ML13178A214

2013/06/24 Limerick Lr - Minor Updates, Corrections, and Clarifications Regarding Draft NUREG-1437, Supplement 49

ML13178A214
Person / Time
Site:	Limerick
Issue date:	06/24/2013
From:	- No Known Affiliation
To:	Division of License Renewal
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Download: ML13178A214 (16)

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1 LimerickNPEm Resource From: Nancy.Ranek@exeloncorp.com Sent: Monday, June 24, 2013 3:13 PM To: Perkins, Leslie Cc: albert.fulvio@exeloncorp.com; Ch ristopher.Wilson2@exeloncorp.com; michaelp.gallagher@exeloncorp.com

Subject:

Minor Updates, Corrections, and Clarificat ions Regarding Draft NUREG-1437, Supplement 49 Attachments:

6 24 2013_Infrml_Cmts_on_Drft_LGS_SEIS.docxHi Leslie -- As you know, on Friday, June 21, 2013, Exelon submitted comments for the record regarding the Draft NUREG-1437 Supplement 49 for Limerick Generating Station (LGS) License Renewal. With this message, I am forwarding an informal list of additional minor updates, corrections, and clarifications that NRC may want to consider.

Feel free to call if there are questions.

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

Fax: 610-765-5658

Email: nancy.ranek@exeloncorp.com This e-mail and any attachments are confidential, may contain legal, professional or other privileged informa tion, and are intended solely for the addressee. 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. -EXCIP Hearing Identifier: Limerick_LR_NonPublic Email Number: 1596 Mail Envelope Properties (84A4AE9C5B8C0A45AF695C41B1E94E00023E63F1)

Subject:

Minor Updates, Corrections, and Clarifications Regarding Draft NUREG-1437, Supplement 49 Sent Date: 6/24/2013 3:13:27 PM Received Date: 6/24/2013 3:13:46 PM From: Nancy.Ranek@exeloncorp.com Created By: Nancy.Ranek@exeloncorp.com Recipients: "albert.fulvio@exeloncorp.com" <albert.fulvio@exeloncorp.com> Tracking Status: None "Christopher.Wilson2@exeloncorp.com" <Christopher.Wilson2@exeloncorp.com> Tracking Status: None "michaelp.gallagher@exeloncorp.com" <michaelp.gallagher@exeloncorp.com> Tracking Status: None "Perkins, Leslie" <Leslie.Perkins@nrc.gov> Tracking Status: None

Post Office: mobmsxch06.energy.power.corp Files Size Date & Time MESSAGE 947 6/24/2013 3:13:46 PM 6 24 2013_Infrml_Cmts_on_Drft_LGS_SEIS.docx 42848

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Page 1 of 14 Minor Updates, Corrections, and Clarifications On Draft NUREG-1437, Supplement 49 Regarding Limerick Generating Station, Units 1 and 2 Where suggested changes to the SEIS are provided, they are highlighted with bolded italics for inserted text and strikethroughs for deleted text.

Page # Line # Section # Comment xviii 4 to 5 Executive Summary Clarify the phrase "from the continued operation of Exelon" by revising it to read as follows: "from the continued operation of Exelon LGS" xviii 12 Executive Summary Delete the word "in" before the phrase "NUREG-0974, Supplement 1" xix 14 to 15 Executive Summary Sentence in lines 14 to 15 on page xix appears garbled. Consider revising it to read as follows: "The NRC staff also considered the no-action alternative and the effects it would have." xx 2 to 4 Executive Summary The Staff concludes that its "preliminary recommendation is that the adverse environmental impacts of license renewal for LGS are not great enough to deny the option of license renewal for energy planning decision makers." Consider revising the conclusion to read more consistently with 10 CFR § 51.95(c)(4),

possibly as follows: "preliminary recommendation is that the adverse environmental impacts of license renewal are not so great that preserving the option of license renewal for energy planning decision makers would be unreasonable." xxi 9 Abbreviations and Acronyms Consider deleting the parenthetical, which reads "[Also: UK Atomic Energy Authority]" from line 9 because "AEA" is not used anywhere in this document as an acronym for the UK Atomic Energy Authority. xxiii 4 Abbreviations and Acronyms Correct the spell out for "FT" by changing it from "threatened" to "Federally threatened" xxvi 14 to 16 Abbreviations and Acronyms Correct the phrase "also used in this report as an acronym for Philadelphia Electric Company or PECO Energy Company, predecessors of Exelon Generation" by revising it to read as

follows: "also used in this reportas an acronym for Philadelphia Electric Company or PECO Energy Company, predecessors a predecessor of PECO Energy Company and Exelon Generation" xxvi 17 Abbreviations and Acronyms Correct the spell out of the agency name by changing the word "Boating" to "Boat" xxvi 29 Abbreviations and Acronyms Correct the spell out for "PR" by changing it from "rare" to "Pennsylvania rare" Page 2 of 14 Minor Updates, Corrections, and Clarifications On Draft NUREG-1437, Supplement 49 Regarding Limerick Generating Station, Units 1 and 2 Where suggested changes to the SEIS are provided, they are highlighted with bolded italics for inserted text and strikethroughs for deleted text.

Page # Line # Section # Comment xxvi 31 Abbreviations and Acronyms Add an entry between lines 31 and 32 for the abbreviation "PT" and its spell out, "Pennsylvania threatened" xxvii 27 Abbreviations and Acronyms For consistency between the spell outs of SE and ST, change the capitalization of the word "State" to "state" xxviii 4 Abbreviations and Acronyms Replace the word "upload" with the word "load" xxviii 7 Abbreviations and Acronyms Delete the entry for "TSF" from the list of Abbreviations and Acronyms because it is not used in the SEIS. 1-3 16 1.3 The NRC notice of availability of the LGS draft SEIS, which was published in the Federal Register on May 7, 2013, states that comments are due by June 27, 2013, which is 51 days from the date of publication. Consider whether the sentence on line 16, stating that the draft SEIS is available for public comment for a period of 75 days should be modified. 2-1 2 2.0 Add "primarily" before "in Limerick Township" because a small part of the LGS site is located in the adjacent East Coventry Township, as stated in the Draft SEIS, Section 2.2.8.1. 2-1 18 to 21 2.1 Clarify the description of the LGS nuclear reactors by revising the text in lines 18 to 21 on page 2-1 as follows: "The nuclear reactor for each unit is a General Electric Mark II (GE) boiling water reactor (BWR) producing a reactor core rated thermal power of 3,515 megawatts (MWt). The nominal net electrical capacity is 1,170 megawatts electric (MWe). Both LGS reactors have Mark II primary containment structures.

2-1 23 to 24 2.1.1 Because the primary and secondary containments, which are not part of the reactor system are described in lines 31to 37 on page 2-1, clarify the description of the LGS nuclear reactors by revising the sentence in lines 23 to 24 on page 2-1 as follows:

"The nuclear reactor system for each Limerick unit includes a single-cycle, forced circulation General Electric Mark II GE BWR."

Page 3 of 14 Minor Updates, Corrections, and Clarifications On Draft NUREG-1437, Supplement 49 Regarding Limerick Generating Station, Units 1 and 2 Where suggested changes to the SEIS are provided, they are highlighted with bolded italics for inserted text and strikethroughs for deleted text.

Page # Line # Section # Comment 2-1 31 to 33 2.1.1 Clarify the description of the primary containment in lines 31 to 33 on page 2-1 by revising the text as follows: "The Mark II primary containment surrounds the reactor vessel and also houses the reactor coolant recirculation pumps and piping loops." 2-2 19 2.1.2 Change "Buildings" to "Enclosures" for consistency with the LGS naming convention and with other locations in the Draft SEIS where it is used. 2-2 37 2.1 Change "collected and chemically neutralized before" to read as follows: "collected and, if necessary, chemically neutralized

before" 2-6 12 2.1.2.2 Change "radwaste building" to "radwaste enclosure" for consistency with the LGS naming convention and with other locations in the SEIS where it is used.

2-6 24, 33, 34 2.1.2.3 Correct the spelling of "Duratech" by changing it to "Duratek" 2-6 33 2.1.2.3 Because Duratek does not provide final disposal services and future contractual arrangements may change, replace the phrase that reads "and shipped to Duratech [sic] in Tennessee for processing and disposal" with the phrase "and sent offsite for processing or final disposal." 2-7 4 to 17 2.1.2.4 This section states (line 6) that LLMW generation at LGS is "rare," and then later states (line 16) that it is "occasional." If the paragraph in lines 13 to 17 is retained in the final SEIS, consider using the same terminology in both lines 6 and 16 to characterize the LLMW generation frequency. 2-7 8 to 9 2.1.2.4 Because the RCRA mixed waste treatment and storage conditional exemption (40 CFR 266, Subpart N) was not adopted until 2001, clarifying the words in lines 8 to 9 on page 2-7 by replacing "1976 Resource Conservation and Recovery Act (RCRA)" with the word "RCRA." 2-8 25 2.1.3.1 Correct the phrase "to the Bradshaw Reservoir to the East Branch Perkiomen Creek" by revising it to read as follows: "to from the Bradshaw Reservoir to the East Branch Perkiomen Creek" Page 4 of 14 Minor Updates, Corrections, and Clarifications On Draft NUREG-1437, Supplement 49 Regarding Limerick Generating Station, Units 1 and 2 Where suggested changes to the SEIS are provided, they are highlighted with bolded italics for inserted text and strikethroughs for deleted text.

Page # Line # Section # Comment 2-8 28 to 33 2.1.3.1 The paragraph in lines 28 to 33 on p. 2-8 of the draft SEIS do not provide any information about LGS and seem to be irrelevant to the discussion of non-radiological waste management at LGS. Consider deleting the entire paragraph or clarifying its relevance to LGS. 2-9 21 2.1.4 Clarify the words "LGS refuels" by replacing them with the following words: "Each LGS unit refuels." 2-9 26 2.1.5 Change "Philadelphia Energy Company" to "PECO Energy Company" consistent with acronym list 2-15 24 2.1.5.2 Correct an omission from the phrase "North American Electric Reliability (NERC)" by revising it to read as follows: "North American Electric Reliability Corporation (NERC)" 2-16 11 to 12 2.1.6 The statement that the clay-lined spray pond "has an insignificant interface with the environment" is unclear. Consider clarifying it by adding the following words at the end of the sentence (after "environment"): "because its use by wildlife and aquatic life is discouraged or prevented through barrier fencing, chemical additions, and dredging, and the clay-liner minimizes water seepage." (See LGS License Renewal ER, Section 3.1.1.3, page 3-5). 2-16 44 2.1.6.1 Correct typo by changing "212,700 m 3" to "212,700 m 3/d" 2-18 26 to 27 2.1.6.2 Clarify the phrase "needed to maintain the facility's water storage tank" by revising it to read as follows: "needed to maintain the facility's water storagewater level in the system's storage tank located at the LGS site" 2-18 28 2.1.6.2 Replace the words "a storage tank located at the LGS site" with the words: "the storage tank." 2-18 36 2.1.6.3 For consistency, add "site" after "the LGS" 2-19 6 2.1.6.3 For consistency with information in line 32 on page 2 51 of the draft SEIS and information in the 2nd paragraph on page 2-5 in the LGS License Renewal ER, change the words "a 43-acre site" to the words "a 42-acre site." 2-20 14 to 15 2.1.6.4 Correct the reservoir name by changing "Merrill Creek Reservoir" to "Still Creek Reservoir" 2-20 41 2.1.6.4 In the phrase "blowdown line that combines into a single, 36-in. (32-cm) line," correct the metric dimension of the blowdown line by changing "32-cm" to "91.4-cm".

Page 5 of 14 Minor Updates, Corrections, and Clarifications On Draft NUREG-1437, Supplement 49 Regarding Limerick Generating Station, Units 1 and 2 Where suggested changes to the SEIS are provided, they are highlighted with bolded italics for inserted text and strikethroughs for deleted text.

Page # Line # Section # Comment 2-21 14 2.1.6.4 Correct a typo in the phrase "the LGS cooling powers" by changing "powers" to "towers" 2-21 21 2.1.6.4 Consistent with Section 2.3.2 on page 2-33 in the LGS License Renewal ER, modify the sentence in line 21 on page 2-21 by revising it as follows: "Potable water and a backup supply of fire emergency water for LGS are provided by two separate wells." 2-21 42 2.1.7 Consistent with Section 2.3.2 on page 2-33 in the LGS License Renewal ER, modify the sentence in line 42 on page 21 by revising it as follows: "Exelon also operates two primary groundwater supply wells in the main plant area to meet the potable needs of plant personnel and to provide a backup supply of fire emergency water, respectively. 2-22 8 2.1.7.1 For consistency with the list of Abbreviations and Acronyms, change "42 MGD" to "42 mgd". 2-22 15 to 16 2.1.7.1 Consider clarifying the sentence in line 15 on page 2-22 by revising it as follows: "This is adjusted based on upstream releases from DRBC-approved projects unrelated to LGS, such as releases from Blue Marsh Reservoir" 2-22 27 2.1.7.1 In the phrase "makeup at or above that temperate," change "temperate" to "temperature" 2-23 7 to 8 2.1.7.2 Consistent with Section 2.3.2 on page 2-33 in the LGS License Renewal ER, clarify the following sentence by revising it as indicated: "Well 3 (the "Batch Plant" Well) provides backup water supply supplies water to a backup fire emergency water storage tank." 2-23 12 2.1.7.2 For consistency in the use of capitalization, revise the phrase "while well 3 is located" by changing "well" to "Well" 2-23 44 2.2 Add "plant site" after "The LGS" 2-25 1 to 3 2.2.1 The community names and distances to LGS given in lines 1 to 3 on p. 2-25 are inconsistent with the community names and distances to LGS given in lines 44 and 45 on p. 2-23 and lines 1 to 3 on p. 2-24. For example, Phoenixville is said to be 7.6 miles away on p. 2-25, but page 2-24 says it is 9.3 miles, and Philadelphia is said to be 29 miles away on p. 2-25 but page 2-24 says it is 21 miles. Consider harmonizing the duplicate information so that it is consistent, or deleting the duplicate information in one of the two locations where it appears.

Page 6 of 14 Minor Updates, Corrections, and Clarifications On Draft NUREG-1437, Supplement 49 Regarding Limerick Generating Station, Units 1 and 2 Where suggested changes to the SEIS are provided, they are highlighted with bolded italics for inserted text and strikethroughs for deleted text.

Page # Line # Section # Comment 2-31 43 2.2.4.1 Correct a typo In the phrase "an area of some 363 m 2 (940 km 2)," by changing "363 m 2" to "363 mi 2". 2-31 4 2.2.4.1 Clarify the phrase "Schuylkill River, Possum Hollow Run, and Brooke Evans Creek" by revising it to read as follows:

"Schuylkill River , (Possum Hollow Run, and Brooke Evans Creek)" 2-32 37 to 38 2.2.4.2 Clarify the phrase "designed for use in the maintenance of stocked trout" by revising it to read as follows:

" designated designed for use as a trout stocked fishery, maintaining in the maintenance of stocked trout" 2-33 47 2.2.4.2 Correct the citation by changing "(Exelon 2012a)" to "(Exelon 2012b)" 2-35 3 2.2.5.1 Consider clarifying the phrase "LGS's four groundwater production wells" by revising it to read as follows: "LGS's four

groundwater productionsupply wells." Exelon believes it may be misleading to characterize all four wells associated with the LGS as "groundwater production wells" because the term could be misunderstood to mean that all four wells pump large amounts of water, when the two secondary supply wells actually pump only an average of less than 4 gpm combined (see section 2.1.7.2, lines 35 and 36 on p. 2-23). 2-35 27 2.2.5.2 Consider clarifying the phrase "collected from the plant's production wells" by revising it to read as follows: "collected

from the plant's production primary groundwater supply wells" 2-37 44 to 45 2.2.6.1 Correct the agency name by replacing the words "Boating" with "Boat" as follows:  : "Pennsylvania Fish and Boating Boat Commission." 2-42 10 2.2.6.1 Correct the tributary name by revising "East Branch of the Perkiomen Creek" to read as follows: "East Branch of the Perkiomen Creek" 2-44 42 2.2.6.1 Correct a typo by changing "RFBC" to " PFBC" 2-45 13 2.2.6.1 Correct a typo by changing the words "Brook Evans Creek" to "Brooke Evans Creek" 2-45 8 2.2.6.1 Change "State of Pennsylvania" to "Commonwealth of Pennsylvania" Page 7 of 14 Minor Updates, Corrections, and Clarifications On Draft NUREG-1437, Supplement 49 Regarding Limerick Generating Station, Units 1 and 2 Where suggested changes to the SEIS are provided, they are highlighted with bolded italics for inserted text and strikethroughs for deleted text.

Page # Line # Section # Comment 2-47 21 2.2.7 Correct the tributary name by replacing the words "Brook Evans Run" with the following words: "Brooke Evans Creek." Although some documents have called the tributary mentioned in line 21 on p. 2-47 by the name "Brooke Evans Run," it is referred to in the Pennsylvania Department of Environmental Protection

stream standards (25 Pa.Code 93.9b) as "Brooke Evans

Creek." 2-47 29 2.2.7 Correct a typo by changing "22-60" to "220-60" 2-49 19 2.2.7 Correct a typo by changing "Schwensksvill" to "Schwenksville" 2-51 26 2.2.8.1 Correct a typo in the phrase "One of lines" by revising it to read as follows: "One of the lines" 2-53 31 2.2.8.2 Delete "State" after "Pennsylvania" (redundant) 2-54 31 2.2.8.2 For consistency in naming, change "Point Pleasant Pump Station" to "Point Pleasant Pumping Station" 2-66 10 2.2.9.1 For consistency with the discussion in section 2.2.9.1, which addresses Berks, Chester, and Montgomery Counties, change the phrase "two-county ROI" to "three-county ROI" 2-67 17 2.2.9.2 Clarify the phrase "LGS withdraws water" by revising it as follows: "LGS withdraws cooling system makeup water" 2-67 17 to 21 2.2.9.2 To clarify that LGS does not obtain potable water from any of the named public water supply systems, consider adding the following sentence to the end of the paragraph in lines 17 to 21 on page 2-67: "As discussed in Section 2.1.7.2, the potable water supply at the LGS plant site is obtained from an onsite

well." 2-68 Table 2-8 2.2.9.2 Capitalize "water" in "Pottstown Borough water Department" near bottom of table 2-68 3 2.2.9.2 Before the paragraph in lines 3 to 9 on page 2-68, add the subsection heading "Education" 2-72 12 2.2.9.5 Correct a typo by changing the spelling of the cited reference from "UCSB 2010" to "USCB 2010" Page 8 of 14 Minor Updates, Corrections, and Clarifications On Draft NUREG-1437, Supplement 49 Regarding Limerick Generating Station, Units 1 and 2 Where suggested changes to the SEIS are provided, they are highlighted with bolded italics for inserted text and strikethroughs for deleted text.

Page # Line # Section # Comment 2-74 16, 24, 26 2.2.9.5 The numbers provided in the text do not match Table 2-13. Specifically, based on Table 2-13, in line 16 on page 2-74, the number of farms in Chester County hiring workers for less than 150 days should be 233 rather than 250. In line 24, the number of farms in Berks County that employed 591 workers for less than 150 days per year should be 180 rather than 458. In line 26, the number of farms in Montgomery County that employed 208 temporary farm workers should be 71 rather than 105.

2-76 Table 2-14 2.2.9.6 Change the spelling of the cited reference for Table 2-14 from "UCSB 2011" to "USCB 2011" 2-76 11 2.2.9.6 Correct the phrase "followed by manufacturing and (13.2 percent)" by revising it as follows: "followed by manufacturing and (13.2 percent)" 2-76 13 2.2.9.6 Modify the phrase "and the ROI area is" by revising it as follows: "and the ROI area is" 2-77 9 2.2.9.6 Clarify the words "had 13.4 percent." by revising them as follows: "had 13.4 percent of persons living below the poverty level

." 2-77 11 2.2.9.6 Clarify the phrase "(13.6 percent)" by revising it as follows: "(13.6 percent each)" 2-78 25 2.2.9.6 Clarify the phrase "of these taxes to Montgomery County" by revising it as follows: "of these the taxes paid to it to Montgomery County" 2-81 5 2.2.10.1 Correct typo by changing "LSG" to "LGS" 2-81 5 to 6 2.2.10.1 Change "State of Pennsylvania" to "Commonwealth of Pennsylvania" 2-82 10 2.2.10.1 Correct typo by changing "Unites States" to "United States" 2-82 19 2.2.10.2 Correct typo by changing "Operating License Renewal State" to "Operating License Renewal Stage" 2-82 41 2.2.10.2 Change "State of Pennsylvania" to "Commonwealth of Pennsylvania" 2-84 18 2.3 Change "State of Pennsylvania" to "Commonwealth of Pennsylvania" 2-97 39 2.4 Correct agency name by changing "Pennsylvania Fish and Boating Commission" to "Pennsylvania Fish and Boat Commission."

Page 9 of 14 Minor Updates, Corrections, and Clarifications On Draft NUREG-1437, Supplement 49 Regarding Limerick Generating Station, Units 1 and 2 Where suggested changes to the SEIS are provided, they are highlighted with bolded italics for inserted text and strikethroughs for deleted text.

Page # Line # Section # Comment 2-97 41 2.4 Correct agency name by changing "Pennsylvania Fish and Boating Commission" to "Pennsylvania Fish and Boat Commission." 4-4 31 to 32 4.4.2.1 Correct typo by changing "DBRC" to "DRBC" in two places 4-6 28 4.5.2.2 Correct typo by revising the phrase "relatively low wells" as follows: "relatively low wells levels" 4-10 6 4.7.2 Correct the reference citation by replacing the word "Entergy" with the word "Exelon" 4-10 33 and 37 4.8.1 Correct typo by changing "Section 4.7.3" to "Section 4.8.2" in both line 33 and line 37. 4-11 38 4.8.2.1 Replace the words "Atlantic sturgeon eggs" with the following words: "shortnose sturgeon eggs" 4-13 23 4.8.2.2 Correct typo by inserting double space after "River." 4-23 10 to 11 4.9.2 Clarify the phrase "The atmospheric samples" by revising it as follows: "The atmospheric pathway samples" 4-27 28 4.9.4 Clarify the phrase "PECO, and owners and operators of the transmission lines, conduct" by revising it as follows: "PECO, amd as the ownersowner and operators operator of the transmission lines, conducts" 4-27 32 to 33 4.9.4 Clarify the phrase "Exelon expects that it, as well as PECO, will" by revising it as follows: "Exelon expects that it, as well as PECO, a subsidiary of Exelon Corporation, will" 4-27 35 4.9.4 Clarify the phrase "Exelon's and PECO's periodic surveillance of the transmission system" by revising it as follows: "Exelon's and PECO's periodic surveillance of the transmission system" 4-32 20 to 21 4.10.6 Update the phrase "Construction activity is expected to begin in 2012" by revising it as follows: "Construction activity is expected to begin in 2012 , which began in 2012, was completed in May 2013" 4-39 28 4.10.8 Because the conclusion beneath the heading "Section 4.10.8 Conclusion" addresses only information presented in Section 4.10.7.4, consider deleting the section heading. Alternatively, the discussion could be expanded to address information presented in Sections 4.10.7.1 through 4.10.7.4, and the section number could be changed to 4.10.7.5.

Page 10 of 14 Minor Updates, Corrections, and Clarifications On Draft NUREG-1437, Supplement 49 Regarding Limerick Generating Station, Units 1 and 2 Where suggested changes to the SEIS are provided, they are highlighted with bolded italics for inserted text and strikethroughs for deleted text.

Page # Line # Section # Comment 4-40 36 4.11 For consistency with lines 28 to 30 on p. 4-40 and to use the actual title of the annual report that includes the groundwater monitoring data, clarify the sentence "The groundwater monitoring data are reported in the annual LGS REMP reports" by revising it as follows: "The groundwater monitoring data are reported in the annual LGS REMPradiological environmental operating reports" 4-41 3 to 4 4.11 Because groundwater monitoring data are included in the Annual Radiological Environmental Operating Report rather than the Annual Radioactive Effluent Release Report, correct the phrase "report the results in the annual radioactive effluent operating reports" by revising it as follows: "report the results in the annual radioactive effluent radiological environmental operating reports." 4-42 4 and 5 4.12 Consider whether it remains appropriate to include the plants listed in lines 4 and 5 on page 4-42 in the analysis of cumulative impacts, considering that the Cromby Generating Station was closed in 2011 and the Titus Station is scheduled for closure in September 2013. 4-45 13 to 14 4.12.2.2 Consider clarifying the phrase "LGS's four groundwater production wells" by revising it as follows: "LGS's four groundwater productionsupply wells." Exelon believes it may be misleading to characterize all four wells associated with the LGS as "groundwater production wells" because the term could be misunderstood to imply that all four wells pump large amounts of water, when the two secondary supply wells actually pump only an average of less than 4 gpm combined (see section 2.1.7.2, lines 35 and 36 on p. 2-23). 4-45 19 4.12.2.2. Consider clarifying the phrase "LGS and its regulated production wells" by revising it as follows: "LGS and its regulated productiongroundwater supply wells." 4-46 32 to 34 4.12.3 Clarify the sentence in lines 32 to 34 on page 4-46 by rearranging the words as follows: "Increased urbanization over the past 100 years has also led to increased runoff and elevated levels of pollutants within the Schuylkill River, Perkiomen Creek, and East Branch Perkiomen Creek" 4-47 23 to 25 4.12.3.2 For consistency with the list of Abbreviations and Acronyms, change "MGY" to "mGy" at one location in each of lines 23, 24, and 25.

Page 11 of 14 Minor Updates, Corrections, and Clarifications On Draft NUREG-1437, Supplement 49 Regarding Limerick Generating Station, Units 1 and 2 Where suggested changes to the SEIS are provided, they are highlighted with bolded italics for inserted text and strikethroughs for deleted text.

Page # Line # Section # Comment 4-47 23 4.12.3.2 Please note that water use at the Eddystone Generating Station has been reduced since 2005. The two coal-fired Eddystone Generating Station units are both retired, with Unit 1 being removed from service on May 31, 2011 and Unit 2 being removed from service on May 31, 2012. Two water-consuming units remain in service at Eddystone. Unit 3 and Unit 4, each 380 MW, run on either natural gas or No. 6 oil, based on market pricing. 4-48 40 to 41 4.12.4 Please note that both units at the Cromby Generating Station, one coal-fired and one natural gas/oil-fired were retired during 2011, with Unit 1 being removed from service on May 31, 2011 and Unit 2 being removed from service on December 31, 2011.

Also, the Titus Station is scheduled for closure in September

2013. 4-49 3 4.12.4 Please note that as stated in Appendix F, Table F-1 of the LGS Draft SEIS, the Linfield Energy Center project has been

withdrawn 4-52 20 and 22 4.12.7 The term "relicensing" implies that the entire licensing process is being redone, which is not accurate and may be misunderstood. Consider replacing the word "relicensing" in lines 20 and 22 on page 4-52 with the phrase "license renewal," which more accurately describes the process.

4-53 Table 4-10 Last Row 4.12.8 The term "relicensing" implies that the entire licensing process is being redone, which is not accurate and may be misunderstood. Consider replacing the word "relicensing" in the 4th and 5th lines of the last row in Table 4-10 on page 4-53 with the phrase "license renewal," which more accurately describes the process. 5-7 33 5.3 Correct the citation "Entergy 2011c" by revising it as follows: "EntergyExelon 2011c" 5-7 34 to 36 5.3 Replace the words "and the applicant evaluated the new and significant information evaluation with respect to the Commission's regulation" with the following words: "and the applicant evaluated new and significant information consistent with the Commission's regulation" 5-7 39 5.3 Correct a typo in the term "SAMDS Analysis" by revising it as follows: "SAMDSSAMDA Analysis" 5-7 43 5.3 Correct a capitalization error by replacing "SAMAS" with "SAMAs" Page 12 of 14 Minor Updates, Corrections, and Clarifications On Draft NUREG-1437, Supplement 49 Regarding Limerick Generating Station, Units 1 and 2 Where suggested changes to the SEIS are provided, they are highlighted with bolded italics for inserted text and strikethroughs for deleted text.

Page # Line # Section # Comment 5-9 20 5.3 Correct a typo by inserting a space between $5,000,000 and "(assuming similar construction -" 5-11 43 5.3 Correct a typo by revising the words "further reducing that probability" as follows: "further reducing that the probability" 6-1 6 6.1 Clarify the phrase "The uranium cycle" by revising it as follows: "The uranium fuel cycle" 6-1 9 to 10 6.1 Clarify the phrase "The generic potential impacts of the radiological and nonradiological environmental impacts of the uranium fuel cycle" by revising it as follows: "The generic potential impacts of the radiological and nonradiological environmental impacts of the uranium fuel cycle" 8-8 38 to 39 8.1.1 Because the draft LGS DSEIS excludes the existing LGS site as the host for replacement generating facilities (see page 8-3, lines 22 to 27), clarify the phrase "located at the LGS site" by revising it as follows: "located at the LGS site an existing power plant site within Pennsylvania or PJM" 8-10 15 8.1.3 For consistency with the now approved DRBC docket for LGS, consider changing the phrase "either the Delaware River or the Wadesville Mine Pool" as follows: "either the Delaware River or the Wadesville Mine PoolDRBC-approved augmentation sources for LGS (Section 2.1.7.1)" 8-11 18 to 24 8.1.4 Construction of an NGCC to provide replacement generation capacity would comply with all applicable state and federal endangered species protection laws, but please note that construction of an NGCC plant would not require NRC approval and may not require approval of any other federal agency. Therefore, federal interagency consultations under the ESA and Magnuson-Stevens Act may not be triggered. Consider modifying lines 18 to 24 on page 8-11 accordingly. 8-11 45 to 47 8.1.5 Construction of an NGCC to provide replacement generation capacity would comply with all applicable state and federal endangered species protection laws, but please note that construction of an NGCC plant may not require approval of any federal agency. Therefore, federal interagency consultations under the ESA and Magnuson-Stevens Act may not be triggered. Consider modifying lines 45 to 47 on page 8-11 accordingly.

Page 13 of 14 Minor Updates, Corrections, and Clarifications On Draft NUREG-1437, Supplement 49 Regarding Limerick Generating Station, Units 1 and 2 Where suggested changes to the SEIS are provided, they are highlighted with bolded italics for inserted text and strikethroughs for deleted text.

Page # Line # Section # Comment 8-23 11 to 13 8.2.5 As for the NGCC alternative, construction of an SCPC to provide replacement generation capacity would comply with all applicable state and federal endangered species protection laws, but please note that construction of an SCPC plant may not require approval of any federal agency. Therefore, federal interagency consultations under the ESA and Magnuson-Stevens Act may not be triggered. Consider modifying lines 11 to 13 on page 8-23 accordingly. 8-27 38 to 39 8.2.13 Clarity the phrase "although the waste generated during operation" by revising it as follows: "although the impacts of managing waste generated during operation" 8-35 15 8.3.11 Correct the phrase "construction of the SCPC alternative" by revising it as follows: "construction of the SCPC New Nuclear alternative" 8-43 31 3.4.8 Correct a typo by changing "Section 8 1.8" to "Section 8.1.8" 8-44 9 8.4.9 Correct a typo and clarify the cross-reference by changing "8.4.7" to " Section 8.4.8" 8-66 2 8.6.3 Correct a typo in the following phrase "that it has an air permit for up to 804 MW(e) of capacity that the site (FENOC 2011)" by revising it as follows: "that it has an air permit for up to 804 MW(e) of capacity that at the site (FENOC 2011) 8-77 36 8.6.8 Consider clarifying that the cited court decision, C&A Carbone, Inc. v. Town of Clarkstown, is a United States Supreme Court decision (511 U.S. 383 (1994)).

8-85 Table 8-11 8.8 Table 8-11 reports the impacts on aquatic and terrestrial resources from the Wind, Solar, and NGCC combination alternative as "SMALL to MODERATE." This appears to be inconsistent with the text of sections 8.6.2.4 and 8.6.2.5, which conclude that the impacts on aquatic and terrestrial resources, respectively, from the combination alternative would be SMALL.

Consider harmonizing Table 8-11 with section 8.6.2.4 and

8.6.2.5. 9-1 21 9.1 Correct a typo in the phrase "when the flow of the Schuylkill River falls to 560 (15.9 m 3/s)" by revising it as follows: "when the flow of the Schuylkill River falls to 560 cfs (15.9 m 3/s)"

Page 14 of 14 Minor Updates, Corrections, and Clarifications On Draft NUREG-1437, Supplement 49 Regarding Limerick Generating Station, Units 1 and 2 Where suggested changes to the SEIS are provided, they are highlighted with bolded italics for inserted text and strikethroughs for deleted text.

Page # Line # Section # Comment C-5 Table C-2 C.2 In Table C-2, update information in the column labeled "Dates" related to the entry "D-69-210 CP" in the column labeled "Number." by replacing the "Dates" information with the following:

Issued: 11/7/1975 (Rev. 13 -

5/8/2013) Expires: 12/31/2018 F-1 Table F-1 F.1 Update the Status of the Titus Coal Plant to indicate that it is scheduled for retirement by April 2015 (See Annual Form 10 K Report for NRG Energy, Inc., Part I, Item 2 (page 49)).