ML090750720

Environmental Site Audit Regarding Kewaunee Power Station License Renewal Application

ML090750720
Person / Time
Site:	Kewaunee
Issue date:	04/11/2009
From:	Lopas S L License Renewal Projects Branch 1
To:	Christian D A Dominion Energy Co, Dominion Energy Kewaunee
Lopas, S, DLR/REBA - 415-1147
References
TAC MD9409
Download: ML090750720 (9)

Text

April 11, 2009

Mr. David A. Christian President and Chief Nuclear Officer Dominion Energy Kewaunee, Inc.

Innsbrook Technical Center - 2SW 5000 Dominion Road Glen Allen, VA 23060-6711

SUBJECT:

ENVIRONMENTAL SITE AUDIT REGARDING KEWAUNEE POWER STATION LICENSE RENEWAL APPLICATION (TAC NO. MD9409)

Dear Mr. Christian:

The U.S. Nuclear Regulatory Commission (NRC) staff has reviewed the Environmental Report submitted by Dominion Energy Kewaunee, Inc. (DEK), in support of its application for license renewal for the Kewaunee Power Station (KPS), and plans to conduct its environmental site audit at KPS on May 26-29, 2009. To develop the Supplemental Environmental Impact Statement for the KPS license renewal, the NRC staff requests that the items described in the enclosed list be made available to the extent possible during the KPS environmental site audit.

If you have any questions, please contact me at 301-415-1147 or by e-mail at sarah.lopas@nrc.gov. Sincerely, /RA/ Sarah Lopas, Project Manager Projects Branch 1 Division of License Renewal Office of Nuclear Reactor Regulation

Docket No. 50-305

Enclosure:

As stated

cc w/encl: See next page

ML090750720 OFFICE LA:DLR PM:DLR:RPB1 PM:DLR:RPB1 BC:DLR:RPB1 NAME IKing SLopas SHernandez DPelton DATE 3/18/09 4/11/09 3/31/09 4/ /09 Letter to D. Christian from S. Lopas, dated April 11, 2009

SUBJECT:

ENVIRONMENTAL SITE AUDIT REGARDING KEWAUNEE POWER STATION LICENSE RENEWAL APPLICATION (TAC NO. MD9409)

DISTRIBUTION:

PUBLIC B. Holian / S. Lee (RidsNrrDlr)

R. Shane, OCA B. Keeling, OCA D. Pelton (RidsNrrDlrRpb1)

B. Pham (RidsNrrDlrRerb)

OPA (RidsOpaMail)

OGC (RidsOGCMailRoom)

S. Hernandez S. Lopas P. Tam M. Kunowski S. Burton K. Barclay I. Couret, OPA V. Mitlyng S. Uttal, OGC

Kewaunee Power Station cc:

Resident Inspectors Office U.S. Nuclear Regulatory Commission N490 Hwy 42 Kewaunee, WI 54216-9510

Mr. Chris L. Funderburk Director, Nuclear Licensing and Operations Support Dominion Resources Services, Inc.

Innsbrook Technical Center - 2SE 5000 Dominion Boulevard Glen Allen, VA 23060-6711

Mr. Thomas L. Breene Dominon Energy Kewaunee, Inc.

Kewaunee Power Station N490 Highway 42 Kewaunee, WI 54216

Mr. Michael J. Wilson, Director Nuclear Safety & Licensing Dominion Energy Kewaunee, Inc.

Kewaunee Power Station N490 Highway 42 Kewaunee, WI 54216

Mr. William R. Matthews Senior Vice President - Nuclear Operations Innsbrook Technical Center - 2SE 5000 Dominion Boulevard Glen Allen, VA 23060-6711

Mr. Alan J. Price Vice President - Nuclear Engineering Innsbrook Technical Center - 2SE 5000 Dominion Boulevard Glen Allen, VA 23060-6711

Mr. William D. Corbin Director - Nuclear Engineering Innsbrook Technical Center - 3NE 5000 Dominion Boulevard Glen Allen, VA 23060-6711

Mr. Paul C. Aitken Supervisor - License Renewal Project Innsbrook Technical Center - 3NE 5000 Dominion Boulevard Glen Allen, VA 23060-6711

Mr. David A. Sommers Supervisor - Nuclear Engineering Innsbrook Technical Center - 2SE 5000 Dominion Boulevard Glen Allen, VA 23060-6711

Ms. Lillian M. Cuoco, Esq.

Senior Counsel Dominion Resources Services, Inc.

120 Tredegar Street Riverside 2 Richmond, VA 23219

Mr. Stephen E. Scace Site Vice President Dominion Energy Kewaunee, Inc.

Kewaunee Power Station N490 Highway 42 Kewaunee, WI 54216

Mr. David R. Lewis Pillsbury Winthrop Shaw Pittman, LLP 2300 N Street, N.W.

Washington, DC 20037-1122

Mr. Ken Paplham E 4095 Sandy Bay Rd.

Kewaunee, WI 54216

Mr. Richard Gallagher Senior Scientist, License Renewal Dominion Resources Services, Inc.

Route 156, Rope Ferry Road Waterford, CT 06385

Kewaunee Power Station

cc:

Mr. Ronald Kazmierczak Regional Director Wisconsin Department of Natural Resources Northeast Region Headquarters 2984 Shawano Avenue P.O. Box 10448 Green Bay, WI 54307-0448

Ms. Kathleen Angel Federal Consistency and Coastal Hazards Coordinator Wisconsin Coastal Management Program P.O. Box 8944 Madison, WI 53708-8944

Mr. Jeff Kitsembel, P.E.

Public Service Commission of Wisconsin P.O. Box 7854 Madison, WI 53707-7854

ENCLOSURE Kewaunee Power Station License Renewal Environmental Site Audit Needs List

The NRC staff has reviewed Appendix E, Environmental Report (ER), of the Kewaunee Power Station (KPS) license renewal application and have found that it meets the requirements of 10 CFR 51.45. However, to develop the Supplemental Environmental Impact Statement for license renewal, a number of additional informational needs have been identified and are outlined below. Please have the following information and documentation available for review, or be prepared to discuss, during the May 26-29, 2009, environmental site audit at KPS:

General During specific plant area tours, please provide personnel knowledgeable of the pertinent technical area(s) (i.e. aquatic, terrestrial, radiological, cultural resources, etc.) to guide or accompany the tour, and to field questions that may arise during the tour. In addition to resource-specific tours, interview time for NRC staff and licensee/contractor counterparts should also be scheduled.

Terrestrial Biology (Nathan Goodman)

1. Have any invasive species been seen or documented on the site? Are any invasive species populations being managed, or have any been managed in the past? 2. What pesticides and/or herbicides are used on site or within the in-scope transmission line right-of-ways (ROWs)? What protocol do the contractors follow when applying chemicals near streams and wetlands? 3. Please provide in-scope transmission line ROW maintenance plans and the names of any ROW contractors. If available, please provide any aerial photos and topographic maps of the ROWs. 4. Please provide any additional information on the piping plover (Charadrius melodus) not already in the ER. 5. Please provide information on any bird deaths (including birds of prey and migratory birds) that have occurred at the reactor building, the meteorological tower, or along the transmission line ROWs. 6. Please provide a topographic map of the KPS site and in-scope transmission line segments, including any significant natural heritage areas, stream crossings, and historical sitings of endangered species, any birds of significance to the natural community, and migratory bird rookeries, if available. Additionally, please provide percentages of terrestrial communities on site (e.g., 20 percent of the site is forest habitat), if available. 7. Please provide delineation information for the locations and boundaries of floodplain and wetland areas on site. 8. Please provide any wildlife management plans that are used at KPS.

9. Please provide any best management practices followed for ground-disturbing activities.

Meteorology and Air Quality (Ekaterina Lenning)

1. Description of the on-site meteorological system/tower with the discussion of the system's back capabilities in the event of a censor fa ilure situation. 2. Please provide the most recent and detailed description of the KPS meteorological 2program, meteorological tower(s), description of instrumentation, and description of the review and data quality assurance process for meteorological data. 3. Please provide copies of all applicable air permits for the past 5 years. Please list all emission sources if air permit(s) does not contain this information. 4. NRC would like a description of burned diesel oil and lubricating oil disposal and/or re-use, and any incinerators on-site. 5. On page 2-10, Section 2-7 of Revision 9 dated 12/02/2005 of the KPS Updated Final Safety Analysis Report, is states that radioactively contaminated oil is incinerated on-site.

Please describe this process and applicable procedures. 6. Air quality and meteorological tours, including: a. Tour of meteorological tower(s).

b. A tour of on site-emissions sources.

Radiation Protection (Stephen Klementowicz)

1. Please provide information on any abnorma l or unusual spills or leaks in accordance with 10 CFR 50.75(g) or Nuclear Energy Institute Groundwater Protection Initiative reports. 2. Please provide information on the on-site disposal (10 CFR 20.2002) of radioactive material. 3. Please provide information regarding the radiological groundwater monitoring program.

4. Radiological tour including: a. Radioactive waste storage.

b. Radioactive effluent release points.

c. Radioactive effluent monitoring systems.

d. Radiological environmental monitoring stations (including any co-located State monitoring stations).

Hydrology (Dennis Beissel and Allison Travers)

1. Pumping records from on-site wells to confirm KPS uses less than 100 gallons per minute of groundwater. 2. Records of water withdrawal and discharge to Lake Michigan through the intake and discharge system, or example calculations for the intake/discharge values presented in the ER. 3. Any description and permits for dredging of the intake or discharge areas in the lake.

4. Any monitoring well records for groundwater tritium studies.

Environmental Justice (Jeffrey Rikhoff)

1. To help address the provisions of Section 4-4 "Subsistence Consumption of Fish and Wildlife" in Executive Order 12898, the NRC needs information about current or past wildlife sampling and testing of game animals such as deer, squirrel, turkey, pheasant, duck, and other game birds and animals that may have been conducted in the vicinity of the KPS by the state and/or the owner/operators of the plant. Wildlife sampling and testing may have been conducted at KPS by Wisconsin Public Service Corp. and Wisconsin Power and Light Co., and/or the state before, during, and after plant construction, and in the early days of plant operation.

3Socioeconomics (Jeffrey Rikhoff)

1. In addition to the utility aid payment info rmation presented in Section 2.7 of the ER, please describe any other annual support payments, one-time payments, and other forms of compensation (if any) provided to local organizations, communities, and

jurisdictions (e.g., county, municipality, townships, villages, incorporated places, and school districts) on behalf of KPS. 2. Also, please provide an update on changes to the utility aid paym ents including changes in assessed property value or any other anticipated payment adjustments that could result in notable increases or decreases in payments. 3. NRC would like to meet with plant personnel know ledgeable about the utility aid payments.

Aquatic Ecology (Brianna Balsam)

1. Please provide the following references (if available), which were cited in the 1976 316(b) Demonstration by Nalco Environmental Sciences:

a. Industrial BIO-TEST Laboratories, Inc. 1972. Preoperational thermal monitoring program of Lake Michigan near Kewaunee Nuclear Power Plant, January-December 1971. Report prepared for Wisconsin Public Service Corporation, Green Bay, Wisconsin. 191 pp. b. Industrial BIO-TEST Laboratories, Inc. 1973. Preoperational thermal monitoring program of Lake Michigan near Kewaunee Nuclear Power Plant, Jaunary-December 1972. Report prepared for Wisconsin Public Service Corporation, Green Bay, Wisconsin. 561 pp. c. LaJeone, L. J. 1974. Fish populations and life history. Pages 1-55 in Preoperational thermal monitoring program of Lake Michigan near Kewaunee Nuclear Power Plant, January-December 1973. Third Annual Report prepared for Wisconsin Public Service Corporation, Green Bay, Wisconsin, by Industrial BIO-TEST Laboratories, Inc

., Northbrook, Illinois. d. LaJeone, L. J. 1975. Fish populations and life history. Pages 1-55 in Preoperational thermal monitoring program of Lake Michigan near Kewaunee Nuclear Power Plant, January-December 1973. Fourth Annual Report prepared for Wisconsin Public Service Corporation, Green Bay, Wisconsin, by Industrial BIO-TEST Laborator ies, Inc., Nort hbrook, Illinois. e. LaJeone, L. J. 1976. Fish populations and life history. Pages 1-55 in Preoperational thermal monitoring program of Lake Michigan near Kewaunee Nuclear Power Plant, January-December 1973. Fifth Annual Report prepared for Wisconsin Public Service Corporation, Green Bay, Wisconsin, by Industrial BIO-TEST Laboratories, Inc

., Northbrook, Illinois. 2. A tour of the forebay and screenhouse.

Alternatives to License Renewal (Andrew Stuyvenberg)

1. NRC staff would like to speak with the alternatives expert/contractor on the project.

Nonradiological Waste and Pollution Prevention (Sarah Lopas)

1. Please detail KPS and Dominion procedures to collect and manage nonradiological 4waste (including hazardous and universal wastes, and waste oil) in accordance with federal and state rules. 2. Please provide a description of, or documentation regarding the Dominion Environmental Policy, as referenced on page 3-5 of the ER. 3. Expanding on Table 3.1-1 in the ER, please identify the types of nonradiological wastes that the KPS site has produced for each of the past five years. Please provide an accounting of waste quantities by year and waste stream. 4. Please identify the types and approximate quantities of hazardous waste typically generated during refueling outages. Are these wastes disposed of according to standard plant procedures? 5. Please describe the recycling program currently in place at KPS.

6. Please provide the amounts (by weight) of mixed wastes at the KPS site generated over the past five years. 7. If available, please provide copies of storage tank registrations and permits.

8. Tour of KPS waste management areas for nonradiological wastes, including the sewage treatment plant.

Archaeological and Cultural Resources (Jennifer Davis)

1. Were any surveys (archaeological investigations) completed prior to construction of KPS? If so, the NRC would like to see those reports. 2. Does Dominion Energy Kewaunee, Inc. have corporate procedures that protect historical and archaeological resources (environmental, digging/trenching, maintenance)? Please provide a copy for review. 3. Has the Wisconsin State Historic Preservation Office (SHPO) reviewed onsite procedures regarding historic and archaeological resources? Would the SHPO be contacted in the case of an inadvertent discovery? Would a cultural resource professional be called in to evaluate inadvertent discoveries? 4. Do procedures have a stop work order?

5. Please provide a land disturbance map that identifies areas of heavy, moderate, low, and undisturbed areas of plant property. 6. What training does the Environmental Coordinator have in relation to Section 106 guidelines? 7. The NRC would like to review maintenance procedures for transmission line corridors. Do these procedures take into account the protection of cultural resources? 8. The NRC would like to see any photos that show the plant site before, during, and after construction. 9. The NRC would like to see any old maps of the site prior to plant construction.

10. Are there any archaeological sites or historic structures on or adjacent to transmission line corridors? 11. The NRC would like copies of any correspondence with the Wisconsin SHPO that is not included in the ER. 12. Did the Wisconsin SHPO comment on the Phase 1 report drafted by Archaeological Services, Inc. for KPS?