ML12271A423

Callaway, Unit 1, Responses to Environmental RAI Set #1 to the Callaway LRA

ML12271A423
Person / Time
Site:	Callaway
Issue date:	08/13/2012
From:	Kanuckel L H Ameren Missouri
To:	Office of Nuclear Reactor Regulation, Document Control Desk
References
ULNRC-05893, TAC ME7715, TAC ME7716
Download: ML12271A423 (29)

Text

wAmerenMISSOURICallaway PlantAugust 13, 2012ULNRC-05893U.S. Nuclear Regulatory CommissionAttn: Document Control DeskWashington, DC 20555-000110 CFR 2.10110 CFR 2.109(b)10 CFR 50.410 CFR 50.3010 CFR 51.53(c)10 CFR 54Ladies and Gentlemen:DOCKET NUMBER 50-483CALLAWAY PLANT UNIT 1UNION ELECTRIC CO.FACILITY OPERATING LICENSE NPF-30RESPONSES TO ENVIRONMENTAL RAI SET #1 TO THE CALLAWAY LRAReferences:1) ULNRC-05830 dated December 15, 20112) NRC Letter, "Request For Additional Information for the Review ofthe Callaway Plant, Unit 1 License Renewal Application (TAC No.ME7715 AND ME7716)," dated July 12, 2012.By the Reference 1 letter, Union Electric Company (Ameren Missouri) submitted a license renewalapplication (LRA) for Callaway Plant Unit 1. Reference 2 dated July 12, 2012 transmitted the firstRequest for Additional Information (RAI) related to the environmental portion our application.Enclosure 1 contains Ameren Missouri's responses to the individual requests contained in the July 12,2012 RAIs. Attachment 1 contains a listing of Enclosures 2 through 46 which are provided on theaccompanying DVD.If you have any questions with regard to these RAI responses, or Amendments 4 and 5, please contactme at (573) 823-9286 or Ms. Sarah Kovaleski at (314) 225-1134....................................................................................PO Box 620 Fulton, MO 65251ArnerenMissouri.corn ULNRC-05893August 13, 2012Page 2I declare under penalty of perjury that the foregoing is true and correct.Sincerely,Executed on: AtAQus+ 13,7 012J

• ILes H. KanuckelManager, Engineering DesignDS/SGK/nlsEnclosures: 1) Request for Additional Information (RAI) E-RAI Set #1 ResponsesAttachment: 1) List of Enclosures 2 through 462 through 46) DVD provided to Document Control Desk and Project Manager only -byovernight mail ULNRC-05893August 13, 2012Page 3cc: U.S. Nuclear Regulatory Commission (Original)Attn: Document Control DeskWashington, DC 20555-0001Mr. Elmo E. CollinsRegional AdministratorU. S. Nuclear Regulatory CommissionRegion IV1600 East Lamar BoulevardArlington, TX 76011-4511Senior Resident InspectorCallaway Resident OfficeU.S. Nuclear Regulatory Commission8201 NRC RoadSteedman, MO 65077Ms. Carmen FellsProject ManagerOffice of Nuclear Reactor RegulationU. S. Nuclear Regulatory CommissionMail Stop 0-1 IF1Washington, DC 20555-0001Mr. Samuel Cuadrado De JesdisProject Branch 1Division of License RenewalOffice of Nuclear Reactor RegulationU.S. Nuclear Regulatory CommissionMail Stop 0-1 IFIWashington, DC 20555Mr. Fred LyonSenior Project Manager, Callaway PlantOffice of Nuclear Reactor RegulationU. S. Nuclear Regulatory CommissionMail Stop O-8G14Washington, DC 20555-2738Mr. Gregory A. PickU. S. Nuclear Regulatory CommissionRegion IV1600 East Lamar BoulevardArlington, TX 76011-4511 ULNRC-05893August 13, 2012Page 4Index and send hardcopy to QA File A160.0761Hardcopy:Certrec Corporation4150 International Plaza Suite 820Fort Worth, TX 76109(Certrec receives ALL attachments as long as they are non-safeguards and may be publicly disclosed.)Electronic distribution for the following can be made via Tech Spec ULNRC Distribution:A. C. HeflinF. M. DiyaC. 0. Reasoner IIID. W. NetererL. H. GraessleJ. S. GeyerS. A. MaglioR. Holmes-BoboNSRB SecretaryL. H. KanuckelS. G. KovaleskiT. B. ElwoodG. G. YatesE. Blocher (STARS PAM COB)Mr. Bill Muilenburg (WCNOC)Mr. Tim Hope (Luminant Power)Mr. Ron Barnes (APS)Mr. Tom Baldwin (PG&E)Mr. Mike Murray (STPNOC)Ms. Linda Conklin (SCE)Mr. John ONeill (Pillsbury Winthrop Shaw Pittman LLP)Missouri Public Service CommissionMr. Dru Buntin (DNR)

Page 1 of 23Enclosure 1to ULNRC-05893Aquatic Ecology1. Provide a copy of the review of new and significant information document or describe whatspecific records or information Ameren Missouri (Ameren) reviewed to determine that nonew and significant information exists for each of the aquatic ecology Category 1 issuesapplicable to Callaway Plant, Unit 1 (Callaway).Callaway Response:Ameren's New and Significant Information Report, describes the process that Ameren usedto determine if any of the 92 issues identified in 10 CFR 51, Appendix B (including Category1 issues) that are applicable to Callaway fall into either of these two categories:a. Information that identifies a significant environmental issue not covered in the GElS(NUREG 1437) and codified in the regulation (10 CFR 51, Appendix B)b. Information that was not covered in the GElS analyses and which leads to an impactfinding different from that codified in the regulation.In Chapter 5 of Ameren's Environmental Report, the following conclusion is reported:Ameren is not aware of any new and significant information regarding the plant'senvironment or operations that would make any generic conclusion codified by theNRC for Category 1 issues not applicable to Callaway Unit 1, that would alterregulatory or GElS statements regarding Category 2 issues, or that would suggestany other measure of license renewal environmental impact.Ameren's New and Significant Information Report, without Appendix B (which containspersonal information on individuals who were interviewed), is provided as Enclosure 2.Appendix B contains documentation of the aquatic ecology interviews and was madeavailable for NRC staff review during the environmental audit.2. Clarify the location of the discharge point for blow-down water and other waste streams tothe Missouri River.Callaway Response:The Callaway discharge point for blow-down can be found in Ameren's EnvironmentalReport as Figure 3.1-2. Other waste streams are combined with the cooling towerblowdown near the power block and are discharged to the Missouri River at a singlelocation.3. Provide copies of or, if copies are not available, descriptions of pre-operational surveys offish conducted in 2007 and 2008 within reach of the Missouri River adjacent to Callaway'scooling water intake mentioned on page 20, plus any associated reports or documentation.Callaway Response:Documentation describing the pre-operational surveys of fish conducted in 2007 and 2009within reach of the Missouri River adjacent to Callaway's cooling water intake is available asSection 2.4 of the AmerenUE Callaway Plant Unit 2 COLA (Environmental Report), Rev. 1 Page 2 of 23Enclosure 1to ULNRC-05893(ML090710389). Descriptions of the methodologies used to conduct the surveys arecontained in the MACTEC Standard Operation Procedures (SOP) for the Callaway NuclearPlant Unit 2 Siting Study, Natural Resources Field Sampling and Analysis, and are providedas Enclosure 3.4. Provide any associated reports or documentation related to the historical records andcontacts with State and Federal resource agencies related to the occurrence of State andFederally listed threatened and endangered species.Callaway Response:Ameren reviewed Missouri Department of Conservation (MDC) and U.S. Fish and WildlifeService (USFWS) records (county lists of occurrences) relative to listed species in theproject area and reported this information in Ameren's Environmental Report. Ameren alsowrote the MDC and USFWS seeking information on potentially affected (state and federallylisted) species, and provided names of five protected or sensitive mussel species believedto occur in the project area. The USFWS responded with a "no effect" determination anddid not provide any information on the five mussel species or any species. The MDCprovided a list of sensitive mussel species believed to occur in waterbodies in or adjacent toproject-related transmission corridors. These agency responses are in Appendix C ofAmeren's Environmental Report.5. Provide a description of the cooling water intake system, including the intake velocity at thetraveling screens, design and operation of the traveling screens, and any other operationalprocedures or structural designs that affect impingement and entrainment at the CallawayPump Station on the Missouri River. Also provide information regarding the depth of theintake and the means by which flow is regulated for the flow intake structure.Callaway Response:The "Callaway NPDES Flow Diagram" contains a description of the cooling water intakesystem and is included as Enclosure 4.Intake velocity at the traveling screen at a normal flow of 9000gpm and a normal water levelof 16' of water in the pump bay was calculated to be 0.307 fps. The highest theoreticalvelocity of 0.595 fps was based on maximum pump flow and low river level.The Callaway intake structure has many structural designs to minimize impingement andentrainment. The size of the intake structure has been increased beyond the requireddesign in order to reduce the velocities of intake water through the screens. The intake hasbeen located so it protrudes into the main river channel, and water is withdrawn from areaslocated away from shallow and slower moving water where the largest populations ofaquatic organisms would be expected to occur. Water withdrawal by the intake occurs fromthe depths of the main channel where few organisms inhabit, giving buoyant or semibuoyantorganisms a lesser chance of entrainment. Additionally, the face of the intake has beenaligned parallel to the river flow ensuring water is withdrawn perpendicular to the flow of theriver. Thus, river currents tend to sweep river organisms past the intake structure. Thisinformation is documented in the Union Electric Company 1986 report "Evaluation ofCooling Water Intake Impacts on the Missouri River," and is included as Enclosure 5.

Page 3 of 23Enclosure Ito ULNRC-05893A traveling screen is provided in each pump bay to remove small debris. The screen meshsize is 1/8 inch, and the screen is made up of sections of screen linked together in acontinuous chain-like arrangement.The traveling screens can be operated manually or automatically via a signal from a timerevery 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> and rotate for 30 minutes or a signal generated by differential pressure (DP)across the screen indicating sediment buildup on the screen. The traveling screen washstarts automatically in slow speed at 6" DP and shift to fast speed at 18" DP across thescreen. A high screen DP of 48" will cause the intake pump to trip. In automatic (screenwash on), the associated screen wash header pressure must be >100 psig for the travelingscreen to rotate. This ensures debris is washed off of the screen and not carried over to thepump side of the screen.The operating deck elevation of the intake structure is at 561.5 feet above mean sea level(MSL) and the pump bays are at 482 feet MSL. Flow is regulated by adjusting backpressurewith a sleeve valve.6. Provide a description of the fish escape openings at the water intake structure and anexplanation of why a fish return system is not required. Also provide copies of any studies ordocumentation of the effectiveness of this mitigation system.Callaway Response:Incoming water initially passes through a set of vertical trash racks designed to stop largeobjects and debris from entering the intake structure. The trash racks are constructed of 0.5inch bars and allow only objects smaller than 0.5 in2 to enter the intake. Intake stop gatesare located between the trash racks and the traveling screens to provide intake bay isolationfor maintenance. The intake structure is constructed with fish escape openings, similar tothe stop gates, in the side walls of the pump bays. These openings are directly in front ofthe traveling screens. The fish escape openings are 3 feet wide and 10 feet high, toping at496 feet MSL.Each intake pump's stop and fish gates are normally open when the intake pump isoperating. The gate positions are reversed when an intake pump is stopped. Intake pumpsA and B include similar circuits. However, to open the B fish gate, stop gates B and C mustbe open; to open the A fish gate, stop gates A and B must be open. These configurationsprevent fish from being trapped in the bays.The Callaway intake structure's location was selected so that the effects on the fishpopulation would be minimal. Water withdrawal occurs from the depths of the main channelwhere fish inhabitation is minimal. Feeding, spawning and nursery areas for fish are limitedin the area of the intake structure. Fish involvement with the intake basically entails fishmigrating around the structure. The low impingement rates indicate that the intake structurewas located and designed to minimize impingement since fish do not reside in the area ofintake. A fish return system in not required based on the design and placement of the intakestructure and the low impingement rate. Supporting information can be found in the UnionElectric Company 1986 report "Evaluation of Cooling Water Intake Impacts on the MissouriRiver," and is included as Enclosure 5.

Page 4 of 23Enclosure 1to ULNRC-058937. Provide a description of what chemicals are used and the associated application rates andschedules to treat the cooling and auxiliary water system.Callaway Response:The cooling and auxiliary water system includes the Intake, Water Treatment Plant, andCirculating and Service Water Systems. Chemicals used to treat the system include amolluscicide, bleach, coagulant aid, cationic polymer, sodium bromine, copolymer,hydroxyethylidine diphosphonic acid (HEDP), pyrophosphate, sodium tolytriazole,biopenetrant, and sulfuric acid. These chemicals are administered as follows:Intake:Molluscicide: Molluscicide is added one or two times per year at the intake during thespawning season. 8 gallons are added to each of three bays while the bay is isolated.Water Treatment Plant:Molluscicide: Molluscicide is added once every 3 weeks when river temperature exceeds600 F in the spring and ending in June when spawning season is over. Treatment resumesin the fall starting in September. This usually amounts to four treatments in the spring andfour in the fall. Each of the four treatments uses 55 gallons and is scheduled approximatelythree weeks apart. Each seasonal treatment uses approximately 250 gallons ofmolluscicide, which is added to the water treatment plant clearwellBleach: Sodium hypochlorite (12%) is added at the water treatment plant during the summermonths once river temperature exceeds 600 F. Bleach addition is halted when the river tempdrops below 600 F. 200 gallons per clarifier per week are added. In 2011, the total additionwas 11,100 gallons, added between June and October. Ameren plans to use triazine as anon-oxidizing biocide for algae control starting in the summer of 2013. When this change isimplemented, 5 gallons of triazine and 100 gallons of bleach will be added per clarifier onceper week during the summer months.Coagulant aid: When needed, coagulant aid is added in December, January and February ifriver temperatures fall below 40' F. The coagulant is added at the water treatment plantstilling basin at a daily rate of 20 -30 gallons.Polymer: Cationic polymer (DMDAAC) (DADMAC) is added at the sleeve valves in the watertreatment plant for water clarification. In 2011, the average addition rate was 1629gallons/month or approximately 20,000 gallons/yearCirculating/Service Water System:Bleach: Sodium hypochlorite (12%) is added to the circulating and service water systemsdaily for 15 minutes to service water, 30 minutes to 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> to the circulating water (moreduring warm weather). If there is evidence of condenser tube fouling the amount may beincreased for a "shock" treatment. The addition amount varies greatly between summer andwinter, averaging approximately 6000 gallons per month. The 2011 total bleach addition tothe circulating and service water systems was 67,733 gallons.Bromine: Sodium bromine (40%) is added in conjunction with bleach to the circulating andservice water systems as a daily addition. More bromine is added during warm weather.

Page 5 of 23Enclosure 1to ULNRC-05893Bromine usage averages about 1350 gallons per month. The total for 2011 was 16,275gallons.Copolymer: Copolymer is added to the circulating and service water systems to keep solidsin suspension. This prevents deposition and fouling of the surfaces of the heat exchangersand allows solids to be removed through cooling tower blowdown. Copolymer is fedcontinuously, averaging approximately1500 gallons per month. The 2011 total was 19,435gallons.HEDP: Hydroxyethylidine diphosphonic acid (60%) is fed continuously as a scale inhibitor toprotect against calcium carbonate in the circulating/service water system. Average usage isapproximately 500 gallons per month. The 2011 total was 6633 gallons.Pyrophosphate: This mild steel corrosion inhibitor is fed continuously to the circulating andservice water systems at a rate of 30 gallons per day.Sodium Tolytriazole (50% TTA): For yellow metal corrosion control, TTA is fed continuouslyto the circulating and service water systems, averaging about 200 gallons per month. Thetotal for 2011 was 2599 gallons.Biopenetrant: Biopenetrant is added at a rate of 60 gallons once per week in conjunctionwith the daily biocide treatment and during "shock" treatments of the circulating and servicewater systems to enhance effectiveness of the oxidizing biocides.Sulfuric acid: Sulfuric acid (93%) is fed continuously to the circulating and service watersystems for pH control, averaging approximately 50,000 gallons per month. The 2011 totalwas 475,200 gallons.8. Provide for review the available studies or procedures that Ameren funds, undertakes, oruses to document that protected species are not impinged or entrained at the intake oraffected by the thermal effluent. These species should include the fish species that theprotected freshwater mussels attach to during their glochidal stages.Callaway Response:An impingement and entrainment study was performed and documented in the 1986 report"Evaluation of Cooling Water Intake Impacts on the Missouri River" and is included asEnclosure 5. This study concluded that based on the design and location of the intakestructure, impingement and entrainment, and thermal effluent were not issues at Callaway.9. Provide the Union Electric Company 1986 report "Evaluation of Cooling Water IntakeImpacts on the Missouri River," and any other similar reports referencing effects on aquaticresources.Callaway Response:The Union Electric Company 1986 report "Evaluation of Cooling Water Intake Impacts onthe Missouri River," is included as Enclosure 5.

Page 6 of 23Enclosure Ito ULNRC-0589310. Provide a description of the thermal discharge temperatures of the blowdown water.Callaway Response:Descriptions of the thermal discharge temperatures is contained in the Discharge MonitoringReports, which are prepared quarterly and reflect a year's worth of data. The four mostrecent Discharge Monitoring Reports are included as Enclosures 6,7,8, and 9.11. Provide a description of the planned construction of additional water treatment/sedimentretention ponds over the next 20 years.Callaway Response:The average life for the sediment retention ponds is between 6 -8 years. The life of anyspecific retention pond depends on the size of the pond and the amount of silt being carriedin the Missouri River. Currently, it is estimated that the #4 sediment pond will be at capacitywithin 3 years. Over the next 20 years, assuming that Callaway will continue to get makeupwater from the Missouri River, Callaway will need 3 additional sediment retention ponds.

Page 7 of 23Enclosure Ito ULNRC-05893Environmental Justice & Socioeconomics1. Provide information about any observed subsistence consumption behavior patterns,specifically fish and wildlife consumption, by minority and low-income populations inthe vicinity of Callaway. This subsistence consumption behavior could consist ofhunting, fishing, and trapping of game animals and any other general food gatheringactivities (e.g., collecting nuts, berries, and other plant materials) conducted byminority and low-income individuals.Callaway Response:Although there are individuals living around the Callaway Plant that consume localwildlife and plants, Ameren is not aware of any population groups with subsistencebehavioral patterns. As reported in Table 2.6-2 of Ameren's Environmental Report,there are no minority populations in the nearest counties of Callaway, Gasconade,Montgomery, and Osage, and few within the 50-mile region (see EnvironmentalReport Figure 2.6-2). Callaway County has two low-income block groups.The AmerenUE Callaway Plant Unit 2 COLA (Environmental Report), Rev. 1discusses subsistence living in Sections 2.5.4.3 and 4.4.3.2 (ML090710390 andML090710395, respectively). The sections do not identify any subsistence patternsby minority or low-income populations.2. In addition to property tax payment information presented in Section 2.10 of theenvironmental report (ER), describe any other major annual support payments, one-time payments, and other forms of non-tax compensation (if any) provided to localorganizations, communities, and jurisdictions (e.g., county, municipality townships,villages, incorporated places, and school districts) on behalf of Callaway.Callaway Response:Ameren makes several support payments to the State Emergency ManagementAgency (SEMA) and other counties with the 50 mile emergency planning zone. Thebreakdown for payments in 2011 are as follows:SEMA -$266,225 out of a total of $1,331,125 to be paid between Sept. 2011 andJuly 2013Callaway County -$260,000Osage County -$48,000Montgomery County -$48,000Gasconade County -$48,000 Page 8 of 23Enclosure Ito ULNRC-058933. Provide data on the height of the tallest (visible from offsite locations) structures atCallaway and general information on the visibility of plant facilities from variousoffsite locations.Callaway Response:Section 2.1 of Ameren's Environmental Report states, "For about a six-mile radius,the elevation is slightly lower than that of the plant area. Therefore, the Callawaycooling tower is a prominent feature of the area." It also states that the averageelevation of the site is approximately 850 feet. Section 3.1.2 of this report furtherdescribes the cooling tower as 555 feet above ground level. While no viewshedanalysis has been performed, the cooling towers are clearly visible from Interstate I-70 approximately 11 or more miles to the north.The AmerenUE Callaway Plant Unit 2 COLA (Environmental Report) Rev. 1,discusses visual impacts in Sections 4.4.1.6 and 5.8.1.5 (ML090710395 andML090710396, respectively), but does not provide viewshed information regardingthe cooling tower visibility.

Page 9 of 23Enclosure 1to ULNRC-05893Electromagnetic Fields1. For the computer code used to calculate the induced current, provide details ofthe code, the model developed for this plant, the input, and the output results.Callaway Response:The program used by Ameren is the FIELDS program developed by SouthernCalifornia Edison. The following information is taken from the documentation fileprovided with FIELDS.The FIELDS program is designed to calculate and plot the magnetic and electricfields produced by transmission and distribution lines. The program will computefields for any combination of up to 60 conductors and 10 ground wires withvoltage, current, and phase angle independently specified.FIELDS 2.0Southern California Edison Co.6090 North Irwindale AvenueIrwindale, Ca 917021. FIELDS can handle up to 60 parallel conductors and 10 ground wires.2. Electric field values can only be computed for conductors placed above ground,as ground is assumed to be a perfect conductor for the E field calculations. Anyconductor touching the surface of the earth will have an effect on the electric fieldabove ground; however, since the conductor is touching the earth and the earth isassumed to be a perfect conductor, these effects are small and complex tocalculate. Therefore the effect or any conductor touching the surface will benegligible. Magnetic fields from underground conductors, however, are calculatedby this program.3. No two conductors or ground wires can occupy the same position or the programwill not function properly.4. The program will give a warning to the user when the field calculations are insidethe surface of a conductor, or within two bundle diameters of a bundled conductor.The algorithm only calculates the fields that are a distance from the center of thewire greater than or equal to the radius of the wire for single wire conductors. Forbundled conductors the exact position and orientation of the wires is not input,therefore the program uses a geometric approximation that breaks down as thepoint of calculation approaches the bundle (within two bundle diameters). If youwant a more exact calculation this close to a bundle, then enter each wire of thebundle as a separate conductor with the exact positions. Remember each wire ofa bundle has the same voltage as the total voltage of the bundle, but each wiresplits the total current of the bundle among each wire.

Page 10 of 23Enclosure 1to ULNRC-058935. The maximum number of points in a given profile is 602. For example, this wouldallow for a maximum observer distance of 300 feet if samples were calculatedevery 1 foot or a maximum observer distance of 3000 feet given calculationsevery 10 feet.6. Users should note that the positions of the phase conductors, groundwires, andthe right-of-way (RA4) lines on the field graphic plots are approximate and mayvery slightly from the user-entered values. If the display of the RAM lines is notdesired, users may leave both R/W positions at zero or may position thembeyond the maximum observer distance; either way the RIW lines will not appearon the plots. FIELDS gives users the option of displaying the configuration of theconductor and ground wires on the plots. It should be noted that only the firstcharacter of the user-specified phase and ground wire name is actually plotted onthe field plots.Methods of Calculation used in FIELDSThe FIELDS program utilizes the basic algorithms for the calculation of electricand magnetic fields listed in EPRI's TRANSMISSION LINE REFERENCE BOOK(THE RED BOOK)(Pages 330-331, 409-410, and 341-342). The electric fieldcalculation assumes earth as a perfect conductor and sums the vectorcomponents of the field created by the charge on each conductor. Likewise, themagnetic field calculation performs a vector sum of the contribution to the fieldfrom each of the conductor currents. FIELDS calculates both the square root ofthe sum of the squares of the vertical and horizontal field components and alsothe maximum phasor component based upon the magnitude of the major semi-axis of the field ellipse. The field calculations are accurate within the validity of theinput data. Special care should be exercised in selecting current and phase anglevalues to insure that the model represents realistic conditions. The modelcalculations have been validated against Electric Power ConsultantsIncorporated's program EBFANRI, and Bonneville Power Administration'sprogram, Corona, among others.The inputs are the geometry, voltage, frequency and other parameters for the cases to be run. Theoutput to this analysis was the graph reported in Ameren's Environmental Report. The inducedcurrent was then calculated based on these results.

Page II of 23Enclosure Ito ULNRC-05893Hydrology and Water Quality -Groundwater1. Provide the plant flow diagram that was part of the recent National PollutantDischarge Elimination System (NPDES) permit renewal.Callaway Response:The flow diagram that was included as part of the recent NPDES permit is includedas Enclosure 4.2. Confirm and provide documentation that the groundwater sample reported in the ER(Table 2.3-2) was analyzed for strontium, rather than only for the isotope ofstrontium (strontium-90).Callaway Response:The table data were taken from Table 2.3-34 of the Unit 2 COL Application(AmerenUE 2009). Table 2.3-34 shows that the units for Sr-90 should be pCi/L.Therefore, radioactive strontium (Sr-90) is what was intended, not elementalstrontium. A revised Table 2.3-2 from the Callaway license renewal ER is includedas Enclosure 10.3. For those wells with tritium levels above background provide data that showschanges in tritium concentrations in groundwater over time.Callaway Response:Tritium in the power block wells is due to washout from gaseous effluentsdischarged in accordance with the Callaway Operating License. The washout isinfluenced by several factors such as the type and amount of precipitation, the winddirection, and the temperature.The elevated tritium in well MW-939 in March & April, 2011 is due to condensationfrom the Refueling Water Storage Tank vent during cold weather conditions.The very low concentration of tritium observed in monitoring wells MWO14, MWO17,MWO18, and MWO19 is from minor releases over a 24 year period from air releasevalves on the original plant blowdown pipe in this area. High density polyethylenepipe was installed in 2008 to replace the original blowdown piping. The new HDPEpipe does not use air release valves. Eleven wells were installed to closely monitorthe natural attenuation of the tritium. The well sample data shows that the plume isnot migrating and is slowly dissipating. A table of tritium concentrations bymonitoring well is included as Enclosure 11.

Page 12 of 23Enclosure 1to ULNRC-058934. To adequately describe groundwater quantity impacts, NRC needs to know thesource or sources of the water that flows into the groundwater sump (i.e., Whataquifers are being impacted or are there other sources for the water?). In respondingto this request, explain why you believe the groundwater is being supplied from thatsource or sources that are identified in the response. If there are other sumps in thebasements of the buildings of the power block collecting groundwater, estimate therate of groundwater collected from those sources. Provide cross section drawingsreferred to in an October 8, 2008, letter from Ameren to the Missouri Department ofNatural Resources (MDNR) (ML083150703) as Attachment F.Callaway Response:The undisturbed areas surrounding the power block still have the original glacial tilland loess creating a fairly impermeable "bathtub" comprised of Graydon Chert(extremely low permeability rates) (Callaway Standard Plant FSAR Section 1.2.1.5).After excavation, the powerblock area was backfilled with Category I StructuralBackfill and capped with a clay blanket. The source of the water in the bathtub areaunder the Callaway power block is rainwater. Based on the design of the powerblock bathtub, there would be very limited to no interaction between the groundwater inside the bathtub and existing aquifers. Therefore, there would be nosignificant aquifer impacts.Ameren has also observed minor amounts of condensed tritium in washout (by rainor snow) from airborne effluent releases in several monitoring wells and in thegroundwater sump samples. Potential leaks of plant piping or components withinthe power block area would be identified quickly in these monitoring wells. Water iscontinuously pumped from the groundwater sump. This pump was installed in thegroundwater sump to help remediate a diesel fuel oil leak within this area. Waterwithin the bathtub is drawn down or pulled towards the groundwater sump and ispumped to an oily waste separator. No other sumps are currently installed to collectthis groundwater. The groundwater sump and additional monitoring wells locatedwithin the power block bathtub are monitored monthly for tritium and gammaemitters. This provides the earliest indication of any potential leak of radioactivefluid from power block piping or equipment.Sumps in the power block buildings do not normally collect groundwater, but maycollect groundwater if the groundwater within the bathtub area is high enough forintrusion into the buildings. Sumps are piped to the Radwaste Building for dischargein radioactive liquid effluents.Drawings provided in the April 18, 2008 letter (Attachment F provided plant drawingsshowing cross-sections of the power block buildings and structures) are as followsand provided as Enclosures 12, 13, 14, 15, and 16 respectively:8600-X-88130 -Power Block -Building Fill & Backfill Plan Sheet Page 13 of 23Enclosure 1to ULNRC-058938600-X-88133 -Power Block -Building Fill & Backfill Cross Sections8600-X-88134 -Power Block -Building Fill & Backfill Cross Sections8600-X-88139 -Power Block -Building Fill & Backfill Cross Sections8600-X-88140 -Power Block -Building Fill & Backfill Cross Sections5. Provide a map showing the closest private well to Callaway that is approximately0.25 miles southeast of Intake Well #1.Callaway Response:A map showing the closest private well to Callaway is included as Enclosure 17.

Page 14 of 23Enclosure Ito ULNRC-05893Hydrology and Water Quality -Surface Water1. Provide a description of settling and effluent discharge pond changes (i.e., newponds needed and old ponds abandoned) over the period of license renewal.Callaway Response:There are no changes planned for the current storm water settling ponds during thelife of the plant including the 20 year extension period. There are currently fiveponds with current NPDES permitted storm water discharge outfalls (Ouffalls: 010,011,012,014 and 015). Outfall 013 was removed from the last NPDES Permit as itno longer has drainage from an area of "industrial activity".2. Provide any notices of violation (NOVs), nonconformance notifications, or relatedinfractions received from regulatory agencies associated with NPDES permitteddischarges, sewage systems, groundwater or soil contamination, including spills,leaks, and other inadvertent releases of fuel solvents, chemicals, or radionuclides(covering the past 5 years).Callaway Response:There have been no notices of violation or similar infractions within the last 5 years.

Page 15 of 23Enclosure 1to ULNRC-05893Land Use and Transmission Lines1. Please confirm whether the 2005 land use/land cover data presented in Table2.11-1 and Figure 2.11-1 has changed; and if so, please provide the following: 1)the most recently available land use calculation package for Callaway County and2) an updated figure depicting the most recently available land use data.Callaway Response:Ameren checked the source, the Missouri Spatial Data Information Service, for theland use/land cover data used in the ER and found that the 2005 data remain themost current. A dated copy of the applicable MSDIS webpage, in portabledocument format, is provided as Enclosure 18. Accordingly, there is no updatedFigure 2.11-1.The land use calculation package has been provided as Enclosure 19.

Page 16 of 23Enclosure 1to ULNRC-05893Meteorology and Air Quality1. Provide a description of the primary meteorological tower and backup meteorologicaltower. Include a description of instrumentation installed and height of installation foreach instrument. Describe any changes in land use around the tower sites that haveoccurred since installation that may affect any meteorological sensors.Callaway Response:A detailed description of Callaway's meteorological tower is contained in theCallaway Final Safety Analysis Report -Site Addendum Chapter 2.3.3.2. Provide the most recent 5 years of annual emission statements to the MDNR foremissions of air pollutants resulting from operations at Callaway.Callaway Response:The most recent 5 years of annual emission statements to the MDNR for emissionsof air pollutants resulting from operations at Callaway are provided as Enclosures20, 21, 22, 23, and 24.3. Provide a summary of Callaway greenhouse gas emissions. Include emissions ofcarbon dioxide from permitted combustion sources and emissions of sulfurhexafluoride (SF6) leakage, if available.Callaway Response:Ameren has no direct data on greenhouse gas emissions, including carbon dioxideand sulfur hexafluoride. The current permitting process only requires the reportingof gallons of fuel used, not emissions or emission source run times. Greenhousegas emission sources at Callaway include two emergency diesel generators, anauxiliary boiler and four alternate emergency power supply diesel generators. All ofthese emission sources are run on an infrequent basis for testing or use duringrefueling outages.4. Provide noise emissions studies conducted at Callaway, if any, and any informationabout noise that could be considered a nuisance to offsite property owners. Also,provide information about any noise complaints.Callaway Response:Callaway has not received any noise complaints and therefor has not conducted anynoise studies. Noise was not identified as an issue during the New and SignificantInformation Process.

Page 17 of 23Enclosure 1to ULNRC-05893Terrestrial Ecology1. Provide a copy of the review of new and significant information document ordescribe what specific records or information Ameren reviewed to determine that nonew and significant information exists for each of the terrestrial ecology Category 1issues applicable to Callaway.Callaway Response:The New and Significant Information Report is included as Enclosure 2. Also, seeresponse to Aquatic Ecology RAI #1.2. The ER references several ecological studies conducted in 2007 and 2008 for theCallaway Plant, Unit 2, combined license application (COLA) and also referencesthe COLA ER. Please provide copies of the terrestrial studies performed for theCOLA, including the mammalian, avian, and herpetological studies mentioned onpage 17 and the floral survey and 2007 land cover survey mentioned on page 2-226of the COLA ER. Describe the specific mitigation measures that Ameren takes toensure that its transmission-line maintenance does not impact any Federally listedspecies, including personnel training, coordination with State and Federal agencies,and specific precautions that workers must take in the field. Provide copies of relatedprocedures, if applicable.Callaway Response:These studies exist as section 2.4 of the Callaway Unit 2 COL Application.Descriptions of the methodologies used to conduct the surveys are contained in theMACTEC Standard Operation Procedures (SOP) for the Callaway Nuclear Plant Unit2 Siting Study, Natural Resources Field Sampling and Analysis, and are provided asEnclosure 3. If Ameren observes federally listed species, vegetation maintenancewill not be performed in that area.3. Provide a description of the time of year ground clearing is conducted for thetransmission line management.Callaway Response:Ameren performs ground clearing year round on an as-needed basis. However,special precaution is taken to avoid areas where threatened and endangeredspecies are present.4. Provide a description of any special vegetation management techniques along thetransmission lines at stream and wetland crossings.Callaway Response:It is not Ameren's practice to leave woody vegetative buffers along water ways orroadways. These buffers inhibit line of sight and provide little more soil stability thanapproved low variety perennial vegetation or a forb/grass mix. NPDES allows the Page 18 of 23Enclosure 1to ULNRC-05893vegetation management methodology to be left up to individual land managers.Ameren treats all buffers, including water's edge buffers. Ameren, using EPAregistered herbicides & staying within the MSDS label restrictions, will either basalband, hack/squirt, cut/stubble or use a low volume individual stem application onbrush located within these waters edge buffer zones.

Page 19 of 23Enclosure Ito ULNRC-05893Waste Management1. Provide information about Callaway's typical yearly low-level waste generation rate,processing methods, storage capability, and disposal options or reasonablyforeseeable disposal options that demonstrate that there will be adequate storageand disposal capabilities during the period of license renewal. With respect to thedisposition of Class B and Class C waste, provide the status of the arrangementsbeing made for the disposal of this material in the licensed low-level radioactivewaste disposal facility in Texas or other options.Callaway Response:This information is contained in the "Callaway Energy Center Radioactive WasteManagement Plan" and is provided as Enclosure 25.2. Provide Callaway's Radioactive Waste Management Plan.Callaway Response:See enclosed "Callaway Energy Center Radioactive Waste Management Plan" andis provided as Enclosure 25.3. Is Callaway a large quantity, small quantity, or conditionally exempt small quantitygenerator of hazardous waste?Callaway Response:Callaway Plant is a small quantity generator of hazardous waste generating between200 and 2200 lb. of hazardous waste per month. The waste is stored in aprefabricated Hazardous Waste Storage Building (HWSB) with containment sumps,designed specifically for storage of hazardous waste. Waste is stored in the HWSBfor up to 180 days prior to disposal via an off-site vendor. Typical wastes generatedare Chromium, Lead, Mercury, Silver, and solvents. The plant also currentlymaintains an outside satellite accumulation area where waste paint and solvents areaccumulated. These wastes are accumulated from work performed in the plant intwo separate 55-gallon drums held in a prefabricated closed spill container capableof holding 110 percent of the volume in both drums.4. Provide 2010 and 2011 Generator's Hazardous Waste Summary Reports.Callaway Response:This information is contained in the Hazardous Waste Summary Reports and isprovided as Enclosures 26 and 27.

Page 20 of 23Enclosure 1to ULNRC-058935. Provide 2010 and 2011 Facility Summary Reports.Callaway Response:The quarterly Facility Summary Reports for 2010, 2011 and first quarter 2012 areprovided as Enclosures 28 and 29.6. If radiologically contaminated used oil is not addressed in the Facility SummaryReports, provide a brief description of the quantities of such oil that are generatedand how the oil is handled and disposed of.Callaway Response:Radiologically contaminated oil is not specifically addressed in the Facility SummaryReport. The amount produced varies based on radiological conditions and theamount of work performed. The average amount of radiologically contaminated, non-mixed waste, oil is approximately 100 gallons per year. This oil is stored anddisposed of in the same way as any other low level waste.7. Provide 2010 and 2011 Emergency Planning and Community Right-to-Know Act(EPCRA) reports (Tier Two inventories).Callaway Response:Ameren has provided the Callaway Tier II Reports for 2010 and 2011 as Enclosures30 and 31.8. Provide recent (2011) reporting for hazardous air pollutants released (SARA ToxicRelease Inventory reports).Callaway Response:Ameren has provided the most recent Air Emission Report as Enclosure 24.

Page 21 of 23Enclosure Ito ULNRC-05893References Requested for DocketingEnclosureI TitleAquatic Ecology32 A. CDM (Camp Dresser & McKee, Inc.) 1981. Water quality and aquaticbiological preoperational monitoring program for the CallawayNuclear Plant: June 1980 through May 1981. Prepared for UnionElectric Company, St. Louis, Missouri, by Camp Dresser & McKee,.Milwaukee, Wisconsin. July.33 B. CDM (Camp Dresser & McKee, Inc.) 1982. Water quality and aquaticbiological preoperational monitoring program for the CallawayNuclear Plant: June 1981 through May 1982. Prepared for UnionElectric Company, St. Louis, Missouri, by Camp Dresser & McKee,Milwaukee, Wisconsin. September.2 C. UEC (Union Electric Company) 1986. Callaway Plant: Evaluation ofCooling Water Intake Impacts on the Missouri River. Prepared byEnvironmental Services Department, St. Louis. July.2 D. All related 316 studies completed for Callaway.34 E. Callaway NPDES Permit MO-0098001Hydrology and Water Quality -Groundwater35 A. AmerenUE 2007. Callaway Plant Final Environmental Evaluation ofBlowdown Line Replacement. July.36 B. AmerenUE 2008b. Callaway Major Water Use Report 2008.37 C. AmerenUE 2010a. Callaway Action Request System 201005073,Absence of Monitoring Wells near SSCs Containing RadioactiveFluids. May.10 D. AmerenUE 2010b. Groundwater Sample Minima, Maxima, and MeanValues for all Sampling Rounds at Callaway Plant Site 2007 -2008.April.38 E. AmerenUE 2010c. Callaway Landfill Groundwater Quality Data 2006-2009. March.

Page 22 of 23Enclosure Ito ULNRC-0589339 F. Burns & McDonnell (Burns and McDonnell Engineering Company)2008. Phase II Hydrogeologic Investigation Report Collector WellSiting Study, Callaway Unit 2. June.Does not G. MDNR (Missouri Department of Natural Resources) 2003. Majorexist Nuclear Power Plant. October.40 H. MDNR (Missouri Department of Natural Resources) 2009b. Callaway#2 Water District PWSS Report 3024085.43 I. Rizzo (Rizzo Associates, Inc) 2008. Final Groundwater Model Report(rev 1, Callaway Nuclear Power Plant, October.)44 J. Terracon 2010. Groundwater Monitoring, Fuel Groundwater Wells.February.45 K. Tetra Tech 2010. Map Showing Location of Callaway #2 WaterDistrict and Fulton Water District Public Supply Wells. January.Hydrology and Water Quality -Surface Water46 A. Ameren Missouri. 2011. 2010 Annual Radiological EnvironmentalOperating Report for the Callaway Plant. USNRC-05785. April 29,2011.5 B. UEC (Union Electric Company) 1986. Callaway Plant: Evaluation ofCooling Water IntakeDoes not C. Impacts on the Missouri River. Prepared by Environmental Servicesexist Department, St. Louis. Jul.47 D. USACE (United States Army Corps of Engineers) 2003. FinalEnvironmental Impact Statement for the Missouri River Fish andWildlife Mitigation Project. U.S. Army Corps of Engineers.Does not E. Kansas City District, Kansas City, Missouri, and Omaha District,exist Omaha, Nebraska. March.Terrestrial Ecology Page 23 of 23Enclosure Ito ULNRC-0589348 A. Missouri Department of Conservation 2008. Reform ConservationArea: Area Plan 20062016.Waste ManagementPreviously A. Ameren document CTP-HM-00300, Handling, Storage, Evaluation,Provided and Disposal of Hazardous and Mixed Wastes.Previously B. Ameren document APA-ZZ-00831, Hazardous Chemical ControlProvided Program.Previously C. Ameren document APA-ZZ-00832, Hazardous and Special WasteProvided Management Program Page 1 of 2Attachment Ito ULNRC-05893Attachment 1Enclosure Document TitleNumber2 Ameren's New and Significant Information Report, without Appendix B3 MACTEC Standard Operation Procedures (SOP) for the Callaway NuclearPlant Unit 2 Siting Study, Natural Resources Field Sampling and Analysis4 Callaway NPDES Flow Diagram5 Evaluation of Cooling Water Intake Impacts on the Missouri River6 Callaway Discharge Monitoring Report -3rd Quarter 20117 Callaway Discharge Monitoring Report -4th Quarter 20118 Callaway Discharge Monitoring Report -1 st Quarter 20129 Callaway Discharige Monitoring Report -2nd Quarter 201210 Revised Environmental Report Table 2.3-211 Groundwater Tritium Well Data12 8600-X-8813013 8600-X-8813314 8600-X-8813415 8600-X-8813916 8600-X-8814017 Map of Wells Within 1 Mile of the River Water Intake Structure18 MSDIS19 Calc Package Land Use20 Callaway 2007 Air Emission Report21 Callaway 2008 Air Emission Report22 Callaway 2009 Air Emission Report23 Callaway 2010 Air Emission Report24 Callaway 2011 Air Emission Report25 Callaway Energy Center Radioactive Waste Management Plan26 2010 Generator's Hazardous Waste Summary Report27 2011 Generator's Hazardous Waste Summary Report28 2010 Facility Summary Reports29 2011 Facility Summary Reports30 2010 Emergency Planning and Community Right-to-Know Act (EPCRA)report31 2011 Emergency Planning and Community Right-to-Know Act (EPCRA)reports32 CDM (Camp Dresser & McKee, Inc.) 1981. Water quality and aquaticbiological preoperational monitoring program for the Callaway Nuclear Page 2 of 2Attachment Ito ULNRC-05893Plant: June 1980 through May 1981. Prepared for Union ElectricCompany, St. Louis, Missouri, by Camp Dresser & McKee, Milwaukee,Wisconsin. July.33 CDM (Camp Dresser & McKee, Inc.) 1982. Water quality and aquaticbiological preoperational monitoring program for the Callaway NuclearPlant: June 1981 through May 1982. Prepared for Union ElectricCompany, St. Louis, Missouri, by Camp Dresser & McKee, Milwaukee,Wisconsin. September.34 Callaway NPDES Permit MO-009800135 AmerenUE 2007. Callaway Plant Final Environmental Evaluation ofBlowdown Line Replacement. July.36 AmerenUE 2008b. Callaway Major Water Use Report 2008.37 AmerenUE 2010a. Callaway Action Request System 201005073, Absenceof Monitoring Wells near SSCs Containing Radioactive Fluids. May.38 AmerenUE 2010c. Callaway Landfill Groundwater Quality Data 2006-2009. March.39 Bums & McDonnell (Bums and McDonnell Engineering Company) 2008.Phase II Hydrogeologic Investigation Report Collector Well Siting Study,Callaway Unit 2. June.40 MDNR (Missouri Department of Natural Resources) 2009b. Callaway #2Water District PWSS Report 3024085.41 Rizzo (Rizzo Associates, Inc) 2008. Final Groundwater Model Report (rev1, Callaway Nuclear Power Plant, October.)42 Terracon 2010. Groundwater Monitoring, Fuel Groundwater Wells.February.43 Tetra Tech 2010. Map Showing Location of Callaway #2 Water Districtand Fulton Water District Public Supply Wells. January.44 Ameren Missouri. 2011. 2010 Annual Radiological EnvironmentalOperating Report for the Callaway Plant. USNRC-05785. April 29, 2011.45 USACE (United States Army Corps of Engineers) 2003. FinalEnvironmental Impact Statement for the Missouri River Fish and WildlifeMitigation Project. U.S. Army Corps of Engineers. Kansas City District,Kansas City, Missouri, and Omaha District, Omaha, Nebraska. March.46 Missouri Department of Conservation 2008. Reform Conservation Area:Area Plan 20062016.