers wouldbe unreasonable."11. 1.10 1-9/ FENOC suggests changing "Accession Nos." to theLine 5 singular "Accession No.".12.2.02-1 /Lines 2 & 5FENOC suggests removing the extra spaces (25 mi) (40km) (2500 m) in lines 2 & 5. Also, the statement"[a]pproximately 700 ac (300 ha) are marshland..." is theonly location in the DSEIS where 700 ac is used;elsewhere, the statement "approximately 733 ac" is usedmultiple times. Recommend using "approximately 733 ac"throughout the DSEIS.

FENOC Comments Related to Draft DSEISL-1 4-146Page 4 of 14DSEISItem DSEIS PaeICNo. Section Page / CommentLine(s)13. 2.1 2-1 / FENOC recommends the use of 908 megawatts-electricLine 19, (MWe) instead of 913 MWe in the DSEIS, to be consistentwith the License Renewal Application and Environmental2.1.1 2-6 / Report. The reference cited on page 2-6, Line 11 (i.e.,Line 9 FENOC 201 Oc), is the License Renewal Application,which lists electrical output as "908 MWe". Also, 908 MWeis used later in the DSEIS for the comparison ofAlternatives.14. 2.1.1 2-6 / The sentence states that each primary coolant loopLine 17 contains one reactor coolant pump, but Davis-Besse hastwo reactor coolant pumps per loop. FENOC recommendschanging Line 17 from "... one reactor coolant pump," to"... one or two (depending on the plant design)reactor coolant pumps,".15. 2.1.2.3 2-10 / FENOC suggests revising the 3 cited references (FENOCLines 12, 17 2011) on this page to be consistent with the references& 27 Section 2.4, which lists the references as FENOC 2011 a,2011b, or 2011c.2-11/ Same comment for page 2-11, line 26 (FENOC 2010),Line 26 which has no alpha character (a, b, c or d) following theyear.16. 2.2.1 2-18/ The Magee Marsh Wildlife Area entrance is approximatelyLine 19 6 miles west of the station. Lake Erie is east of the station.FENOC recommends revising Line 19 to read, "TheNavarre Marsh partially surrounds the station to the north,east and southeast."17. 2.2.2.1 2-21 / Regarding the sentence, "Davis-Besse has many sourcesLine 15 of criteria pollutants and HAPs to include the followincq:",FENOC recommends changing the sentence to read:"The Davis-Besse sources of criteria pollutants andHAPS are as follows:" As currently written, the sentencesuggests there are more sources than those listed.18. 2.2.2.1 2-21 / FENOC requests that, at the beginning of the sentence atLine 44 the end of the Line, NRC consider adding "However," infront of "In 1992, Davis-Besse..." to make it clear that theprevious discussion of fires and the chemicals releasedduring transformer fires didn't apply in this case.19. 2.2.4 2-27 / FENOC recommends changing "Augqust 14, 2006" toLine 12 "July 1. 2011" to align with the new permit date and thesuggested update to Appendix C, below.

FENOC Comments Related to Draft DSEISL-14-146Page 5 of 14Item DSEIS DSEISNo. Section Page I CommentLine(s)20. 2.2.4 2-28 / FENOC recommends deleting "asbestos", because theLine 23 updated permit does not require monitoring for asbestos.21. 2.2.4 2-28 / FENOC recommends changing or deleting the referenceLine 25 source cited (Brown 2010) since there is nocorresponding reference citation in the references list inSection 2.4.22. 2.2.4 2-29 / FENOC recommends changing "2006" to "2011" to alignLine 7 with the new permit date, a previous comment and thesuggested update to Appendix C, below.23. 2.2.4 2-29 / The use of the terms "violate" with respect to NPDESLines 16-18 requirements and "NOV" (Notice of Violation issued by aregulator e.g., OEPA) are confusing when usedinterchangeably in the first two sentences. Thestatements need to be clear that site personnel mayindicate an action, lack of action, or parameter may haveexceeded ("violated") permit requirements, but there wereno formal NOVs issued for the cases described whereFENOC exceeded permit requirements for a period oftime. FENOC recommends changing "NOV" on line 17 to"violations".24. 2.2.4 2-29 / The change has been submitted and approved, and zincLines 26-27 acetate is being used, so FENOC recommends revisingthe last sentence to be past tense.25. 2.2.5 2-31 / FENOC recommends changing the sentence to read,Line 4 "...December 2010 at monitoring wells 30S...".26. 2.2.5 2-33 / FENOC recommends changing "Ce-1 37" to "Cs-1 37" andLines 13-14 "Ce-i134" to "Cs-134".Also, the cited reference (NRC 1991) is not included inthe list of references in Section 2.4, page 2-87.27. 2.2.5 2-33 / FENOC recommends changing "sodium hydroxide" toLine 30 "sodium hypochlorite".28. 2.2.8.3 2-49 / FENOC suggests that the reference to "Table 2.3-8" inLine 13 this line should instead be "Table 2.2-8."29. 2.2.8.4 2-52 / FENOC suggests that the reference to "Section 2.2.6" inLine 6 this line should instead be "Section 2.2.7.2."30. 2.2.9.2 2-59 / FENOC suggests underlining and separating the headingLine 10 "Transportation" in a manner similar to the formatting ofthe previous heading "Education".

FENOC Comments Related to Draft DSEISL-1 4-146Page 6 of 14Item DSEIS DSEISNo. Section Page / CommentLine(s)31. 2.2.9.5 2-60 / A space is needed between the first two words in the line.Line 4232. 2.2.9.5 2-65 / The word "temporary" is missing the letter "t".Line 1133. 2.2.9.6 2-67 / There is an errant comma following the word "of'.Line 1234. 2.2.10.1 2-69 / FENOC recommends rewording the following sentence asLines 21-22 shown: "One documented fluted projectile point is6leeatedwas discovered at the Peters site in Ottawa County,south of Davis-Besse along the Portage River wasdie6eered (Prufer and Shane 1973)."35. 2.2.10.1 2-71 / FENOC recommends changing "north" to "northwest",Line 23 because the Maumee River runs from the southwest tothe northwest of Davis-Besse.36. 2.2.10.2 2-72 / The Magee Marsh is approximately 6 miles west of Davis-Line 40 Besse. FENOC recommends adding a period after"...agricultural purposes" and deleting the remainder ofthe sentence.37. 2.4 2-74 Many of the titles for the Code of Federal Regulationsto 2-76 / citations are incorrect or duplicated. Examples includel0various CFR Part 60, Part 70, 15 CFR Part 930 has multipleLines citations bundled together, 40 CFR Part 80, 40 CFR Part239, etc. FENOC recommends verifying the titles forthese citations in this section and in the other referencessections of the DSEIS.38. 2.4 2-79 FENOC suggests that the title of this document referenceLine 24 should read, "Loggerhead Shrike: First Ever Captured...".39. 2.4 2-82 FENOC recommends deleting the "(2010b)" at the end ofLine 37 the reference to be consistent with the other FENOC 2010citations.40. 2.4 2-83 / This FENOC 2011 citation appears to be out ofLines 15-19 chronological order and should be located between linesand Line 20 11 and 12.On line 20, [FENCOl should read [FENOC].

FENOC Comments Related to Draft DSEISL-1 4-146Page 7 of 14Item DSEIS DSEISNo. Section Page / CommentLine(s)41. Chapters All Although these substantive chapters evaluating the3 & 4 environmental impacts of refurbishment and operationappear to address most of the new issues in the June 20,2013 final rule that revised Table B-i, it is not clearwhether each individual issue has been addressed.For example, it does not appear to be clearly statedwhether the following Category 1 issues are applicable toDavis-Besse and, if so, how they are addressed: effectsof dredging on surface water quality, groundwater qualitydegradation resulting from water withdrawals, effects ofdredging on aquatic organisms, and impacts oftransmission line ROW management on aquaticresources.Therefore, FENOC recommends that the NRC include adiscussion in this chapter, or elsewhere in the SEIS, toprovide an explanation of how the Category 1 issues inthe new final rule have been addressed, or, in thealternative, to provide a justification for any differencesbetween what is in the DSEIS versus what is in therevised GElS/final rule.42. 3.1 3-3 / There are numerous references in Chapters 3 & 4 toLines 5 & 6 replacement of the steam generators and that theseactivities "will be performed during an extended outagescheduled for the spring of 2014" (e.g., Pg 3-3, lines 17-20). At the time of this review, both steam generatorshave been replaced and the 2014 refueling outage isnearing completion. Consider changing the tense forsteam generator replacement to past tense, althoughFENOC realizes that this change would impact manypages and sections of the DSEIS.43. 3.2.1 3-4 / FENOC is an entity. FENOC recommends changing theLine 33 sentence from "FENOC noted in their ER that..." to"FENOC noted in its ER that...". This issue appears inmultiple locations (at least 8 instances) in the DSEIS (seeChapter 4 for more examples).3-5 / Similarly, FENOC recommends changing the statement inLine 1 Line 1 on the next page from "FENOC's proceduresrequire them to coordinate with the FWS..." to "FENOC'sprocedures require coordination with the FWS..."44. 3.2.8 3-9 / FENOC recommends changing "EnvironmentalLine 7 Procedure" to "Environmental Evaluations procedure" tomatch the title of the procedure.

FENOC Comments Related to Draft DSEISL-1 4-146Page 8 of 14Item DSEIS DSEISNo. Section Page I CommentLine(s)45. 4.7.3 4-8 / FENOC recommends deleting one of the uses of the word[No line "vicinity" in the 2nd paragraph, 1st sentence.numbers]46. 4.9.1 4-13 / The first sentence begins with an errant period.[No linenumbers]47. 4.14 4-30 & FENOC requests that the DSEIS be revised to include an4-31 affirmative statement in this section clarifying that theNRC has reviewed the Category 1 issues in Table B-i, asrevised in the June 20, 2013 final rule, and hasdetermined that, to the extent such topics are applicableto Davis-Besse, there is no new and significantinformation, and therefore the Category 1 designations forthese issues remain correct and the small impactdesignations in Table B-1 remain correct. Alternatively,the SEIS should provide a justification for any differencesbetween what is in the DSEIS versus what is in therevised GElS/final rule.48. Table 4-32 & 4-33 At the bottom of page 4-32, the first project listed under4.15-1 "Energy Projects" is the 'Independent Spent Fuel StorageInstallation on Davis-Besse site; dry spent-fuel storage'. Itis not clear why the Status discusses Spent Fuel Pool andtransfer pit storage versus the dry fuel storage pad andcurrent dry fuel storage capability.On page 4-33, the 3rd PROJECT/ACTION listed (ToledoRefinery Substation Project), the LOCATION descriptionends abruptly... "Oregon, Ohio, near the intersection of'.49. 4.15.5.2 4-43 / The sentence at the end of the second paragraph in thisLine 20 section is not complete and has no period.

FENOC Comments Related to Draft DSEISL-1 4-146Page 9 of 14Item DSEIS DSEISNo. Section Page / CommentLine(s)50. 5.3.1 5-3 / In response to NRC requests for additional informationLines (RAIs), the total number of SAMAs was changed from 16723 & 33 to 168, and the number of SAMAs eliminated based onscreening was changed from 152 to 153. (see ADAMS5.3.3 5-6 / Accession No. ML1 11 80A233 [FENOC Letter L-1 1-154Lines 12, 21 dated June 24, 2011], RAI 5.c).This comment also applies to Appendix F, Section F.1F. 1 F-1 / (page F-1). However, since this Appendix is writtenLine 18 chronologically, FENOC recommends adding thefollowing bullet to page F-2 under the list of FENOCF-2 / provided information via letter dated June 24, 2011:Lines 4-23 -identification of a new SAMA candidate (OT-9R),which changed the total number of SAMA candidatesevaluated to 168 instead of the original 167.51. 5.3.1 5-3 / FENOC suggests adding the text in bold/underline: "In theLines 35-36 third step, FENOC estimated the benefits and the costsassociated with each of the 15 candidate SAMAs."52. 5.3.2 5-4 / The text states: "Column totals in Table 5.3-2 may differLine 29 due to round off." The table reference appears to beincorrect. The correct reference is Table 5.3-1.53. 5.3.2 5-5 / FENOC recommends clarifying the following two initiatingTable 5.3-1 event descriptions:From:"Flooding in CCW pump room"F.2.1 F-4 /Table F-1 To:"Flooding in CCW pump room from SW" [or, ServiceWater]and, From:"Flooding in turbine building"To:"Flooding in turbine building from Circ water"Also, consider noting that the % contribution to CDFvalues are slightly different from those reported in FENOCEnvironmental Report Table E.3-1 due to rounding.Comment also applies to Appendix F, Section F.2.1,Table F-I.

FENOC Comments Related to Draft DSEISL-1 4-146Page 10 of 14Item DSEIS DSEISNo. Section Page / CommentLine(s)54. 5.3.2 5-5 / FENOC recommends that the Population Dose andTable 5.3-2 % Contribution be updated to match those included inFENOC Letter L-12-244 dated July 16, 2012 (see TableF.2.1 F-5I E.3-21).Table F-2 Comment also applies to Appendix F, Section F.2.1,Table F-2.55. 5.3.5 5-7 / Suggest adding the text in bold/underline: "FENOC'sLines 13-14 derivation of each of the associated costs is summarizedin Appendix E of the ER."56. 6.2.1.2 6-5 / The DSEIS states that the various studies it reviewedLines 19-21 show that "the relatively lower order of magnitude of GHGemissions from nuclear power, when compared to fossil-fueled alternatives (especially natural gas), couldpotentially disappear if available uranium ore grades dropsufficiently.. ." (Emphasis added.) This statement isspeculative, apparently based on worst-caseassumptions, and a review of the data presented in Table6.2-2 reveals it to be unsupported. See, e.g., POST(2006) (referenced and described in Table 6.2-2). FENOCrecommends deleting this sentence.57. 6.2.2 6-8 / The DSEIS states that "[flew studies predict that nuclearLines 39-40 fuel cycle emissions will exceed those of fossil fuels withina timeframe that includes the Davis-Besse period ofextended operation." But none of the studies cited inTable 6.2-2 appear to support this thesis-at least basedon the data presented. Therefore, FENOC suggestsrevising this sentence to state: "Nearly all studiespredict that nuclear fuel cycle emissions will remainan order of magnitude or more below those of alltypes of fossil fuels during the Davis-Besse period ofextended operation."58. 6.2.2 6-9 / The DSEIS concludes that "it is likely that GHG emissionsLines 8-9 from renewable energy sources would be lower thanthose associated with Davis-Besse at some point duringthe period of extended operation." This conclusionappears to be unsupported by the data presented in Table6.2-3. FENOC suggests revising this sentence to statethat "most of the relevant studies show that it is likelythat GHG emissions associated with Davis-Besse willremain comparable to or below those from renewableenergy sources throughout the period of extendedoperation."

FENOC Comments Related to Draft DSEISL-14-146Page 11 of 14Item DSEIS OSEISNo. Section Page / CommentLine(s)59. 8.0 8-3 / FENOC recommends changing "... FENOC ServiceLine 30 Company's..." to "... FirstEnergy Service Company's...."60. 8.1 8-6 / The conclusion that the air quality impacts of new naturalTable 8.1-1 gas combined cycle generation would be SMALL toMODERATE appears inappropriate, in that it blurs thesignificant difference between emissions from Davis-Besse and natural gas sources. See Table 6.2-2 (page6-6). FENOC suggests that if the impacts from Davis-Besse are SMALL, then the impacts from natural gasfacilities should logically be at least MODERATE,consistent with the Davis-Besse Environmental Report.61. 8.1.5.1 8-12/ FENOC suggests revising the acronym "GGNS" to readLine 17 "Davis-Besse".62. 11.0 11-4 FENOC recommends changing the name "Nesser" toAppendix A A-4 & A-1 73 "Nusser" in 3 locations. Nusser is the correct spellingaccording to the signature on the email included as pageA-173.63. Appendix C C-5 / Storage of spent nuclear fuel & high-level radioactiveTable C-2 waste:STATUS -The word Expired should read "Expires".64. Appendix C C-5 / Permit to operate an air containment source:Table C-2 STATUS -should read as follows:Operation of station auxiliary boilerFacility ID#: 0362000091Permit#: P0110436Issued: 02/28/2013Expires: 02/28/202365. Appendix C C-5 & C-6 / NPDES Permit -Treatment of wastewater and effluentTable C-2 discharge to surface receiving waters (Toussaint Riverand Lake Erie):STATUS -the Ohio Permit No. should read21B0001 1*JDIssued: 07/01/2011Expires: 04/3012016 FENOC Comments Related to Draft DSEISL-14-146Page 12 of 14Item DSEIS DSEISNo. Section Page / CommentLine(s)66. Appendix C C-6 / Hazardous material registration:Table C-2 STATUS -should read as follows:Transportation of hazardous materialsPermit Number: 052112 020 004UWIssued: 05/22/2012Expires: 06/30/2015(Renewed Triennially)67. Appendix C C-6 / License to deliver radioactive waste:Table C-2 STATUS -should read as follows:Shipment of radioactive material to a licensed disposal-processing facility within the State of TennesseeTennessee Delivery License# T-0H003-L14Issued: AnnuallyExpires: 12/31/201468. Appendix C C-6 / New Row:Table C-2 License to deliver radioactive waste:AGENCY -should read as follows:South Carolina Department of Health andEnvironmental ControlAUTHORITY -should read as follows:South Carolina Radioactive Waste Transportation andDisposal Act No. 429 of 1980STATUS -should read as follows:Shipment of radioactive material to a licenseddisposal-processing facility within the State of SouthCarolinaPermit #: 0054-34-14Issued: 12/10/2013Expires: 12/31/2014 FENOC Comments Related to Draft DSEISL-14-146Page 13 of 14Item DSEIS DSEISNo. Section Page / CommentLine(s)69. Appendix C C-6 / Underground storage tank registration:Table C-2 STATUS -should read as follows:Gerifirate Facility # 62000072Expires: 06/30/201470. Appendix C C-7 / X-ray generating equipment registration:Table C-2 STATUS -should read as follows:Expires: 05/31/201471. Appendix C C-7 / Scientific Collection Permit:Table C-2 STATUS -should read as follows:Permit #: 15-112Issued: 03/16/2014Expires: 03/15/201572. Appendix E E-8 The following FENOC letter is missing from the list ofcorrespondence:Letter L-12-244 from John C. Dominy, Davis-BesseNuclear Power Station, Unit 1. Docket No. 50-346,License Number NPF-3, Correction of Errors in the Davis-Besse Nuclear Power Station. Unit No.1, LicenseRenewal Application (TAC No. ME4613) EnvironmentalReport Severe Accident Mitigation Alternatives Analysis,and License Renewal Application Amendment No. 29(dated July 16, 2012)FENOC notes that this same correspondence is listed inAppendix F, Section F.8 (References), page F-36, Lines34-38 (FENOC 2012a). However, the ML number listed inAppendix F is a duplicate of the ML number for FENOCletter dated June 24, 2011. Also, FENOC was not able tofind the document in ADAMS using various search terms(may not be available to the public).73. F.2.2 F-12 / FENOC suggests inserting the word "are" as follows: "TheLine 7 Level 1 core damage sequences are grouped into coredamage bins according to similarities in their impact oncontainment response."

FENOC Comments Related to Draft DSEISL-14-146Page 14 of 14DSEISItem DSEIS SINo. Section Page / CommentLine(s)74. F.2.2 F-14 / FENOC suggests editing the quoted sentence as follows:Lines 14-17 "Data from 2006 through 2008 was were considered, butthe 2006 data was were chosen because it-was theywere the most complete data set. Data from year 2008was-were considered unusable as it they contained toomany missing long data-sequences of unusable data."75. F.2.2 F-14 / FENOC suggests adding to the following sentence theLines 39-40 language in bold/underline: "In response to an NRC staffRAI, FENOC revised the Level 3 PRA to include thatportion of the Canadian population located within the50-mi radius SAMA analysis region (FENOC 2011)."76. F.3.1 F-17 / Same issue as Comment 49 [5.3.1]. Specifically, the totalLine 34 number of SAMAs was changed from 167 to 168, and thenumber of SAMAs eliminated based on screening wasF.7 F-35 / changed from 152 to 153.Lines However, since Appendix F is written chronologically,18 & 19 FENOC recommends adding the following sentence afterline 6 on page F-18 and after line 19 on page F-35:In response to NRC RAIs, FENOC's initial list of 167SAMA candidates was increased to 168, of which 153were eliminated based on screening.77. F.3.2 F-21 / FENOC suggests editing the quoted sentence as follows:Line 30 "In response to the RAIs, FENOC addressed thesuggested lower cost alternatives and determined thatthey were eitheF-already implemented at Davis-Besse (b),not feasible (c), or not cost-beneficial (a, d, e, and f)(FENOC 2011)."78. F.5 F-27 / The word "applicant's" should be "applicants'."Line 27