ML101810091

Request for Additional Information Related to the Environmental Site Audit for Columbia Generating Station License Renewal

ML101810091
Person / Time
Site:	Columbia
Issue date:	07/08/2010
From:	Dan Doyle License Renewal Projects Branch 1
To:	Oxenford W Energy Northwest
Doyle D, NRR/DLR, 415-3748
References
TAC ME3121
Download: ML101810091 (11)

Text

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 July 8,2010 Mr. W.S. Oxenford, Vice President, Nuclear Generation and Chief Nuclear Officer Columbia Generating Station Energy Northwest MD PE08 P.O. Box 968 Richland, WA 99352

SUBJECT:

REQUEST FOR ADDITIONAL INFORMATION RELATED TO THE ENVIRONMENTAL SITE AUDIT FOR COLUMBIA GENERATING STATION LICENSE RENEWAL (TAC NO. ME3121)

Dear Mr. Oxenford:

By letter dated January 19, 2010, Energy Northwest submitted an application pursuant to Title 10 of the Code of Federal Regulations Part 54 (10 CFR Part 54), to renew Operating License NPF-21 for Columbia Generating Station for review by the U.S. Nuclear Regulatory Commission (NRC or the staff). The staff is reviewing the information contained in the license renewal application and the associated Environmental Report. An environmental site audit was conducted June 8-10,2010. Enclosure 1 is the list of audit needs that was requested by the NRC prior to the audit. The NRC requests that certain documents that were reviewed during the site audit, as identified in enclosure 2, be submitted by Energy Northwest to the staff for further review.

The items in enclosure 2 were discussed with Mr. Abbas Mostala. A mutually agreeable date for the response is within 30 days from the date of-this letter. If you have any questions, please contact me at 301-415-3748 or bye-mail at daniel.doyle@nrc.gov.

Sincerely, Daniel Doyle, Project Manager Projects Branch 1 Division of License Renewal Office of Nuclear Reactor Regulation Docket No. 50-397

Enclosure:

As stated cc w/encl: Distribution via Listserv

AUDIT NEEDS SUBMITTED APRIL 30, 2010 Health Physics HP-1. Information on any abnormal, unusual spills, and leaks of radioactive material that occurred onsite that are applicable to the criteria in 10 CFR 50.75(g) and NEI 07 07, "Industry Ground Water Protection Initiative - Final Guidance Document" HP-2. Information on anyon-site disposals of low-level radioactive waste HP-3. Information on the radiological groundwater protection program HP-4. Tour to cover the following:

a. Low-level radioactive waste storage

b. Radioactive effluent release points

c. Radioactive effluent monitoring systems

d. Radiological environmental monitoring stations (air monitoring stations, including any co-located state monitoring stations)

Terrestrial All requests for information regarding transmission line rights-of-way (ROWs) assume that the following transmission lines are included in the proposed action

• The 500-kV line between SPA's Ashe Substation and the Hanford Substation 17.5 miles to the northwest (pp 3-11 and D-13 of the ER)

• 230-kV line that shares the 500 kV ROW for 7.25 miles and then runs north for about 2.5 miles (described on page D-13 of the ER)

• 115-kV backup power source for safe shutdown under accident conditions (pp 3-11 and D-13 of the ER)

• 0.5 mile segment of the 230-kV and 500-kV lines between the power plant and Ashe substation (pp 3-11 and D-13 of the ER)

TE-1. Please provide any aerial photos and topographic maps you have of the ROWs.

Specifically, topographic maps of the site and in-scope transmission line segments that show any significant natural heritage areas, stream crossings, historical sightings of endangered species, and migratory bird rookeries. Additionally, please provide percentages of terrestrial communities on site (e.g. 20% of the site is forest habitat).

TE-2. Please provide the in-scope transmission line ROW maintenance plans and the names of any ROW maintenance contractors.

TE-3. What pesticides and/or herbicides are used onsite or within the in-scope transmission line ROWs? What protocol do contractors follow when applying chemicals near ENCLOSURE 1

- 2 streams and wetlands? Are there any special procedures used in areas that contain species of concern (federal or state) or habitats identified as unique, rare, or a priority for protection by Native American tribal agencies?

TE-4. Have surveys for state and/or federal threatened and endangered species been conducted within the transmission line ROWs?

TE-5. During the transmission line tour, NRC staff would like to see representative examples of ROW land, including stream and wetland crossings (if applicable).

TE-6. Please provide any information on any bird strikes (including birds of prey and migratory birds) that have occurred at the reactor building, the meteorological tower, or along the in-scope transmission line ROWs. Provide a description of reporting procedures for raptor and other bird strikes at transmission lines and cooling towers.

TE-7. Please provide any wildlife management plans used on site.

TE-8. Please provide any best management procedures followed for ground-disturbing activities and activities that could disturb nesting migratory birds.

TE-9. Have any invasive species been seen or documented on the site or in the transmission line ROWs? Are any invasive species populations being managed. or have any been managed in the past?

TE-10. Please provide any information on wildlife use of the onsite ponds (described on pages 2-22 and 3-9 of the ER)

• Unlined evaporation/percolation pond

• Sanitary Waste Ponds

• Outfall 003 Hydrology & Water Quality HY-1. Discharge Monitoring Reports for the last 6 months Aquatic Ecology/Marine Biology AQ-1. References cited in the ER on aquatic ecology should be available for review at the site audit. Of particular interest are the company specific documents that are not readily available. such as:

a. WPPSS 1982. Technical Review of the Aquatic Monitoring Program of WNP-2, Washington Public Power Supply System, Richland, Washington, September 1982.

- 3

b. WPPSS 1986. Operational Ecological Monitoring Program for Nuclear Plant 2 - 1985 Annual Report, Washington Public Power Supply System, prepared April 1986.

c. WPPSS 1987. Operational Ecological Monitoring Program for Nuclear Plant 2 - 1986 Annual Report, Washington Public Power Supply System, prepared April 1987.

d. WPPSS 1988. Operational Ecological Monitoring Program for Nuclear Plant 2 - 1987 Annual Report, Washington Public Power Supply System, prepared April 1988.

e. WPPSS 1996. Operational Ecological Monitoring Program for Nuclear Plant 2 1995 Annual Report, Washington Public Power Supply System, prepared April 1996.

AQ-2. Map of salmon redds (chinook and steelhead) in the vicinity of the makeup water and discharge lines for the circulating water system.

AQ-3. Describe any general maintenance procedures, if any, for the makeup water and discharge lines for the circulating water system. Are there any issues with biofouling, debris accumulation, or other issues with the submerged makeup water and discharge lines?

AQ-4. Was NOAA Fisheries contacted concerning compliance with the Magnuson-Stevens Fishery Conservation and Management Act (16 USC 1801 et seq.) and identification of essential fish habitat for the Pacific Salmon Fishery?

AQ-5. Include a tour to the makeup water pumphouse as part of the site audit.

Cultural Resources/Archaeology CR-1. Describe the process to identify Tribes and interested parties to consult with regarding the potential impacts to cultural resources as a result of the proposed project.

CR-2. Provide copies of all consultation letters with SHPO, Tribes, and interested parties as well as response letters and comments received from the SHPO, Tribes, and interested parties as a result of the proposed project.

CR-3. Describe the cultural background (prehistoric and historic) at Columbia Generating Station and the vicinity to put the historical properties in context.

CR-4. Identify the status of the 106 consultation process.

CR-5. Provide a knowledgeable expert at the environmental site visit who can describe the Area of Potential Effect (APE) and the cultural resources located within.

- 4 CR-6. Provide copies of relevant cultural resources reports and site forms for the CGS property and the associated survey reports for the transmission line corridors. Provide copies of all relevant reports and site forms associated with the APE.

CR-7. Provide the references presented in the ER regarding cultural resources.

CR-8. Provide copies of procedures that identify measures to be taken if cultural resources and/or human remains are inadvertently discovered during operation and maintenance activities.

CR-9. Provide pre- and post-construction aerial photographs, if available.

CR-10. Provide a knowledgeable expert at the environmental site visit to discuss cultural resources at CGS and the impacts the proposed action may have on cultural resources at CGS.

CR-11. Provide a knowledgeable expert at the environmental site visit to discuss the status of the 106 consultation process.

CR-12. Provide a knowledgeable expert at the environmental site visit to provide a tour of the cultural resources within the APE.

CR-13. Provide information on management around less-developed areas of the plant site, for instance, brush removal programs near known historic and archaeological resources or near unsurveyed areas.

CR-14. Provide a copy of the transmission line vegetation management program plan, including timing of mowing, herbicide application, and clearing; inspections and repair activities conducted by helicopters or other vehicles; standard operating procedures or guidelines for the Applicant and any contractors; technician training programs, and any regulations that restrict maintenance activities (e.g., looking for the depth of disturbance, especially with tree removal in a portion of the corridor). Of particular importance are vegetation management procedures for the site and associated transmission line(s) to avoid impacts to historic and archaeological resources.

CR-15. Provide a copy of the Environmental Compliance Manual and any other environmental review procedures for land-disturbing activities (e.g., trenching, clearing, digging).

CR-16. Provide maps of ownership and land use of the Applicant's property and associated transmission lines. Copies of historic plat maps would be useful, if available.

Alternatives No site audit needs at this time.

-5 Socioeconomics/Environmental Justice/Land Use Environmental Justice To help address the provisions of Section 4-4 "Subsistence Consumption of Fish and Wildlife" in Executive Order 12898, the following information is needed to assist the NRC in its environmental justice review:

EJ-1. Information about any observed subsistence consumption behavior patterns specifically fish and wildlife consumption-by minority and low-income populations in the vicinity of CGS. This sUbsistence consumption behavior could consist of hunting, fishing, and trapping of game animals and any other general food gathering activities (e.g., collecting nuts, berries, and other plant material) conducted by minority and low income individuals in the vicinity of CGS.

EJ-2. Information about current or past wildlife sampling and testing of game animals such as deer, squirrel, turkey, pheasant, duck, fish and other game birds and animals that may have been.conducted in the vicinity of CGS. Wildlife sampling and testing may have been conducted before, during, and after plant construction and in the early days of plant operation, but was discontinued after determining that tissue samples consistently showed no significant or measurable radiological impact on the environment from plant operations.

Socioeconomics The following information is needed to assist the NRC in its socioeconomic impact review:

SO-1. In addition to privilege tax payment information presented in Section 2.7 of the ER, please describe any other major annual support payments, one-time payments, and other significant forms of non-tax compensation (if any) provided to local organizations, communities, and jurisdictions (e.g., county, municipality, townships, villages, incorporated places, and school districts) on behalf of CGS.

80-2. Also, please provide information about any other recent or anticipated payment adjustments that could result in notable increases or decreases in tax or other payments.

SO-3. Data on the height of the tallest (visible from offsite locations) structures at CGS and general information on the visibility of plant facilities from various offsite locations.

SO-4. Information on noise impact analyses (if conducted) to offsite receptors or any noise emission studies on CG8.

- 6 Air Quality/Meteorology MET-1. Provide hourly meteorological data from the onsite meteorological program for the most recent 5-year period, including the meteorological data used in the MACCS2/SAMA analysis.

MET-2. Describe refurbishment activities, if any, which have the potential to affect regional air quality.

Non-radiological waste NRW-1. Please provide a description of all non-radioactive (hazardous and non-hazardous) waste streams at CGS including types and quantities for the past 5 years (2005-2009).

NRW-2. Please provide information on the status of CGS as a hazardous waste generator (as recognized by EPA). How much waste is generated per year for the past 5 years?

NRW-3. Please provide hard copies of the bill of lading/disposal certificates of non-radioactive sludge waste as well as hard copies of the bill of lading/disposal certificates for LLW sludge disposal to NRC-permitted disposal facility for the past five years.

NRW-4. Please provide hard copies of the Section 312 (TIER II) annual reports to EPA with a list of hazardous and toxic chemicals for past 3 years.

NRW-5. What pollution prevention/waste minimization measures are incorporated by CGS?

Please provide a copy of CGS pollution prevention plan/waste minimization plan/program, if available.

NRW-6. Does CGS generate universal waste? If yes, provide list of waste and how these are handled and disposed/recycled for the past 5 years.

NRW-7. Does CGS produce any medical wastes? If so, please specify quantity and how it is handled.

NRW-8. Any Federal (e.g. EPA, Corps of Engineers) or State (e.g. Washington Department of Ecology; Washington Department of Health; Washington Energy Facility Site Evaluation Council (EFSEC)) RCRA or CERCLA-related clean-up, monitoring within or adjacent to CGS?

References Requested for Docketing at the Columbia Generating Station Environmental Site Audit June 8-June 10, 2010 Meteorology and Air Compliance Response to site audit needs question MET-1 (meteorological data). Note: please provide data

.In eIect ' .x1 romc ft s orma.

Response to NRC request 3054 (EFSEC order 672 updates)

List of permitted air emission sources and associated emission quantities (NRC request 3055)

Terrestrial Ecology Ecological Monitoring Program for Columbia Generating Station, Summary Report for 1975 to 2002 (EN 2003)

Avian species list, e-mail communication from R.E. Welch to J.P. Chasse, 2009 (EN 2009b)

Rare Plant and Vegetation Survey, Riparian Zone, December 2008 (Link 2008)

Rare Plant and Vegetation Survey, Uplands, July 2009 (Link 2009)

Operational Ecological Monitoring Program -1987 Annual Report (WPPSS 1988)

Responses to site audit needs questions TE-1 (photos and maps), TE-2 (t-line maintenance plans), TE-3 (pesticides/herbicides), TE-4 (surveys), TE-5 (tour), TE-6 (bird strikes), TE-7 (wildlife management plans), TE-8 (migratory bird nesting), TE-9 (invasive species), and TE-10 (ponds)

Aquatic Ecology Response to site audit needs question AQ-1 (ER references):

• Technical Review of the Aquatic Monitoring Program of WNP-2, Washington Public Power Supply System, Richland, Washington, September 1982 (WPPSS 1982)

• Operational Ecological Monitoring Program for Nuclear Plant 2 -1985 Annual Report, Washington Public Power Supply System, prepared April 1986 (WPPSS 1986)

• Operational Ecological Monitoring Program for Nuclear Plant 2 - 1986 Annual Report, Washington Public Power Supply System, prepared April 1987 (WPPSS 1987)

• Operational Ecological Monitoring Program for Nuclear Plant 2 - 1987 Annual Report, Washington Public Power Supply System, prepared April 1988 (WPPSS 1988)

• Operational Ecological Monitoring Program for Nuclear Plant 2 -1995 Annual Report, Washington Public Power Supply System, prepared April 1996 (WPPSS 1996)

Energy Northwest Columbia Generating Station Effluent Mixing Study, prepared June 2008 (EN 2008)

Response to NRC request 3007 (circulating water system)

Hydrology Discharge Monitoring Reports for the last six months Table of estimated f------ .....

pumping rates for Wells 1 and 2 from October 2009 through May 2010 Procedure SWP-CHE-01 Site Certification Agreement for Hanford No.2, dated May 17, 1972 Nonradiological Waste Responses to site audit needs questions NRW-1 (annual report summaries for waste streams),

NRW-4 (Section 312 Tier" annual reports), and NRW-6 (universal waste)

Environmental Justice Responses to site audit needs questions EJ-1 (subsistence consumption) and EJ-2 (wildlife sampling)

Socioeconomics Responses to site audit needs questions SO-1 (payments), SO-2 (payment adjustments), SO-3 (height data),§lnd SO-4 (nOise)

ENCLOSURE 2

- 2 Land Use None Archaeological and Cultural Resources

• Hanford Cultural Resources Management Plan, DOE/RL-98-10, Rev 0., U.S. Department of Energy, Richland, Washington, February 2003, Website:

http://www.hanford.gov/doe/history=rmp, accessed September 9,2008 (USDOE 2003)

Rivers of North America, A.C. Benke and C.E Cushing, Editors, Elsevier Academic Press, Burlington, MA and London, U.K. (Benke and Cushing 2005)

Cultural Resources Review for Security Upgrades/Easement to Energy Northwest, letter from i PI\INL to Fluor Hanford, dated May 13, 2002 (PNNL 2002)

• Notice to Proceed, Columbia Generating Station Access Road Improvement, email

• communication from EL. Kennedy, PNNL, to S.J. Urban, Energy Northwest, July 16, 2008 (PNNL 2008b)

Draft Supplement to the Environmental Statement, Fiscal Year 1975 Proposed Program, Ashe-Hanford 500 kV Transmission Line, Bonneville Power Administration, March 8, 1974

! (BPA 1974a)

! Draft Supplement to the Environmental Statement, Fiscal Year 1975 Proposed Program, Richland Area Electrical Service Transmission Lines and Substations, Bonneville Power Administration, March 1974 (BPA 1974b)

Responses to site audit needs questions CR-9 (aerial photographs) and CR-14 (T-line vegetation management)

Map of leased land from DOE with a narrative about CGS related activities outside blocks A & B (NRC request 3046)

• Written response from EN describing the work process and how procedures are implemented to i ensure protection of cultural resources (NRC request 3049)

I Letter transmitting cultural resource protection procedures (SWP-ENW-04) to SHPO and any

! response from SHPO (NRC request 3047) .

. . ... ..

Written response from EN describing routine activities that occur In the culturally sensitive areas around the river pump house (NRC request 3048)

Latl'tude an d Iongl'tude for SOl*1 sampleI Ioca t'Ions 1, 7 an d 23

!

Map of siren locations and latitude and longitude of each siren location Alternatives None Cumulative Impacts EN's unsolicited proposal to DOE for the Mid-Columbia Energy Initiative (NRC request 3043)

'.. ML101810091 OFFICE PM:RPB1:DLR TLADLR BC:RPB1:DLR PM:RPB1:DLR NAME DDoyle IKing BPham DDoyle DATE 07/07/10 07/07/10 07/08/10 07/08/10

Letter to W.S. Oxenford from Daniel Doyle dated July 8,2010

SUBJECT:

REQUEST TO DOCKET INFORMATION RELATED TO THE ENVIRONMENTAL SITE AUDIT FOR COLUMBIA GENERATING STATION LICENSE RENEWAL (TAC NO. ME3121)

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