ML15061A110

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

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

Text

James, LoisFrom: Ranek, Nancy L.:(GenCo-Nuc)

<Nancy.Ranek@exeloncorp.com>

Sent: Friday, February 13, 2015 9:56 AMTo: James, LoisCc: Gallagher, Michael P:(GenCo-Nuc);

Fulvio, Albert A:(GenCo-Nuc);

Hufnagel Jr, JohnG:(GenCo-Nuc)

Subject:

Minor Updates, Corrections, and Clarifications Regarding Draft NUREG-1437, Supplement 54Attachments:

RS-15-072

-Byron-Comments on Draft SEIS.pdf; 2015.02.12

_MinorUpdatesCorrectionsClarifDSEISSupp54.pdf Hi Lois --As you know, by letter dated Thursday, February 12, 2015, Exelon submitted comments for the record regarding theDraft NUREG-1437 Supplement 54 for the Byron Station License Renewal.

I am attaching that submittal for yourinformation.

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

Please call if there are questions.

Thanks.Nancy L. Ranek -License Renewal Environmental LeadExelon Generation, LLC "200 Exelon Way, KSA/2-E .. -Kennett Square, PA 19348 2Phone: 610-765-5369

%-nFax: 610-765-5658 Email: nancy.ranek@exeloncorp.com This e-mail and any attachments are confidential, may contain legal,professional or other privileged information, and are intended solely for theaddressee.

If you are not the intended recipient, do not use the information in this e-mail in any way, delete this e-mail and notify the sender. -EXCIPSUNSI Review CompleteTemplate

= ADM -013E-RIDS= ADM-03Add= /,(--' _ -)1 1fMinor Updates, Corrections, and Clarifications onDraft Supplement 54 to the Generic Environmental Impact Statement for License Renewal of Nuclear Plants Regarding Byron Station, Units 1 and 2Where suggested changes to the SEIS are provided, they are highlighted with bolded italic font forinserted text and ctrikotHro; font for deleted text.Page Line Section Commentxxi 11 Executive In the Executive

Summary, on page xxi in line 11,Summary add "Revision 1" after the words "(GELS) for LicenseRenewal of Nuclear Plants."xxiii Executive For consistency with 10 CFR Part 51, Table B-i,Summary insert the following parenthetical into the Executive 2 Summary on page xxiii after the words "Water useconflicts with aquatic resources":

"(plants with cooling ponds or cooling towersusing makeup water from a river)" to match,xxiii Executive For consistency with 10 CFR Part 51, Table B-i, editSummary the text in the Executive Summary on page xxiii as3 follows:"Threatened, or endangered, and protected species and essential fish habitat'xxvii 21 to 22 Abbreviations

& The two definitions for "APE" provided on lines 21 toAcronyms 22 on page xxvii apply only to "APE" as used in theDSEIS Appendix F. In the main body of the DSEIS,4 "APE" is used as an acronym for "area of potential effect" as applicable to historic and archaeological resources (see pp. 3-65, 4-46, and 4-106). Theadditional meaning for APE should be added to thelist of Abbreviations

& Acronyms.

1-1 19to 20 1.1 In lines 19 to 20 on page 1-1:" Add a space between "NRP-37" and the word5 "and"." License[s]

for an additional 20 years -licenseshould be plural.1-7 20 to 21 1.10 In lines 20 to 21 on page 1-7, add the word"applicable" as follows:6 "Exelon is responsible for complying with allapplicable NRC regulations and otherapplicable

Federal, state and localrequirements."

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

Suggest deleting:

7 "Examples of these activities

include, but are notlimited to, replacement of boiling-water reactorrecirculation piping and pressurized water reactorsteam generators."

8 2-4 29 2.2.2 Change "at the end of this section" to "in section 2.3"2-5 28 2.2.2 As written, the sentence in line 28 on page 2-5suggests that only ComEd customers receive9 electricity from Byron. Consider changing thesentence as follows:"Byron is owned and operated by Exelon and2/12/2015 2Minor Updates, Corrections, and Clarifications onDraft Supplement 54 to the Generic Environmental Impact Statement for License Renewal of Nuclear Plants Regarding Byron Station, Units 1 and 2Where suggested changes to the SEIS are provided, they are highlighted with bolded italic font forinserted text and strkothro font for deleted text.Page Line Section Commentprovides electricity through Commonwealth

-diser-to the ROI through transmission lines owned by Commonwealth Edison".2-6 11 2.2.2 In line 11 on page 2-6, hyphenate the words10 "megawatt hours"as follows:"megawatt-hours" 2-6 2 2.2.2 In line 2 on page 2-6, consider changing the phrase11 "... procured from adjoining states ..." as follows:"... procured from Illinois or adjoining states ...12 2-7 31 to 33 2.2.2 In lines 31 to 33 on page 2-7, "clean coal technology" is mentioned twice. Delete the duplicate.

2-11 35 2.2.2.1 A short citation to "NRC 2011" is provided in line 3513 on page 2-11, but no corresponding full citation isprovided on page 4-126 in section 4.18 (References).

2-12 23 to 24 2.2.2.2 In lines 23 to 24 on page 2-12, consider inserting textas follows:14 "The technology is cleaner than conventional pulverized coal plants because some of themajor pollutants are removed from the gasstream before combustion."

2-12 46 2.2.2.2 In line 46 on page 2-12, consider inserting text asfollows:15 "The IGCC plant will reduce carbon emissions per MWh by nearly half compared toconventional coal-fired power plants (DukeEnergy 2013)."16 2-15 23 2.2.2.4 Delete the words "the environmental impacts of" online 232-16 45 to 49 2.2.2.4 In lines 45 to 49 on page 2-16 and lines 1 to 2 onand and page 2-17, it is not clear how the information is17 2-17 1 to 2 pertinent to the proposed wind alternative, whichdoes not include interconnecting of wind farms as afirming capacity method.2-18 30 to 34 2.2.2.5 The discussion of impacts in lines 30 to 34 on18 page 2-18 seems out of place. Consider moving it toChapter 4.2-20 21 to 22 2.3.3 In lines 21 to 22 on page 2-20, consider changing thesentence as follows:19 "The NRC staff describedevaaueted such apossible combination alternativees deernFbed in Section 2.2.2.4."

2/12/2015 3Minor Updates, Corrections, and Clarifications onDraft Supplement 54 to the Generic Environmental Impact Statement for License Renewal of Nuclear Plants Regarding Byron Station, Units 1 and 2Where suggested changes to the SEIS are provided, they are highlighted with bolded italic font forinserted text and ..ikthro font for deleted text.Page Line Section Comment2-21 18 to 19 2.3.3.3 In lines 18 to 19 on page 2-21, consider changing thesentence as follows:20 "The NRC staff describedevaluated such apossible combination alternativea-dcScF*bin Section 2.2.2.4."

2-22 36 2.3.6 In line 36 on page 2-22, correct the name "Electric 21 Power Resource Institute (EPRI)" as follows:"Electric Power ReseiFeeResearch Institute (EPRI )".2-27 Table 2-2 Note 9 In Note 9 for Table 2-2 on page 2-27, change the 1stsentence as follows:"The Purchased Power Alternative could be22 disproportionately affect low-income populations bybecause of increased utilitybills behause-efresulting from the cost ofpurchased power."2-27 Table 2-2 Note 3 Modify Note 3 for Table 2-2 on page 2-27 byreplacing the words "these populations" with thewords "minority and low-income populations".

The23 revised text should read: "Continued operation ofByron would not have disproportionately high andadverse human health and environmental effects ontheseminority and low-income populations."

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

3-5 1 to 2 3.1.1 To ensure clarity in lines 1 to 2 on page 3-5, considerediting the phrase "(Byron Salvage Site; not25 contaminated by activities at Byron)" as follows:"... (Byron Salvage Site; not contaminated byactivities at-related to the construction andoperation of Byron Station)..."

3-8 42 to 44 3.1.3.3 In lines 42 to 44 on page 3-8, the text indicates thatthe essential service water system includes two12-inch pipelines from the river screen house that are26 dedicated to providing a source of backup makeupwater. Consider

whether, for completeness, theadditional emergency backup water source formakeup to the essential service water from the twoon-site deep wells should also be mentioned.

3-10 10 to 11 3.1.4.1 Change the phrase "... these wastes are eitherreleased under controlled conditions via the cooling27 water system or ..." as follows:

"... these wastes areeithefreused, released under controlled conditions via the cooling water system, or..."2/12/2015 4Minor Updates, Corrections, and Clarifications onDraft Supplement 54 to the Generic Environmental Impact Statement for License Renewal of Nuclear Plants Regarding Byron Station, Units 1 and 2Where suggested changes to the SEIS are provided, they are highlighted with bolded italic font forinserted text and tkh font for deleted text.Page Line Section Comment28 3-13 30 3.1.4.3 In line 30 on page 3-13, change "would" to "will."3-13 16 to 18 3.1.4.3 Based on the Byron UFSAR section 11.4.2.4, p.11.4-11, modify the sentence in lines 16 to 18 onpage 3-13 as follows:29 "Byron has a-drumming and storage areas whertwewithin which a total of four remotely operatedcranes (two per unit) are used to tra.spe.-t Rdposition thestored drums wh0i*ie-R sterage, as well astransport them to trucks for offsite disposal."

3-14 40 3.1.5 In line 40 on page 3-14, replace "1420.104(a)"

with"Sections 1420 through 1422 and 1450" because§ 1420.104(a) addresses only the ban on disposal of30 PIMW in Illinois landfills, while taken together, Sections 1420 through 1422 and 1450 addressrequirements applicable to transportation anddisposal of PIMW.3-15 16 to 18 3.1.6.2 Consider revising the sentence on lines 16 to 18 asfollows:

"Fuel is supplied to each standby dieselgenerator via the Fuel Oil System, which contains31 various tanks and fuel transfer pumps thatsized toprovide fuel to each engine for a minimum of 7 daysefduring post-accident operation without offsitesupport."

3-15 37 3.1.6.5 Revise the phrase "are with the scope of the NRC'slicense renewal review" in line 37 on page 3-15 as32 follows:"... are withwithin the scope of the NRC'slicense renewal environmental review".3-15 43 3.1.6.5 In line 43 on page 3-15, change the word "systems" 33 to "system" and change the word "connect" to"connects".

3-15 18 to 20 3.1.6.2 Because there are smaller tanks within the Fuel OilSystem for equipment other than the standby dieselgenerators, the sentence in lines 18 to 20 on page3-15 would be more accurate if changed as follows:34 "Byron's Fuel Oil System nensists ef includesfour 25,000-gallon (gal) diesel oil storagetanks dedinated-tefor the two Unit 1 standbydiesel generators and two 50,000-gal storage tanks dediated efor the two Unit 2standby diesel generators (2013d)."

35 3-16 1 3.1.6.5 In line 1 on page 3-16, change the phrase "Bothswitchyards" to "The switchyard" 36 3-17 19 3.2.1 In line 19 on page 3-17, change "Bryon" to "Byron.2/12/2015 5Minor Updates, Corrections, and Clarifications onDraft Supplement 54 to the Generic Environmental Impact Statement for License Renewal of Nuclear Plants Regarding Byron Station, Units 1 and 2Where suggested changes to the SEIS are provided, they are highlighted with bolded italic font forinserted text and 6trkth1--k font for deleted text.Page Line Section Comment3-17 20 to 21 3.2.1 The sentence in lines 20 to 21 on page 3-17 could bemisinterpreted to mean that Weld Memorial Park ison the Rock River. Instead, it is on Black Walnut37 Creek. Consider deleting the phrase "on the RockRiver," as follows:"These parks offer such recreational activities to the public as camping, picnicking, hiking,fishing, and boating on the RAck Rivor."38 3-17 40 3.2.1 Delete "highways" in line 40 on page 3-17.3-17 46 to 48 3.2.1 The sentence in lines 46 to 48 on page 3-17 is veryawkward.

Consider dividing it into at least twoseparate sentences as follows:"The Oregon Dam, 4 mi (6.4 km)39 downstream, creates the pool from whichByron draws its circulating water makeup andto whichdim&Ghare its blowdown isdischarged.te-and.

The Dam also controlsthe water level in the poolat-thentkake."

40 3-18 33 3.3.1 Change "ft" to "mi" in line 33 on page 3-18.41 3-18 14 3.2.2 In line 14 on page 3-18, insert the word "above"before the phrase "mean sea level."3-19 13 3.3.1 Because, as written, the text does not indicate whenannual average temperature measurements were42 taken, consider specifying the beginning and endingyears that define the "62-year period" mentioned inline 13 on page 3-19..3-19 25 3.3.1 Because, as written, the text does not indicate whenannual precipitation measurements were taken,43 consider specifying the beginning and ending yearsthat define the "30-year period" mentioned in line 25on page 3-19..3-20 38 to 40 3.3.2 In line 39 on page 3-20, the phrase "and there are noreported violations since October 1, 2011" is unclearbecause it suggests that a violation of the ByronFESOP permit limitations may have occurred onOctober 1, 2011. Consider revising the sentence in44 lines 38 to 40, as follows:"Byron has been in compliance with therequirements set forth in the air permit, andthere-area review of information for aperiod beginning October 1, 2011indicates no reported violations-swiee

__ _ __tobor, 2/12/2015 6Minor Updates, Corrections, and Clarifications onDraft Supplement 54 to the Generic Environmental Impact Statement for License Renewal of Nuclear Plants Regarding Byron Station, Units I and 2Where suggested changes to the SEIS are provided, they are highlighted with bolded italic font forinserted text and trikh font for deleted text.Page Line Section Comment3-20 23 to 27 3.3.2 The sentence on lines 23 to 25 on page 3-20 statesthat McHenry County and Kane County arenonattainment areas for PM2.5. The next sentenceon lines 26 and 27 on page 3-20 states that McHenryCounty and Kane County are "also designated 45 maintenance areas for the PM2.5 standard."

Assuch, the two sentences appear to contradict oneanother because the counties cannot simultaneously be both "nonattainment" and "maintenance" areas forthe same pollutant.

Consider better-clarifying theattainment status of McHenry and Kane Counties.

3-22 31 3.3.3 In line 31 on page 3-22, insert a space between the46 comma in the term "(corona discharge),"

and thewords "relief valve" as follows:"... (corona discharge),

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

48 3-23 5 3.3 In line 5 on page 3-23, change "(9 km)" to "(1 km)"because 0.6 mi = 0.966 km3-23 26 to 27 3.4.1 The sentence in lines 26 to 27 on page 3-23 is also49 used (verbatim) in Sections 3.2 and 3.3, and in eachcase a different source document is cited. Considerciting the same source document in all cases.50 3-27 7 3.5.1 Citation in line 7 on page 3-27 should read "(USGS2013d, 2013e)" rather than "(USGS 2013d, 20113e)."

3-28 25 to 26 3.5.1.2 For clarity, consider revising the sentence in lines 25to 26 on page 3-28 as follows:"*hi&The motivation for this operational limitis bydocumented in Byron'sUFSAR.The change is suggested because the Byron UFSARSection 2.4.11.5 (PDF page 1721; UFSAR page2.4-20) states that "The maximum water requirement 51 for the plant is 107 cfs."The Byron UFSAR Section 10.4.5 (PDF page 6502;UFSAR page 10.4-8) further states that ifconsumptive demand at full load exceeds 10 % of theriver flow, then net withdrawal will be maintained at alevel acceptable to the Illinois Department ofConservation, and if necessary, plant power level willbe reduced until river flow increases.

There is nomention in the Byron UFSAR, however, of limitingwithdrawal to 125 cfs.52 3-29 27 3.5.1.3 Delete the second period at the end of the sentence2/12/2015 7Minor Updates, Corrections, and Clarifications onDraft Supplement 54 to the Generic Environmental Impact Statement for License Renewal of Nuclear Plants Regarding Byron Station, Units I and 2Where suggested changes to the SEIS are provided, they are highlighted with bolded italic font forinserted text and strikethroh font for deleted text.Page Line Section Commentin line 27 on page 3-29.3-29 27 3.5.1.3 For clarity, consider inserting the words "not53 associated with Byron Station" after the words"various upstream sources" in line 27 on page 3-29.3-32 28 3.5.2 Change the phrase "within and near the Byron" inline 28 on page 3-32 by deleting the word "the"54 between the word "near" and the word "Byron" asfollows:within and near the-Byron."

3-36 4 3.5.2.2 Change the phrase "to the southwest of the Byron" in55 line 3 on page 3-36 by deleting the word "the"between the words "of" and "Byron" as follows:"... to the southwest of the-Byron."

3-36 44 3.5.2.3 To clarify the shift from discussing groundwater contamination from the Byron Salvage YardSuperfund Site to discussing groundwater contamination from the Byron Station56 intake/discharge

pipeline, consider replacing thewords "the plant" in line 44 on page 3-36 with thewords "Byron Station,"

as follows:"... pipeline that runs from the-plaetByron Station to the Rock River."57 3-39 9 3.6.2 Should be Phleum pratense, not "pretense" 58 3-39 25 3.6.2 Should be Q. palustris, not "palustria" 59 3-39 27 3.6.2 Should be C. ovata, not "ovate"60 3-41 Table 3-5 Should be Equisetum

pratense, not "pretense" 61 3-41 Table 3-5 Should be Luzula acuminata, not "acuminate" 62 3-45 Table 3-8 Should be Myotis sodalis, not "sodalist" 3-47 14 3.6.4 Suggest using the word "restoration" rather than63 "addition" on line 14 on page 3-47, as follows:"... and the possible addition restoration ofprairie plant habitat on the Byron property

..."3-47 17 to 18 3.7 In lines 17 to 18 on page 3-47, consider revising thephrase "from which the facility withdrawals anddischarges cooling system make-up and blowdown64 water" as follows:"... from which the facilitywnthdrFiawlwithdraws cooling system make-up water and to whichit discharges blowdown water."65 3-54 Table 3-11 The scientific name for White sucker should be65_ _Catastomus commersoni, not "Catostomas" 2/12/2015 81Minor Updates, Corrections, and Clarifications onDraft Supplement 54 to the Generic Environmental Impact Statement for License Renewal of Nuclear Plants Regarding Byron Station, Units 1 and 2Where suggested changes to the SEIS are provided, they are highlighted with bolded italic font forinserted text and st"iko..--,,.

font for deleted text.Page Line Section Comment3-54 Table 3-11 In row 20 of Table 3-11 on page 3-54, "Notropis spilopterus" is listed as the scientific name for"spottail shiner."

This is incorrect because thescientific name for spottail shiner is actually Notropishudsonius (see DSEIS Table 3-12, p. 3-56). Itappears that the DSEIS author relied on the ByronOperating License Environmental Report (ComEd1981) for the entry of "Notropis spilopterus" in Table3-11 as the scientific name for spottail shiner.66 However, the Byron Operating LicenseEnvironmental Report was in error. In 1981, Notropisspilopterus was the scientific name for the spotfinshiner (rather than spottail shiner).

Furthermore, thespotfin shiner was reclassified and renamedCyprinella spiloptera circa 1990. So, it is nowimpossible to tell which species was actuallycollected at that time. Consider either deleting theerroneus row 20 from Table 3-11, or adding anexplanatory footnote.

3-58 Table 3-13 Several of the names in the "Common Name" columnare actually scientific names. Consider correcting thisas follows:* Change "lctiobinae spp." to "carpsuckers 67 and buffaloes."

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

" Change "Lepomids" to either "sunfish" (alarge group that also includes black bassand crappies) or "bream."3-64 40 to 42 3.8.1 The text in lines 40 to 42 on page 3-64 states that"As discussed in Section 3.7, the Rock River doesnot contain marine or anadromous fish species."

However, Section 3.7 contains no such discussion, although a reader knowledgeable about the68 distribution and life histories of all the fish specieslisted in Tables 3-11, 3-12, and 3-13 might infer thatno marine/anadromous species are present.

Toimprove clarity, consider explicitly stating in Section3.7 that the data in Tables 3-11, 3-12, and 3-13demonstrate that no marine/anadromous species arepresent in the Rock River.3-67 14 to 15 3.9.1 In lines 14 to 15 on page 3-67, consider deleting from69 the PDF file for the DSEIS the electronic hyperlinks to external web sites for "loway" and "Mascouten."

70 3-68 1 to 2 3.9.2 In lines 1 to 2 on page 3-68, consider explaining whythe cultural resource sites identified in Table 3-15 are2/12/2015 9Minor Updates, Corrections, and Clarifications onDraft Supplement 54 to the Generic Environmental Impact Statement for License Renewal of Nuclear Plants Regarding Byron Station, Units I and 2Where suggested changes to the SEIS are provided, they are highlighted with bolded italic font forinserted text and stik....-,,,

font for deleted text.Page Line Section Commentineligible for the NRHP. This could be accomplished by changing the sentence in lines 1 to 2 as follows:"All sites are ineligible for the NRHP because3-86 23 to 24 3.11.1 In lines 23 to 24 on page 3-86, change the word71 "environmental" to "environment" as follows:"... in the environmental that may ...3-87 13 3.11.2 In line 13 on page 3-87, change the phrase "site-72 specific chemical spill" as follows:"site-specific oil and chemical spill".3-87 20 3.11.3 On page 3-87, delete the words "Radioactive Waste"73 from the beginning of line 20, as follows:"Radioacttiv-Waste Nuclear plants that have3-90 22 3.12 On page 3-90, delete the words "Environmental 74 Justice" from the beginning of line 22, as follows:"EAVi-ronmontal J'-stico Under Executive Order (EO) 12898 ..."3-91 31 to 32 3.12.1 In lines 31 to 32 on page 3-91, consider revising thewords as follows:75 "... composed 23.7 percent of the totaltwethree-county population (see Table341-93-22)."

3-102 29 to 34 3.14 The version of the Byron Storm Water Pollution Prevention Plan provided to the NRC in response toRAI WR-SW-1 b [Exelon letter RS-13-282 to NRC,76 12/19/2013]

is dated January 2013 (rather than June2003). The citation for this document provided inlines 29 to 34 on page 3-102 (i.e., Exelon 2003)should be corrected accordingly.

4-14 15 to 16 4.3.5.1 Revise the sentence in lines 5 to 6 on page 4-14 toindicate that Illinois is included among the statescovered by CAIR, as follows:77 "The CAIR requires 27 states (including

Illinois, Indiana, Iowa, Michigan,

Missouri, Kentucky, and Wisconsin) to improve airquality,

...."4-15 41 4.3.5.2 In line 41 on page 4-16, delete the word"construction" as follows:78 "The NRC Staff concludes that cc~str'-rtopp operation-related noise impacts from theNGCC alternative would be SMALL."2/12/2015 10Minor Updates, Corrections, and Clarifications onDraft Supplement 54 to the Generic Environmental Impact Statement for License Renewal of Nuclear Plants Regarding Byron Station, Units 1 and 2Where suggested changes to the SEIS are provided, they are highlighted with bolded italic font forinserted text and .tik-tho,.h font for deleted text.Page Line Section Comment4-15 45 4.3.6 For consistency among the discussions of generating and and capacity for all alternatives, consider using "MWe"79 4-16 1, 4, & 9 instead of "MW" in line 45 on page 4-15 and lines 1,4 and 9 on page 4-16, when discussing thegenerating capacity of the proposed components ofthe Combination Alternative.

4-16 4 4.3.6 In line 4 on page 4-16, revise the phrase "The NGCC80 alternative" as follows:"The NGCC portion of the combination alternative".

4-16 5 4.3.6 In line 5 on page 4-16, revise the phrase "that sites81 would be located at" as follows:"... that sitesthe new unit would be locatedat ..."4-16 14 4.3.6.1 In line 14 on page 4-16, delete the word "that" as82 follows:approximately 10 percent kat-of theNGCC alternative" 4-17 7 4.3.6.1 In line 7 on page 4-17, revise the phrase "the NGCC83 alternative" as follows:... the NGCC portion of the combination alternative" 4-17 6 4.3.6.1 On p. 4-16, line 14, the NGCC component of thecombination alternative is characterized as having 1084 percent of the electrical output of the NGCCalternative, rather than 13 percent as indicated here(on page 4-17, line 6). Please resolve theinconsistency.

4-17 9 to 10 4.3.6.1 The possibility that the NGCC component of theCombination Alternative would have multiple unitsand multiple sites is introduced on page 4-17 in lines85 9 to 10. In contrast, the text on page 4-16, line 4,section 4.3.6.1, states that the NGCC component ofthe Combination Alternative would be one 267-MWunit. Please resolve the inconsistency.

4-18 23 4.3.6.2 In line 23 on page 4-18, consider deleting the86 redundant

sentence, as follows:"M.nor ..., o Gurce..could bo pipolinocomrofeseor statinns" 4-18 45 4.3.6.2 In line 45 on page 4-18, solar tracking devices areincluded in a list of potential noise sources for the87 solar PV portion of the combination alternative.

However, one advantage of PV solar compared toother solar technologies is that direct exposure tosunlight is not necessary for the PV panels to2/12/2015 11Minor Updates, Corrections, and Clarifications onDraft Supplement 54 to the Generic Environmental Impact Statement for License Renewal of Nuclear Plants Regarding Byron Station, Units 1 and 2Where suggested changes to the SEIS are provided, they are highlighted with bolded italic font for.inserted text and ..-t-,.u .font for deleted text.Page Line Section Commentfunction, which eliminates the need for solar tracking.

Accordingly, consider deleting solar tracking devicesas a potential source of noise in line 45 on page4-18.4-20 17 4.3.8 In line 17 on page 4-20, revise the phrase "... and88 expected to be SMALL" as follows:"... and are expected to be SMALL".4-20 17 to 18 4.3.8 In lines 17 to 18 on page 4-20, revise the phrase"... from operation of the IGCC, combination, and89 purchased power are expected

..." as follows:"... from operation of the IGCC, combination, and purchased power alternatives areexpected

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

4-23 2 4.5.1.1 In line 2 on page 4-23, consider revising the91 subsection title as follows for better consistency withother subsection titles within section 4.5.1.1:"Generic Surface Water Resources Issues"4-25 4 to 5 4.5.1.2 On page 4-25, revise the subtitle on lines 4 to 5 tomatch the words in Table 4-6, col 1, row 4,as follows:"Groundwater Use Conflicts (Plants UsiPg92 With Closed-cycle Cooling T-eweRFs-Cooling Ponds And Withdrawing ThatWithdraw Makeup Water From a SmellRiver)"4-27 11 4.5.3.1 In line 11 on page 4-27, revise the wording asfollows:"NRC staff expects that thatthe Statewould93 In addition, since the new nuclear alternative isprohibited in Illinois, consider providing a basis forthe expectation that the host state for the newnuclear plant would impose limits on surface waterwithdrawals similar to those imposed by Illinois onthe Byron Station.4-27 45 4.5.4.1 In line 45 on page 4-27, consider changing "use of94 the Byron site" to "use of an existing power plantsite".4-28 35 4.5.5.1 In line 35 on page 4-28, consider changing "use of95 the Byron site" to "use of an existing power plantsite".2/12/2015 12Minor Updates, Corrections, and Clarifications onDraft Supplement 54 to the Generic Environmental Impact Statement for License Renewal of Nuclear Plants Regarding Byron Station, Units 1 and 2Where suggested changes to the SEIS are provided, they are highlighted with bolded italic font forinserted text and -- font for deleted text.Page Line Section Comment4-29 24 4.5.6.1 In line 24 on page 4-29, consider replacing the words96 "alternative sites" with the words "another existingpower station site".4-30 35 4.5.7.2 In line 35 on page 4-30, consider replacing the words97 "for the other alternatives" with the words "for theproposed action as well as the other alternatives."

4-32 15 to 26 4.6.1.2 Since no other Chapter 4 author/section (excluding Cumulative

Impacts, Section 4.16) discusses steamgenerator replacement

impacts, consider deleting the98 text in lines 15 to 26 on page 4-32. Doing so wouldprovide an approach to the impact assessment insection 4.6.1.2 that is more consistent with othersections.

4-38 16 to 18 4.7.1.2 Consider changing the sentence in lines 16 to 18 onpage 4-38 as follows:"Thus Byron useswould have used between99 0.7 and 1.7 percent of the Rock River's floweach year for the past 12 years, under theconservative assumption that Byron wasoperating a 100 percent power at all times."4-38 24 to 26 4.7.1.2 Consider changing the sentence in lines 24 to 26 on100 page 4-38 to add mussels, as follows:"The fish and mussel species described inSection 3.7... do not appear to be affected

..."4-41 18 4.8.1 In line 18 on page 4-41, change the text as follows:101 "Appendix D4C. 1 contains information on theNRC staff's section 7 ..."4-50 25 to 32 4.10 The introductory paragraph to Section 4.10("Socioeconomics")

in lines 25 to 32 on page 4-50 isvery general and seems out of place. Considerdeleting the entire paragraph and replacing it with the102 following:

"This section describes the potential impacts of the proposed action (licenserenewal) and alternatives to the proposedaction on socioeconomic NEPA issues."4-53 25 4.10.3.1 Because the reference document (NRC 2008) wasnot authored by Exelon and does not address anExelon facility, the sentence in line 25 on page 4-53103 should be revised as follows:"EXeIGRlt has been estimated that theconstruction workforce for a new 2-unitnuclear plant would peak at 3,500 workers(NRC 2008)."2/12/2015 13Minor Updates, Corrections, and Clarifications onDraft Supplement 54 to the Generic Environmental Impact Statement for License Renewal of Nuclear Plants Regarding Byron Station, Units 1 and 2Where suggested changes to the SEIS are provided, they are highlighted with bolded italic font forinserted text and triko font for deleted text.Page Line Section Comment4-53 22 to 24 4.10.3.2 Consider including refueling outage workforce 104 increases among the causes of transportation impacts listed in lines 22 to 24 on page 4-53.4-54 22 to 23 4.10.4.2 In lines 22 to 23 on page 4-54, change the text as105 follows:"... the four-unit IGCC power p4aRtplant would consist of..."4-63 41 4.11.1.2 Because Section 5.3 does not discuss the results ofthe Staffs SAMA review, delete the sentence in line106 41 on page 4-63, as follows:"The rcsults of the review aro diccussedi 4-69 10 4.11.3 In line 10 on page 4-69, change the phrase "two new107 nuclear power plants" as follows:"... two new nuclear antunits4-69 11 4.11.3 In line 11 on page 4-69, consider changing the108 phrase "to those ofthe existing Byron" as follows:"... to those of operating the two existingByron units."4-69 14 4.11.3 In line 14 on page 4-69, change the words "theoperation of two new nuclear plants would be109 SMALL" as follows:"... the operation of two new nuclearplansunits would be SMALL."4-69 17 4.11.4 In line 17 on page 4-69, verify that the phrase"combustion-based renewable energy" is correct.110 Other than possibly biomass combustion, Exelon isunaware of any renewable energy sources that arecombustion-based, and section 4.11.4 does notaddress a biomass alternative.

4-69 21 4.11.4 For consistency with the assumption throughout theother sections in Chapter 4 that new construction 111 would be at an existing power plant site that might beeither nuclear or coal-fired, consider replacing thewords "existing nuclear plant" in line 21 on page 4-69with the words "existing power plant".4-69 28 to 29 4.11.4 Note that air pollution control equipment does notgenerate additional ash. Accordingly, considerchanging the words "equipment for controlling airpollution generates additional ash and scrubber112 sludge" in lines 28 to 29 on page 4-69 as follows:... equipment for controlling air pollution additional ash andproduces scrubber sludge, which must bemanaged as coal combustion wastes."2/12/2015 14Minor Updates, Corrections, and Clarifications onDraft Supplement 54 to the Generic Environmental Impact Statement for License Renewal of Nuclear Plants Regarding Byron Station, Units 1 and 2Where suggested changes to the SEIS are provided, they are highlighted with bolded italic font forinserted text and strikothr" font for deleted text.Page Line Section Comment4-83 19 to 41 4.13.4 and 4.13.5 As a clarification, consider noting in sections 4.13.4and 4.13.5 that the discussions of WasteManagement and Pollution Prevention for the IGCC113 and NGCC Alternatives focus solely on solid waste.Airborne waste is considered separately, under thesections on Air Quality, but is nevertheless a sourceof pollution.

4-86 27 4.15.1.2 The acronym "VOC" should be defined in line 27 on114 page 4-86 as well as in the list of Abbreviations andAcronyms on page xxxvii.4-89 14 to 15 4.15.3 Because the sentence in lines 14 to 15 on page 4-89inaccurately suggests that Byron's GHG emissions are linked in some considerable way to climatechange, consider revising the sentence as follows:"The following sections discuss GHG115 emissions released from operation of ByronStation-and-thep._They also discussenvironmental impacts that could generally occur from changes in climate conditions, although the significant contributory effects would come from other sourcesindependent of Byron Station."

4-89 21 4.15.3.1 The acronym "HFC" should be defined in line 21 on116 page 4-89 as well as in the list of Abbreviations andAcronyms on page xxxi.4-92 10 Table 4-22 On page 4-92, in the 2n, column (labeled "CO2e") ofTable 4-22, the entries in the rows titled "Byron117 Station continued operation" and "New Nuclear,"

should be changed from "1.363x0 03, to "1.363x1 04MT/year.4-104 26 to 29 4.16.4.6 To clarify the conclusions in section 4.16.4.6 (lines 26to 29 on page 4-104), consider inserting the words'although the only significant contributory effects inthe region would be from projects other than Byron118 Station" after the words "impacts to terrestrial resources" in line 29, as follows:"... impacts to terrestrial resources althoughthe only significant contributory effects in theregion would be from projects other thanByron Station."

4-111 25 to 27 4.16.11 Consider the following clarifying edits in lines 25 to27 on page 4-111:119 "As described in Section 4.15.3.1, operations at Byron Station emit GHG emissions directlyand indirectly.

Therefore, it is recognized that2/12/2015 15Minor Updates, Corrections, and Clarifications onDraft Supplement 54 to the Generic Environmental Impact Statement for License Renewal of Nuclear Plants Regarding Byron Station, Units 1 and 2Where suggested changes to the SEIS are provided, they are highlighted with bolded italic font forinserted text and &Hrk1tho-k font for deleted text.Page Line Section CommentGHG emissions from continued Byron Stationoperation may contribute to climate change,although the incremental contributions from Byron Station are insignificant incomparison to the contributions fromother sources."

Absent this clarification, the sentence is misleading interms of the overall impact of Byron Station.

Forexample, the GHG emissions from the NGCCalternative exceed those from the operation of ByronStation by approximately 500 times. As anotherexample, the GHG emissions from Byron employeevehicles are comparable to the remaining ByronStation emissions.

If those employees werecommuting to a different

location, the GHG emissions would be unlikely to change significantly.

4-112 29 to 31 4.16.11 To clarify the conclusions in section 4.16.11, considerinserting the words "although the impacts will beoverwhelmingly due to other projects around theworld independent of Byron Station" after the word120 "MODERATE" in line 31 on page 4-112, as follows:"... would be MODERATE, although theimpacts will be overwhelmingly due toother projects around the worldindependent of Byron Station."

2/12/2015 16Minor Updates, Corrections, and Clarifications onDraft Supplement 54 to the Generic Environmental Impact Statement for License Renewal of Nuclear Plants Regarding Byron Station, Units 1 and 2Where suggested changes to the SEIS are provided, they are highlighted with bolded italic font forinserted text and rtFkth, ouoh font for deleted text.... ... ... .. ... ....... .... _ ,7 1.. ..... ... .... .. te x.. ..Page Line Section CommentConsider changing the sentence in lines 22 to 24 onpage F-1 as follows:"Exelon submitted all 18 potentially cost-121 F-i 22 to 24 F.1 beneficial SAMAs to the Byron Plant HealthCommittee for further implementation consideration in accordance with currentByron processes and procedures forevaluating possible plant modifications."

To improve clarity, revise the sentence in lines 43 to45 on page F-1 as follows:"However, Exelon determined that the otherSAMA would not be cost-beneficial if-givenExelon's possible implementation of122 F-1 43 to 45 F. 1 another SAMA that addresses insights fromthe Fukushima Daiichi accident and which, ifimplemented, were implemented sincoe itwould mitigate many of the largestcontributors to the Byron severe accidentrisk."In line 16 on page F-2, insert the words "a factor of'between the word "by" and the number "2.5" as123 F-2 16 F.2.1 follows:... by multiplying the estimated benefits forinternal events by a factor of 2.5."The sentence in lines 9 to 11 on page F-5 appearsto be incomplete.

Consider revising it as follows:"The NRC staff review concluded that, whileExelon did not provide a definition ofvulnerability, Exelon identified one 'potential vulnerability' and one enhancement-were."

In line 34 on page F-8, define the acronym "AP" as1 2 5 F -8 3 4 F .2 .2 .1 " u ii r o e ""auxiliary power".To improve clarity, consider revising the sentence inlines 31 to 33 on page F-9 as follows:126 F-9 31 to 33 F.2.2.1 "This requirement results from SWVs servicewater being taken from Lake Michigan, thewhesepwatt&

temperature of which variesthroughout the year."2/12/2015 17Minor Updates, Corrections, and Clarifications onDraft Supplement 54 to the Generic Environmental Impact Statement for License Renewal of Nuclear Plants Regarding Byron Station, Units 1 and 2Where suggested changes to the SEIS are provided, they are highlighted with bolded italic font forinserted text and trketho-u-;

font for deleted text.Page Line Section CommentConsider revising the sentence in lines 4 to 5 onpage F-10 as follows:"The Byron IPEEE was submitted inDecember 1996 (CoinEd 1996), in response127 F-10 4to5 F.2.2.2 to Supplement 4 of GL 88-20 (NRC 1991),which requested that each power reactorlicensee identify and report to the NRCplant-specific vulnerabilities to severeaccidents caused by external events."Consider revising sentences in lines 34 to 35 onpage F-10 as follows:"The majority of the outliers involved seismicinteraction concerns that were resolvedthrough seie appropriate licensee128 F-10 34 to 35 F.2.2.2 corrective actions.

Others were resolvedeither by Conservative Deterministic FailureMargin capacity analysis that te showed thatthe seismic capacity substantially exceeded the-wellbeyeREd review-level earthquake demand, or by maintenance ormodifications."

Consider revising the sentence in lines 13 to 16 onpage F-16, as follows:"In response to an NRC staff RAI, Exelonstated that the input for the MAAP casesspecified the fission product masses (asopposed to radionuclide activity values)as recommended by the MAAP Users GroupBulletin, "MAAP-FLASH

1. 68" (Exelon 2014)."Consider revising the sentences in lines 23 to 27 onpage F-20 as follows:"Standardized Ggeneric economic datainputs that isare applied to the region as awhole were obtained from NUREG-1 150 (asreflected in the MACCS2 Sample ProblemA). NUREG-1150 is a seminal, peer-130 F-20 23 to 27 F.2.2.4 reviewed work in PRA performed by theNRC and the national laboratories thatincludes a Level 3 PRA for five different reactor sites. The NUREG-1150-based inputs were rovi-od from the MACCS2sample problem input in erderadjusted toaccount for cost escalation since 1986, theyear that the inputs waswere first specified."

2/12/2015 18Minor Updates, Corrections, and Clarifications onDraft Supplement 54 to the Generic Environmental Impact Statement for License Renewal of Nuclear Plants Regarding Byron Station, Units 1 and 2Where suggested changes to the SEIS are provided, they are highlighted with bolded italic font forinserted text and etd~keh..ueh font for deleted text.Page Line Section CommentConsider revising the sentence in lines 13 to 15 onpage F-22 as follows:"Exelon also provided in the ER tabularlistings of the Level 2 PRA basic events for131 F-22 13 to 15 F.3.2 the combined LERF categories and thecombined Late Release categories, which intotal Rentreb'-te account for approximately 95 percent of the estimated population doserisk and OECR.Consider inserting the following new sentence in line2 on page F-22 after the first sentence on the page:"The RRW is the factor by which the risk132 F-22 1 to 2 F.3.2 would decrease if the component, train,system, function, initiating event, or HEPis assumed to be perfectly reliable (i.e., ifits probability of failure were zero)."Consider revising the sentence in lines 42 to 45 onpage F-22 as follows:"Since Exelon already includes providing forportable ventilation in plant procedures and,as discussed further below, is committed 133 F-22 42 to 45 F.3.2 to installing the "no-leak" RCP seals, theNRC staff concludes that this possiblealternative SAMA, to provide portableventilation during maintenance activities, hasbeen adequately explored and is unlikely tobe cost-beneficial."

134 F-24 42 F.3.2 In line 42 on page F-24, change "Bryon" to "Byron."The text in lines 18 to 22 on page F-27 is redundant to the text on lines 4 to 9 on page F-27. Accordingly, consider deleting it, as follows:"Ewclon's SAA I1- Q process .icudedroiveing insights from the plant specifiG Fiskstudies, and rovieWing plant improvomnt 1 3 5 F -2 7 1 8 to 2 2 F .3 .2 c on sid e re d in p. .......... .n.. .While explicit treat_;#men U t oVf oxrnal oIVntSinthe SAMA identification prcess war, limitod,the NlRC s-taff deter~mined that the priorimplementation of plant moedificattaionis aind thleabsence of external event vulnerabilite reasonably jUstify examining prim~arilyth

______ ___internal events risk results forF this-purpose."

2/12/2015 19Minor Updates, Corrections, and Clarifications onDraft Supplement 54 to the Generic Environmental Impact Statement for License Renewal of Nuclear Plants Regarding Byron Station, Units 1 and 2Where suggested changes to the SEIS are provided, they are highlighted with bolded italic font forinserted text and o font for deleted text.Page Line Section CommentConsider revising the sentence in lines 24 to 25 onpage F-38 as follows:"Exelon divided this cost element into two136 F-38 24 to 25 F.6 parts-the averted onsite cleanup anddecontamination cost (ACC) alse eeemmcnyreferred to 3s ACC, and the avertedreplacement power cost (RPCJ."Consider revising the sentence in lines 38 to 40 onpage F-42 as follows:"Exelon has indicated that all 18 potentially cost-beneficial SAMAs will be submitted to137 F-42 38 to 40 F.7 the Byron Plant Health Committee for furtherimplementation consideration in accordance with current Byron processes andprocedures for evaluating possible plantmodifications."

Consider changing the title of SAMA 16 in Table F-5138 F-31 STable F- on page F-31 as follows:

"16 -Install high flowSAMA 16, sensors on the p RXnon-essential service waterSAMA Title system (WS)"Consider changing the text in Table F-5 describing 139 F-31 SAMA 16, Table F-5 the modeling assumptions for SAMA 16 as follows:modeling "Completely eliminates all risk associated assumptions with SWWWS flood event scenarios" 2/12/2015 Gallagher, CarolFrom:Sent:To:Cc:SubjectAttachnJames, LoisWednesday, February 25, 2015 9:35 AMBladey, CindyGallagher, CarolSubmitting Comments to NRC-2013-018 nents: 017 -Exelon cover memo for informal comments.pdf Cindy,Attached are comments that Exelon submitted on the Byron DSEIS, NRC-2013-018.

Can you add thisto the Regulations.gov docket for NRC-2013-0178?

Thank youLois M. James, Senior Environmental Project ManagerDivision of License RenewalOffice of Nuclear Reactor Regulations lois.iames@nrc.gov (preferred method of communication) 301-415-3306 I