ML18330A157

Subsequent License Renewal Environmental Requests for Additional Information

ML18330A157
Person / Time
Site:	Peach Bottom
Issue date:	11/23/2018
From:	Hayes B NRC/NRR/DMLR/MRPB
To:	Gallagher M Exelon Generation Co
Hayes B, NRR-DMLR 415-7442
References
EPID L-2018-RNW-0013
Download: ML18330A157 (10)

Text

From: Hayes, Barbara Sent: Friday, November 23, 2018 3:53 PM To: michaelp.gallagher@exeloncorp.com Cc: Ranek, Nancy L.:(GenCo-Nuc);

Gibson, Lauren; Drucker, David; Oesterle, Eric; Beasley, Benjamin;Hoffman, Robert; Martinez, Nancy; Ford, William; Folk, Kevin; Moser, Michelle; Rautzen, William;Grange, Briana; Rikhoff, Jeffrey; Young, Mitzi; Gamin, Kayla; Tobin, Jennifer; Wilson, George;Donoghue, Joseph; Burnell, Scott; Sheehan, Neil; Screnci, Diane; Weil, Jenny; Tifft, Doug; Heinly, Justin; Burkhart, Lawrence

Subject:

PEACH BOTTOM ATOMIC POWER STATION, UNITS 2 AND 3, SUBSEQUENT LICENSE RENEWAL ENVIRONMENTAL REQUESTS FOR ADDITIONAL INFORMATION (EPID L-2018-RNW-0013)

Dear Mr. Gallagher:

The U.S. Nuclear Regulatory Commission (NRC) is reviewing the Exelon Generation Company, LLC (Exelon) application for subsequent renewal of the operating licenses for Peach Bottom Atomic Power Station, Units 2 and 3 (Peach Bottom). As part of the environmental review, an environmental site audit was conducted at Peach Bottom, by NRC staff, on November 7 and 8 , 2018. As a result of the audit and the NRC staff's review of the Peach Bottom environmental report, staff has identified areas where additional information is needed to complete the review. The enclosure lists the environmental requests for information (RAIs)and the RAIs are also provided below. Please provide the responses 30 days from the date of this e-mail. If you have any questions, please contact me by telephone at 301-415-7442 or by e-mail at Barbara.Hayes@nrc.gov

. Sincerely,

Barbara Hayes, Project Manager License Renewal Projects Branch Division of Materials and License Renewal Office of Nuclear Reactor Regulation Docket Nos. 50-277 and 50-278

Enclosure:

Environmental Requests for Additional Information cc w/encl: Distribution via Listserv OFFICE PM: MRPB:DMLR PM:MRPB:DMLR BC:MRPB:DMLR (A)BC:MENB:DMLR PM:MRPB:DMLR NAME Bhayes DDrucker BBeasley EOesterle BBeasley for:)BHayes DATE 11/16/18 11/16/2018 11/23/2018 11/23/2018 11/23/2018 OFFICIAL RECORD COPY Enclosure PEACH BOTTOM ATOMIC POWER STATION, UNITS 2 AND 3 SUBSEQUENT LICENSE RENEWAL ENVIRONMENTAL REQUESTS FOR ADDITIONAL INFORMATION Alternatives, Replacement Power (AL) RAI-AL-1: Please provide the basis used to estimate the air quality emissions values presented in the Environmental Report (ER) Section 7.2.3.1 (Natural Gas-Fired Generation) and Section 7.2.3.2 (Coal-Fired Generation).

RAI-AL-2: Has Exelon Generation estimated the cooling water make-up and consumptive water use associated with the Natural Gas-Fired, Coal-Fired, and Small Modular Reactor alternatives presented in ER Sections 7.2.3.1, 7.2.3.2, and 7.2.3.4, respectively?

If yes, please identify these estimates and the basis used to determine them. Air Quality and Meteorology (AQ) RAI-AQ-1: Section 3.2 of the ER discusses three instrumented meteorological towers supporting the PBAPS site:

Tower 2, the River Tower, and the Hill Pole.

Please clarify the current purpose, status, and instrumentation associated with each of these towers.

RAI-AQ-2: Please provide the actual PBAPS air emissions of pollutants listed in ER Table 3.2-1 for the most recently-available 5-year period.

Reconcile any inconsistencies between actual/calculated air emissions and potential emission values presented in ER Table 3.2-1, as discussed between NRC and Exelon staff during the onsite environmental audit.

Aquatic Resources (A) RAI-A-1: Section 2.2.3 of the ER describes a high-pressure spray back-wash system that may allow some impinged or entrapped fish to return to Conowingo Pond.

Please clarify whether a fish handing and return system exists near the inner or outer intake structure or within the intake canal. In addition, please clarify whether fish can travel from the intake canal back to Conowingo Pond through the discharge canal or any other swimmable route.

RAI-A-2: Section 2.2.3 of the ER describes traveling screens on the inner and outer intake structures. The ER also provides information regarding the mesh size, the approach velocity, and the through-screen velocity for the traveling screens on the outer intake structure. Please describe the mesh size, the approach velocity, and the through-screen velocity for traveling screens on the inner intake structure.

RAI-A-3: Section 4.6.2.1 of the ER states that Exelon's September 22, 2014, National Pollutant Discharge Elimination System (NPDES) permit lists conditions with which Peach Bottom Atomic Power Station (PBAPS) must comply during the permit's term to meet best technology available standards for the cooling water intake structure, including protection of "fragile species." Some of these conditions provide options for Exelon to select from. For example, the following are the conditions that address impingement and entrainment:

"A. The PBAPS cooling water intake structures must meet BTA [best technology available] standards for impingement mortality by employing one of the alternatives in 40 CFR §125.94(c)(1) through (c)(7). Additional measures may be required to protect federal or state threatened and endangered species and fragile species."

Please describe which of the alternatives in 40 CFR §125.94(c)(1) through (c)(7)

Exelon has selected to implement since 2014.

RAI-A-4: Describe future activities that Exelon anticipates conducting associated with its post-extended power uprate (EPU) biological and thermal study. In addition, describe any activities associated with these studies that have been completed since the ER was prepared. Please provide documentation if the Pennsylvania Department of Environmental Protection (PADEP) has approved any changes to the conditions within the NPDES permit as it was described in the ER.

RAI-A-5: Discuss whether Exelon is aware of any previous fish kills (from cold or heat shock) or other unusual events that have occurred within the vicinity of the discharge structure and thermal plume.

Groundwater Resources (GW) RAI-GW-1: Sections 2.2.3 and 3.5.2 of the ER provide estimates of the volume of water produced by PBAPS's four active onsite groundwater supply wells as well as the volume of groundwater collected and conveyed by the plant's three drain sumps.

Clarify and/or describe the following:

a. The operational status of the on-site wells and sumps and their pump capacities.

b. If production data is collected for the on-site wells and sumps, provide a summary (by month or other averaging period) of the estimated volume of groundwater withdrawn by the wells or collected in sumps and discharged over the last 5 years (2014-2018 YTD). RAI-GW-2: Sections 3.5.2.3 and 4.5.2.4 of the ER provide a summary and an assessment, respectively, of historic inadvertent releases of radionuclides to groundwater and which include groundwater protection monitoring results that are reported in Exelon's annual radiological environmental operating reports.

Provide a description of any documented inadvertent radiological releases (leaks or spills of liquids containing licensed material) that have occurred since December 2017.

Describe the impact on the environment, if any, identify affected monitoring wells or sumps, and provide a summary of radionuclide concentrations in nearby monitoring wells, sump drains, and surface water stations as appropriate from the date of discovery of the release to the present.

Also, i nclude a description of any related ongoing or completed corrective actions taken.

RAI-GW-3: Section 2.2.5.1 of the ER, in part, describes the operation of the plant's liquid radwaste system including the discharge pipeline for conveying monitored liquid radwaste effluent to the discharge canal.

Summarize the average volume and frequency of discharge and identify the presets for flow and radiation for automatic shut-off.

Also, briefly describe any major modifications to the pipeline since initial license renewal.

RAI-GW-4: Section 9.1 of the ER summarizes Exelon's status of compliance with applicable environmental regulatory requirements governing plant operations.

Provide a summary of any Notices of Violation (NOVs); nonconformance notifications; or related infractions received from regulatory agencies associated with permitted discharges, sanitary sewage systems, groundwater or soil contamination, as well as any involving spills, leaks, and other inadvertent releases (e.g., petroleum products, chemicals, or radionuclides) received over the last five years (2014-2018 YTD).

Provide copies of relevant correspondence to and from the responsible regulatory agencies involving the referenced notifications or that have involved reportable spills, leaks, etc.

RAI-GW-5: Provide copies of the annual water withdrawal reports (for 2014-2017) submitted to the Susquehanna River Basin Commission as required under Docket 20061209-1, Standard Condition 4.

Clarify whether Exelon has registered and reports all on-site surface water and groundwater withdrawals to the Pennsylvania Department of Environmental Protection in accordance with 25 PA Code 110.201 and as specified in SRBC Docket Standard Condition 8.

If so, please provide copies of supporting documentation.

RAI-GW-6: Sections 2.2.6 and 3.5.1.3.2 of the ER reference the plant's sanitary wastewater discharges.

Clarify whether Peach Bottom has any facilities served by septic fields.

If so, summarize the locations and briefly describe how the septic system(s) are operated and maintained.

RAI-GW-7: Provide the following documents:

a. Latest site hydrogeologic investigation report (2018), excluding appendices F through J b. Water balance/flow diagram for the plant (e.g., from the latest NPDES permit renewal application)

Historic and Cultural Resources (HC) RAI-HC-1: Section 3.7.2 of the ER states that Exelon maintains records that "indicate that no historic landscape, traditional cultural property, or archaeological sites have been identified at the PBAPS site since the time of its construction, and confirm that no potentially significant artifact deposits have ever been documented within the present APE".

Provide a copy of these records.

RAI-HC-2: Section 3.7.2 of the ER states that there are structures associated with PBAPS Units 1, 2 and 3 that will exceed 50 years of age during the subsequent license renewal (SLR) term.

Identify and describe these structures.

Additionally, provide the current age of the structures and how the age was determined (e.g., commencement of operation, end of construction, etc.).

RAI-HC-3: The ER states that "appropriate consideration will be given to the historic significance of the Unit 1 structures at the time of Unit 1 decommissioning."

Will a NRHP eligibility evaluation be conducted by Exelon for Unit 1 as well as Units 2 and 3 prior to decommissioning? How will Exelon ensure that the Units are maintained and not dismantled prior to proper historic significance consideration?

RAI-HC-4: Section 4.7 of the ER states that Unit 1 "entered SAFSTOR mode in 1978, with continued surveillance, security, and maintenance-" Describe actions that Exelon has taken to maintain the physical and historic integrity of Unit 1.

RAI-HC-5: Section 3.7.2 of the ER states that the Peach Bottom property was evaluated by an archeologist in 1972.

Identify the areas that were evaluated by the archeologist and what percentage of the Peach Bottom site property was evaluated.

RAI-HC-6: Approximately what percentage of the Peach Bottom property has been disturbed?

Microbiological Hazards (MH) RAI-MH-1: Section 2.2.3 of the ER states that Exelon controls the accumulation of deposits and biofouling organisms in the condensers through the regular use of an on-line condenser cleaning system and dosages of chlorine. The ER also states that Exelon's NPDES permit limits the discharge of Total Residual Chlorine concentration in the permitted outfall to 0.20 milligrams per liter (mg/L) (instantaneous maximum).

Please describe the general dose frequency and average concentration of chlorine that is released into Conowingo Pond.

RAI-MH-2: Section 3.6.1.3 of the ER states that Exelon controls non-native aquatic species by applying biocides, in accordance with its current NPDES permit.

Please describe the general frequency that Exelon applies biocides and the average concentration that is released into Conowingo Pond.

RAI-MH-3: Section 4.9.1 of the ER states that the Exelon continually disinfects PBAPS's sewage effluent. Please describe the general frequency of disinfection activities and the type and amount of disinfectants that are released into Conowingo Pond. RAI-MH-4: Legionellosis outbreaks are often associated with complex water system houses inside buildings or structures, such as cooling towers. Describe any procedures, measures, or best management practices that would minimize the risk for workers to come into contact with Legionella.

Site Procedures Relevant to Environmental Impacts (SP) RAI-SP-1: In several instances, the ER (e.g., Section 3.7.2, p. 3-62; Section 4.6.1.1, p. 4-29; Section 4.6.3, p.

4-42; etc.) states that existing site procedures provide a process for screening proposed activities to determine if environmental impacts will occur that would require further evaluation.

a. Briefly summarize the following site procedures: 1)

EN-AA-103, "Environmental Review"; 2) EN-AA-103-0001, "Environmental Evaluations"; and 3) SA-AA-117,"Excavation, Trenching, and Shoring". Include the associated actions and describe how these procedures ensure that environmental impacts are appropriately addressed prior to beginning work or during projects that involve land-disturbing activities that could affect previously unidentified archaeological or historic resources, that could disturb or degrade terrestrial or aquatic habitats, or that could otherwise result in environmental impacts.

b. How does Exelon ensure that personnel or consultants conducting land-disturbing activities or other activities that could result in environmental impacts are aware of site procedures and what actions those procedures require them to take?

Socioeconomics (SOC) RAI-SOC-1:

Section 3.8.1.1 of the ER provides property tax payment and payments in addition to tax (PATs) Exelon makes to taxing authorities.

The ER states that in 2012, Exelon Generation and the taxing authorities agreed to extend a 2008-2012 settlement agreement, which included PATs to each local taxing body, to cover tax years 2013 to 2017.

a. Has there been new or additional settlement agreements between Exelon and taxing authorities that cover the tax years beyond 2017?

If a settlement agreement has been reached, provide a summary of the agreement.

If a settlement agreement has not been reached, please provide a brief summary of the status of ongoing negotiations or dialogue concerning a potential agreement.

b. Are there any potential future tax payment adjustments anticipated during the SLR period? If known, please provide future tax payment adjustments.

RAI-SOC-2:

The ER and Tables 3.8-6 and 3.8-7 identify that Exelon pays PATS and/or real estate tax to York County, South Eastern School District, Peach Bottom Township, Lower Chanceford Township, and Red Lion School District.

Peach Bottom Units 2 and 3 are located in York County within Peach Bottom Township and the South Eastern School District serves Peach Bottom Township.

Clarify if and why Exelon pays real estate tax to Lower Chanceford Township and Red Lion School District as a result of operations of Units 2 and 3.

If not: a. Discuss why real estate tax payments to the Lower Chanceford Township and Red Lion School District were included in Tables 3.8-6 and 3.8-7.

b. Revise Tables 3.8-6 (last row, "Approximate 2016 Peach Bottom Real Estate Taxes and PAT (% of 2016 Property Tax)") and Table 3.8-7 of the ER to reflect property tax paid to York County, South Eastern School District, and Peach Bottom Township as a result of Units 2 and 3.

RAI-SOC-3:

Table 3.8-7 lists "TBD" for 2017 Tax Paid. Is the 2017 Tax Paid and Total Tax & PAT information available as a result of operation of Units 2 and 3? If so, please provide.

RAI-SOC-4:

Table 3.8-7 provides a School District PAT (2 nd column). Identify the school district(s) the PAT is provided to.

RAI-SOC-5:

Identify the source/reference for the local real estate tax revenue information presented in Table 3.8-6 of the ER for Peach Bottom Township and Lower Chanceford Township.

RAI-SOC-6: Besides property tax payments and PATs, describe any other sizeable annual support payments (e.g., emergency preparedness fees and payments or fees because of the independent spent fuel storage installation), one-time payments, or other forms of non-tax compensation (if any) provided to local organizations, communities, and jurisdictions on behalf of PBAPS.

Special Status Species and Habitats (SS)

RAI-SS-1: In Appendix C of the ER, Exelon includes Pennsylvania Natural Diversity Inventory Environmental Review Tool results related to the proposed Peach Bottom SLR.

On page 4 of these results, Exelon states that the project will affect 1 to 39 acres of forests, woodlots, and trees in response to Q5: "The propose project is in the range of the Indiana bat. Describe how the project will affect bat habitat (forests, woodlots, and trees) and indicate what measures will be taken in consideration of this. Round acreages up to the nearest acre (e.g., 0.2 acres = 1 acre)."

a. Further describe the impacts to forests, woodlots, and trees that would result from site maintenance, hazardous tree removal, and other potential impacts during the proposed SLR term.

b. Clarify how many acres of forests, woodlots, and trees Exelon anticipates would be affected during the proposed SLR term.

c. Describe any applicable procedures and/or best management practices that Exelon maintains that would minimize or eliminate potential impacts to bats during hazardous tree removal and other site maintenance activities that affect trees or forested areas.

RAI-SS-2: With respect to the bog turtle, confirm that Exelon, its personnel, or contractors have not identified any onsite wetlands beyond those that were assessed during the August 2017 Phase 1 bog turtle habitat survey contained in Appendix C of the ER.

RAI-SS-3: With respect to the Chesapeake logperch (Percina bimaculata

)which is under review by the U.S. Fish and Wildlife Service, the ER (Section 4.6.3, p. 4-42) states that in 2016, four individual Chesapeake logperch larvae were collected in entrainment abundance sampling that Exelon is currently conducting pursuant to the Clean Water Act Section 316(b) requirements in the Peach Bottom NPDES permit.

Describe whether any additional Chesapeake logperch have been collected in 316(b) sampling since development of the ER.

Include the life stage and condition (i.e., alive, injured, or dead) for any collected individuals.

RAI-SS-4: The ER (Section 4.6.2.1.3, p. 4-35 and Section 4.6.3, p. 4-43) states that a final decision regarding additional measures to protect federally listed, State-listed, and fragile species will be made in consultation with the Pennsylvania Department of Environmental Protection and the U.S. Fish and Wildlife Service in the context of the next Peach Bottom NPDES permit renewal process. Please describe the current timeline for the NPDES permit renewal and any current discussions with the State or the U.S. Fish and Wildlife Service regarding federally listed, State-listed, and fragile species.

Terrestrial Resources (T) RAI-T-1: The ER (Section 3.6.2.3.2, p. 3-52) references the "Atom Woods Road Site" and "Peach Bottom Woods Site" when describing the occurrences of several State-listed or rare species within the footprint of the Peach Bottom site.

These sites are further described in the York County Natural Areas Inventory (ER reference "YCPC 2004").

a. Describe where these sites lie in relation to the entire Peach Bottom site footprint.

Provide a map depicting these area, if available.

b. Does Exelon actively manage these areas for conservation or restoration purposes?

c. Does Exelon anticipate any land or ground disturbances to these area during the proposed SLR term?

RAI-T-2: The Natural Resources Conservation Service identifies the following 12 invasive plants in Pennsylvania as noxious weeds, which are plants that directly or indirectly cause damage to crops, livestock, irrigation, navigation, the public health, or other natural resources:

a. musk thistle (Carduus nutans

)b. Canadian thistle (Cirsium arvense

)c. bull thistle (Cirsium vulgare

)d. jimsonweed (Datura stramonium

)e. goatsrue (Galega officinalis

)f. giant hogweed (Heracleum mantegazzianum

)g. purple loosestrife (Lythrum salicaria

)h. mile-a-minute (Polygonum perfoliatum

)i. kudzu-vine (Pueraria montana

)j. multiflora rose (Rosa multiflora

)k. shattercane (Sorghum bicolor

)l. johnsongrass (Sorghum halepense

) Is Exelon aware of the occurrence of any of these plants on the Peach Bottom site? If so, does Exelon actively perform maintenance to control any of these plants?

RAI-T-3: Please identify and describe the various environmental stewardship or habitat enhancement initiatives that Exelon has undertaken or plans to undertake on the Peach Bottom site, such as the white-tailed deer management program; initiatives to benefit native pollinators, nesting roosts for raptors; nesting boxes for various waterfowl and songbirds; wildlife food plots within transmission line rights-of-way; etc.

These initiatives may be formal or informal.

RAI-T-4: Describe Exelon's hunting program for the Peach Bottom site, including what year the program was initiated; the purpose of the program; the typical length of the hunting season; hunter permit requirements and limits; and any changes in natural habitats that Exelon has observed over time as a result of implementing the program. RAI-T-5: Please answer the following questions related to Exelon's Wildlife Habitat Council certification for the Peach Bottom site.

a. What programs or initiatives has Exelon undertaken related to this certification?

b. What are the effective dates of the current certification period?

c. Does Exelon intend to maintain certification during the proposed SLR term?

Waste Management (WM) RAI-WM-1: Peach Bottom is subject to the reporting provisions of 40 CFR Part 110 as it relates to the discharge of oil in such quantities as may be harmful pursuant to Section 311(b)(4) of the Federal Water Pollution Control Act. Any discharges of oil in such quantities that may be harmful to the public health or welfare or the environment must be reported to the National Response Center. For the time period of 2013-2018, were there any reportable spills? If so, please provide a description of any spills.

RAI-WM-2: Peach Bottom is subject to the reporting provisions of Pennsylvania Department of Environmental Protection Regulatory Code, 25 PA Code Chapter 245, which requires that reportable releases of oils and other similar hazardous substances be reported to the Pennsylvania Department of Environmental Protection.

For the time period of 2013-2018, were there any reportable spills? If so, please provide a description of any spills.

RAI-WM-3: In Section 2.2.2 of the ER, Exelon states that the Independent Spent Fuel Storage Installation (ISFSI) storage pad is projected to be full by the year 2020.

While spent fuel storage expansion is expected regardless of SLR, please provide the current plan to address ISFSI expansion and future spent fuel storage in general.

RAI-WM-4: Please provide the latest complete Offsite Dose Calculation Manual.