L-24-083, Response to License Renewal Environmental Report Requests for Additional Information and Request for Clarification

Response to License Renewal Environmental Report Requests for Additional Information and Request for Clarification

ML24107B080
Person / Time
Site:	Perry
Issue date:	04/15/2024
From:	Penfield R Vistra Operations Company
To:	Office of Nuclear Reactor Regulation, Document Control Desk
References
L-24-083, EPID L-2023-LNE-0002
Download: ML24107B080 (1)

Text

April 15, 2024 L-24-083 ATTN: Document Control Desk U.S. Nuclear Regulatory Commis.sion Washington, DC 20555-0001

SUBJECT:

Perry Nuclear Power Plant, Unit No. 1 Docket No. 50-440, License No. NPF-58 Perry Nuclear Power Plant Rod L. Penfield Site Vice President 1 0 Center Road Perry, Ohio 44081 10 CFR 54 Response to Perry Nuclear Power Plant License Renewal Environmental Report Requests for Additional Information and Request for Clarification (EPID No. L-2023-LNE-0002)

On July 3, 2023, Energy Harbor Nuclear Corp. submitted to the U.S. Nuclear Regulatory Commission (NRC) an application for renewal of the Perry Nuclear Power Plant (PNPP)

Facility Operating License No. NPF-58. Since submittal of the license renewal application (LRA), the direct and indirect transfer of control of the PNPP Facility Operating License has been transferred to Vistra Operations Company LLC (VistraOps) per conforming license Amendment 203 and the license transfer transaction was closed on March 1, 2024 (EPID L-2024-LLM-0000). The applicable details of the license transfer related to the PNPP LRA will be documented in the LRA annual update required to meet the License Renewal Rule pursuant to 10 CR 54.21(b).

The NRC staff has initiated the environmental review for the PNPP LRA and has requested clarification arid additionc1I information to support the NRC audit of the PNPP LRA Environmental Report (ER) conducted during the weeks of January 22 and January 29, 2024.

The NRC's requested clarification and additional information from the NRC's audit of the PNPP LRA ER were provided to the PNPP staff in the letter from the NRC senior environmental project manager (NRC EPM), dated March 14, 2024 (EPID L-2023-LNE-002).

As agreed to by the NRC EPM, the responses to the requested clarification and additional information associated with the NRC's audit of the Severe Accident Mitigation Alternatives (SAMA) portion of thePNPP ER, will be submitted to the NRC by May 17, 2024..

65S!;i SIERRA DRIVE IRVING, TEXAS 75039 o214*812-4600 VISTRACORP.COM Perry Nuclear Power Plant L-24-083 Page 2 of 2 The responses to the NRC staff's requested clarification and additional information for the remaining environmental issues are provided in the attachment.

As a result of the license transfer previously mentioned, PNPP is now owned by Energy Harbor Nuclear Generation LLC and operated by VistraOps. Therefore, in the responses provided in the attachment, the previous references to Energy Harbor are now VistraOps.

There are no regulatory commitments contained in this submittal. If there are any questions or if additional information is required, please contact Mr. Mark Bensi, PNPP License Renewal Project Manager at (440) 280-6179 or via email at Mark.Bensi@vistracorp.com.

I declare under penalty of perjury that the foregoing is true and correct. Executed on April 15, 2024.

Attachments: Responses to PNPP License Renewal Application Environmental Review Requests for Confirmation of Information and Requests for Additional Information cc: NRC Region Ill Administrator NRC Resident Inspector NRR Project Manager Executive Director, Ohio Emergency Management Agency, State of Ohio (NRC Liaison)

Utility Radiological Safety Board 6555 SIERRA DRIVE IRVING, TEXAS 75039 o 214*812*4600 VISTRACORP.COM Perry Nuclear Power Plant Docket No. 50- 440 Attachments Index Attachment RCI Subject No. RAI 1 RCI Info Need AQ-1 2 RCI Info Need AQ-6 3 RCI Info Need AQN-1 4 RCI Info Need AQN-2 5 RCI Info Need AQN-3 6 RCI Info Need AQN-4 7 RCI Info Need AQN-5 8 RCI Info Need AQN-6 9 RCI Info Need FPE-3 10 RCI Info Need AQN-8 11 RCI Info Need FPE-5 12 RCI Info Need FPE-7 13 RCI Info Need GE-1 and GE-2 14 RCI Info Need GW-2 15 RCI Info Need GW-3 16 RCI Info Need GW-4 17 RCI Info Need GW-5 18 RCI Info Need GW-6 19 RCI Info Need GW-7 20 RCI Info Need HCR-2 21 RCI Info Need HCR-3 22 RCI Info Need HCR-4 23 RCI Info Need HCR-5 24 RCI Info Need HCR-6 25 RCI Info Need HH-3 26 RCI Info Need HH-4 27 RCI Info Need SW-3 28 RCI Info Need TER-5 29 RCI Info Need WM-1 30 RCI Info Need WM-2 31 RCI Info Need WM-3 32 RCI Info Need WM-4 33 RCI Info Need WM-5 34 RCI Info Need WM-6 35 RCI Info Need WM-7 and DECOM-1 36 RAI Info Need GEN-1 37 RAI Info Need FPE-2 38 RAI Info Need GE-3 Perry Nuclear Power Plant Docket No. 50- 440 Attachments Index (continued)

Attachment RCI Subject No. RAI 39 RAI Info Need GW-5 40 RAI Info Need HCR-1 41 RAI Info Need HCR-6 42 RAI Info Need TER-1 43 RAI Info Need TER-2

Enclosure Index

Attachment Enclosure Subject No. No.

36 1 Table 9.1-1 Environmental Authorizations for Current PNPP Operations 38 1 Figure 3.5-3 Geologic Cross Section 1 GW Wells 39 2 Pz Manhole Tritium 3 Pz and Manhole 42 1 PNPP Bird Incident Report

Perry Nuclear Power Plant Docket No. 50- 440 VistraOps Response to NRC RCI No. AQ-1 L-24-0 83 Attachment 1 Page 1 of 1

Attachment No. 1

Aquatic Resources (AQ)

NRC RCI Number: AQ -1

From information gathered during the environmental site audit, please confirm the following: that the Perry Plant cooling water intake system does not include a fish return system. Perry Plant staff inspect the fish baskets when checking the traveling screens. Any fish present in the baskets are discarded with municipal waste. Due to the low intake velocity of 0.5 - 0.7 feet per second, fish are rarely found in the baskets and when present, occur in low numbers (i.e., 1 to 2 fish).

V is traO ps Response:

VistraOps confirms this statement is correct.

References:

None

Associated

Enclosures:

None

Perry Nuclear Power Plant Docket No. 50- 440 VistraOps Response to NRC RCI No. AQ-6 L 083 Attachment 2 Page 1 of 1

Attachment No. 2

Aquatic Resources (AQ)

NRC RCI Number: AQ-6

From the information gathered during the environmental site audit, please confirm that no federally or State-listed mussel species have been identified during periodic surveys to monitor mussel settlement in plant systems during spawning season in Lake Erie.

VistraOps Response:

VistraOps confirms this statement is correct.

References:

None

Associated E nc l os ur es:

None

Perry Nuclear Power Plant Docket No. 50-440 VistraOps Response to NRC RCI No. AQN-1 L 083 Attachment 3 Page 1 of 1

Attachment No. 3

Air Quality and Noise (AQN)

NRC RCI Number: AQN-1

During the environmental audits Air Quality and Noise break -out session and in response to information need AQN -1, Energy Harbor stated that quantified particulate matter emissions for the Unit 1 cooling tower have not been calculated because the facility has demonstrated compliance with all annual emissions limitations. Please confirm Energy Harbor does not have quantified particulate matter emissions for the Perry Plant Unit 1 cooling tower.

VistraOps Response:

VistraOps confirms this statement is correct.

References:

None

Associated E nc l os ur es:

None

Perry Nuclear Power Plant Docket No. 50-440 VistraOps Response to NRC RCI No. AQN-2 L 083 Attachment 4 Page 1 of 1

Attachment No. 4

Air Quality and Noise (AQN)

NRC RCI Number: AQN-2

During the environmental audits Air Quality and Noise break -out session and in response to information need AQN -2, Energy Harbor stated that:

• the annual air em issions in table 3.3-10 of the environmental report (ER) accounts for the auxiliary boilers and Perry Plants three emergency diesel generators;

• the three emergency diesel generators are not required to be included in Perry Plants conditional air permit and are Permit by Rule qualified emission units; and

• additional onsite equipment that contribute to air emissions, but not included in table 3.3-10 of the ER, include four Permit by Rule qualified emission units whose emissions are minimal and are not required to be calculated until or unless the auxiliary boilers emit 20 percent of a major source (20 tons per year).

Please confirm that the summary above is accurate.

VistraOps Response:

VistraOps confirms these statem ents are correct with the following clarification. Since August 24, 2023, the four Permit by Rule (PBR) qualified emission units have been re-evaluated resulting in three of the units no longer requiring tracking. One unit has retained its PBR status.

References:

None

Associated

Enclosures:

None

Perry Nuclear Power Plant Docket No. 50-440 VistraOps Response to NRC RCI No. AQN-3 L 083 Attachment 5 Page 1 of 1

Attachment No. 5

Air Quality and Noise (AQN)

NRC RCI Number: AQN-3

In response to information need AQN -3, Energy Harbor provided air emission reports that are submitted to the Ohio Environmental Protection Agency for NRC staff review. The NRC staff noted that for calendar year 2021 (January 2021-December 2021), 2020 (January 2020-December 2020), and 2019 (January 2019-December 2019) emissions for certain pollutants are inconsistent with those presented in table 3.3-10 of the ER. Please confirm the following:

• for calendar year 2021, the correct sulfur dioxide emissions are 0.048 tons.

• for calendar year 2020, the correct sulfur dioxide emissions are 0.027 tons.

• for calendar year 2019, the correct nitrogen oxides emission are 10.898 tons; and

• for calendar year 2019, the correct carbon monoxide emissions are 2.793 tons.

VistraOps Response:

VistraOps confirms this statement is correct.

References:

None

Associated E nc l os ur es:

None

Perry Nuclear Power Plant Docket No. 50-440 VistraOps Response to NRC RCI No. AQN-4 L 083 Attachment 6 Page 1 of 1

Attachment No. 6

Air Quality and Noise (AQN)

NRC RCI Number: AQN-4

During the environmental audits Air Quality and Noise break -out session and in response to information need AQN -4, Energy Harbor stated that Perry Plant has not received any notices of violation or non-compliances associated with Perry Plants conditional operating air permit since 2021 to present (12/1 8/2023). Please confirm that Perry Plant has not received any notices of violation or non-compliances associated with Perry Plants conditional operating air permit from 2021 to 2023.

VistraOps Response:

VistraOps confirms this statement is correct.

References:

None

Associated E nc l os ur es:

None

Perry Nuclear Power Plant Docket No. 50-440 VistraOps Response to NRC RCI No. AQN-5 L 083 Attachment 7 Page 1 of 1

Attachment No. 7

Air Quality and Noise (AQN)

NRC RCI Number: AQN-5

During the environmental audits Air Quality and Noise break -out session and in response to information need AQN -5, Energy Harbor stated that:

• annual greenhouse gas emissions presented in table 3.3-11 of the Perry Plant ER accounts for two site auxiliary boilers and three diesel generators.

• Sulfur hexafluoride is not used in equipment at Perry Plant.

Please confirm that the summary above is accurate.

VistraOps Response:

VistraOps confirms this statement is correct. Sulfur hexafluoride is not used in equipment owned and operated by the Perry Plant.

References:

None

Associated E nc l os ur es:

None

Perry Nuclear Power Plant Docket No. 50-440 VistraOps Response to NRC RCI No. AQN-6 L 083 Attachment 8 Page 1 of 1

Attachment No. 8

Air Quality and Noise (AQN)

NRC RCI Number: AQN-6

During the environmental audits Air Quality and Noise break -out session and in response to information need AQN -6, Energy Harbor stated that there are no known field tests concerning ozone and nitrogen emissions generated by Perry Plants 22-kV and 345-k V in-scope transmission lines. Please confirm that there are no known field tests concerning ozone and nitrogen oxides emission generated by Perry Plants 22-kv and 345-kV in scope transmiss ion lines.

VistraOps Response:

VistraOps confirms this statement is correct.

References:

None

Associated E nc l os ur es:

None

Perry Nuclear Power Plant Docket No. 50-440 VistraOps Response to NRC RCI No. FP E -3 L 083 Attachment 9 Page 1 of 1

Attachment No. 9

Federally Protected Ecological Resources (FPE)

NRC RCI Number: FPE-3

From information gathered during the environmental site audit, please confirm that Energy Harbor does not plan to undertake tree removal or conduct any other activities at Perry Plant during the license renewal period that would disturb habitat suitable for bat roosting or maternity activities.

VistraOps Response:

VistraOps confirms this statement is correct.

References:

None

Associated E nc l os ur es:

None

Perry Nuclear Power Plant Docket No. 50-440 VistraOps Response to NRC RCI No. AQN-8 L 083 Attachment 10 Page 1 of 1

Attachment No. 10

Air Quality and Noise (AQN)

NRC RCI Number: AQN-8

During the environmental audits Air Quality and Noise break -out session and in response to information need AQN -8, Energy Harbor stated that Perry Plant has not received any noise complaints from 2022 to 2023. Please confirm that Perry Plant has not received any noise complaints from 2022 to 2023.

VistraOps Response:

VistraOps confirms this statement is correct.

References:

None

Associated E nc l os ur es:

None

Perry Nuclear Power Plant Docket No. 50-440 VistraOps Response to NRC RCI No. FP E -5 L 083 Attachment 11 Page 1 of 1

Attachment No. 11

Federally Protected Ecological Resources (FPE)

NRC RCI Number: FPE-5

From information gathered during the environmental site audit, the NRC understands that Energy Harbor has not found milkweed on the Perry Plant site. Although Energy Habor has not conducted surveys to specifically assess the presence of either the monarch butterfly or milkweed on the site, Energy Harbor conducted Vegetation Index Biological Integrity surveys annually from 2015 through 2021 related to an onsite minor stream relocation project. No milkweed was identified during these surveys. Please confirm that the summary above is accurate.

VistraOps Response:

VistraOps confirms this statement is correct.

References:

None

Associated E nc l os ur es:

None

Perry Nuclear Power Plant Docket No. 50-440 VistraOps Response to NRC RCI No. FP E -7 L 083 Attachment 12 Page 1 of 1

Attachment No. 12

Federally Protected Ecological Resources (FPE)

NRC RCI Number: FPE-7

From information gathered during the environmental audit, the NRC staff understands that Energy Harbor has both corporate and site-specific environmental policies and procedures relating to Endangered Species Act (ESA) compliance. These documents summarize the requirements of the ESA, explain how these requirements apply to Energy Harbor's sites and activities, and detail the protocols and reporting procedures that Energy Harbor personnel and contractors must follow to consider listed species before undertaking activities at the Perry Plant site.

For instance, these procedures specify that a site environmental subject matter expert should identify if a planned activity or project could impact federally listed species. If an activity could affect listed species, Energy Harbor must contact the U.S. Fish and Wildlife Service (FWS) and the appropriate State natural resource agency. Specific to listed bats, if suitable habitat occurs in the area and trees must be cut, then cutting must occur between September 30 and April 1. If suitable trees must be cut during the summer months of April 2 to September 29, then a net survey must be conducted in May or June prior to cutting. Energy Harbor procedures also require personnel to consult with a subject matter expert if activities or projects may encounter caves, railroad trestles, or disturb trees other than cutting, as these are cited by the FWS as being used by listed species local to various Energy Harbor facilities.

Energy Harbors procedures detail how incidents should be logged and reported if a listed species is harmed. Energy Harbor personnel must gather detailed information about the incident and report it to the Energy Harbor wildlife team, the FWS, and the appropriate State natural resource agency, as appropriate. Such reporting would also trigger a report to the NRC under 10 CFR 50.72(b)(2)(xi), as described in Section 3.2.12 of NUREG -1022, Rev. 3, Event Report Guidelines 10 CFR 50.72 and 50.7 3.

Please confirm that the summary above is accurate.

VistraOps Response:

VistraOps confirms this summary is accurate with the clarification that wildlife team be replaced with environmental staff.

References:

None

Associated E nc l os ur es:

None Perry Nuclear Power Plant Docket No. 50-440 VistraOps Response to NRC RCI No. GE-1 and GE-2 L 083 Attachment 13 Page 1 of 2

Attachment No. 13

Geological Environment (GE)

NRC RCI Numbers GE-1 and GE-2

During the virtual audit, Energy Harbor provided reports and drawings related to shoreline erosion near to the Perry Plant site. During further discussion during the virtual and in-person site audit, the NRC staff gained a better understanding of the current state of shoreline eros ion and about historical and current erosion protection methods implemented near the plant. Please confirm that the following statements about shoreline erosion and erosion prevention plans are accurate.

1. The majority of plant shoreline is protected by riprap rocks and sheet pile arrangement.

2. Instructions to survey shoreline erosion is contained in environmental and reporting program (EMARP) No.5 titled, Monitoring of Shoreline Recession and Bluff Erosion.

Survey lines are defined in EMARP -0005.

3. The most recent erosion survey data were collected in August and September 2022.

4. Since 2018, approximately 49 feet of shoreline has been lost to erosion. The majority of this loss has occurred along a section of shoreline approximately 700 feet north-east of the Unit 1 Cooling Tower where current plant erosion protection measures end.

5. As of January 2024, a preliminary plan to place Armor Stone and Splash Zone Stone along the area of receding shoreline is confirmed. As part of this preliminary plan, Energy Harbor is in contact with the Ohio Environmental Protection Agency and the Ohio Department of Natural Resources for potential permit requirements.

6. The preliminary plan is expected to commence in May 2024, and the protection measures have an anticipated lifetime of 30- 50 years.

VistraOps Response:

VistraOps confirms the above statements are accurate with the clarification that the abbreviation EMARP stands for E nvironmental Monitoring And Reporting Program and it does not require Perry Plant staff to survey east of where the sheet piling ends. There has been some localized erosion to the east of the sheet piling and it is being visually monitored on a periodic basis. A lso,

the project to address additional shore protection is now anticipated to begin in the fall of 2024.

Perry Nuclear Power Plant Docket No. 50- 440 VistraOps Response to NRC RCI No. GE -1 and GE-2 L 083 Attachment 13 Page 2 of 2

References:

None

Associated E nc l os ur es:

None

Perry Nuclear Power Plant Docket No. 50-440 VistraOps Response to NRC RCI No. GW-2 L 083 Attachment 14 Page 1 of 2

Attachment No. 14

Groundwater (GW)

NRC RCI Numbers GW-2

During the in-person site audit, Energy Harbor provided engineering drawings of the underdrain system and the emergency service water (ESW) pumphouse for the NRC staffs review. Based on the discussio ns with the Energy Harbor staff during the in-person audit, the NRC staff gained a better understanding of the ESW system, the ESW pumphouse, and the pumped underdrain system water to the ESW forebay. Please confirm that the following statements about the ESW system, the ESW pumphouse, and the underdrain system pumpage are accurate.

1. Within the ESW pumphouse, the ESW forebay is hydraulically connected to Lake Erie.

2. The ESW suction bay is isolated from the ESW forebay unless the stop gates between the two bays are opened.

3. According to the dimensions indicated on engineering drawing 015- 0002-00000, Rev. G, the volume of the ESW forebay with the Lake Erie water surface elevation at the minimum average monthly level of 565.26 ft (USGS datum) is approximately 330, 600 gallons.

4. Water pumped from the underdrain system is discharged into the ESW forebay with a typical pumping rate of approximately 5 gallons per minute.

VistraOps Response:

VistraOps confirms the above statements are accurate with the following clarifications.

Within the ESW pumphouse, both the ESW forebay and suction bay are hydraulically connected to Lake Erie.

There are two inlets to the ESW forebay: a normal intake inlet and an em ergency inlet to be used if the normal inlet becomes unavailable. The ESW suction bay and forebay are isolated from the emergency inlet by sluice gates that, when opened, provide an alternate suction path from the discharge tunnel if the normal inlet becom es unavailable. Stop gates between the ESW forebay and the ESW suction bay are part of the screen wash system. Stop gates are not installed during normal operation.

Engineering drawing 015- 0002-00000, Rev G, reports a minimum lake water level of 565.26 ft (USGS) based on the minimum average monthly lake level of 569.3 ft less a 4.01-ft set-down from a probable maximum storm. The ESW forebay is not isolated from the suction bay during normal operation. The combined volume of the ESW forebay and suction bay at the minimum lake water level of 565.26 ft (USGS) is approximately 600,000 gallons.

Perry Nuclear Power Plant Docket No. 50- 440 VistraOps Response to NRC RCI No. GW -2 L 083 Attachment 14 Page 2 of 2

The underdrain system has a design inflow rate of 80 gallons per minute, as described in the Updated Final Safety Analysis Report (UF SAR) Section 2.4.13.5.1. Water pum ped from the underdrain system is discharged into the ESW forebay with a typical pumping rate of approximately 30 gallons per minute, as described in L R ER Section 3.6.2.2.

References:

None

Associated E nc l os ur es:

None

Perry Nuclear Power Plant Docket No. 50-440 VistraOps Response to NRC RCI No. GW-3 L 083 Attachment 15 Page 1 of 2

Attachment No. 15

Groundwater (GW)

NRC RCI Number GW-3

During the virtual and in-person audit, Energy Harbor provided clarifications relating to the underdrain system and inadvertent release of radionuclide response. Please confirm the following statements are accurate:

1. In response to a tritium detection above 2,000 pCi/L in MH -20 in December 2021, Energy Harbor implemented a documented titled Plan of Action for Operations Challenge for the issue Tritium detected in UDMH20 dated 12/16/21 - 3/28/21.

The action plan includes pumping groundwater from piezometer tubes and discharging to the radwaste treatment system. Current piezometer pumping is set to underdrain recharge rates, which vary between 5-50 gpd. A sampling plan was implemented that specified sampling piezometers 2, 3, and 20 every Thursday, Manhole 18 every other Thursday, and the ESW loops A/B/C each time the pump is started. The Tritium Action plan will remain open until MH -20 activity decreases below 1,000 pCi/L for a 2-week period or until a source is identified.

2. Pumped water in response to contaminated spills/leaks is discharged to the radwaste treatment system is recycled back to the plant if water quality specifications are met. If water quality specifications are not met, the water is discharged to the ESW forebay.

3. The following procedures are used in relation to tritium response: NOP -OP-2012 (Groundwater Monitoring), NOP -OP-4705 (Response to Contaminated Spills/Leaks), REC 0104 (Chemistry Specifications: Radwaste, Environmental, and Chemistry Instruction), and NOBP -OP-2012 (System /Work Practice Prioritization for NEI 07-07)

• Gamma radiation monitors in MH 20 and MH 23 shut down pumping of the underdrain system if gamma sensors exceed 3 times background. Gamma radiation monitors, by definition, do not detect non-gam ma-emitting radionuclid es, including tritium. Following a cessation of underdrain pumps, groundwater levels would rise until interception by th e gravity discharge system. If no intervening measures are taken (e.g., manual pumping of contaminated groundwater from the underdrain s ystem to the radwaste treatment building or to holding tanks), all radionuclides would be discharged to Lake Erie via the gravity discharge system.

Perry Nuclear Power Plant Docket No. 50-440 VistraOps Response to NRC RCI No. GW-3 L 083 Attachment 15 Page 2 of 2 VistraOps Response:

VistraOps confirms the above statements are accurate with the following clarifications.

• Tritium activity in MH-20 decreased below 1,000 pCi/L for 2 weeks in March 2022. The final Tritium Action Plan action was completed on May 15, 2023, and the Tritium Action Plan was closed in June 2023. While the Tritium Action Plan was implemented, piezometer pumping rates were set to underdrain recharge rates, which varied between 5-50 gpd.

• If makeup water quality specifications cannot be met, the water is transferred to the ESW system through a radiation-monitored flow path to the Discharge Tunnel Entrance Structure (DTES).

References:

None

Associated E nc l os ur es:

None

Perry Nuclear Power Plant Docket No. 50-440 VistraOps Response to NRC RCI No. GW-4 L 083 Attachment 16 Page 1 of 1

Attachment No. 16

Groundwater (GW)

NRC RCI Number: GW-4

During the virtual audit, it was discussed that the 2023 Annual Radioactive Effluent Release Report (ARERR) (Agencywide Docum ents Access and Management System ML23117A196) for Perry Plant incorrectly reported tritium sample results for MH -20 (table 14 on page 29 or 32).

Please c on f irm the following table reports th e correct tritium sample results fo r MH 20 and MH 23 in Q1-4 of 2022 and confirm LLD refers to lowest limit of detection.

Underdrain Quarter 1 Quarter 2 Quarter 3 Quarter 4 Manhole H-3, µCi/mL H-3, µCi/mL H-3, µCi/mL H-3, µCi/mL

20 1.53E-06 8.60E-07 5.67E-07 4.84E-07

23 <LLD 3.11E-07 <LLD 4.50E-07

VistraOps Response:

VistraOps confirms that the above table reports the correct tritium sample results for MH -20 and MH-23 in Q1-4 of 2022. The following clarifications are provided. As listed in the ARERR for year 2022 on page 4 of 32, LLD refers to lower limit of detection. Table 14 is presented on page 29 of 32 in the ARERR for year 2022.

References:

None

Associated E nc l os ur es:

None

Perry Nuclear Power Plant Docket No. 50-440 VistraOps Response to NRC RCI No. GW-5 L 083 Attachment 17 Page 1 of 1

Attachment No. 17

Groundwater (GW)

NRC RCI Number: GW-5

Please confirm the following statements in relation to tritium, gamma, or difficult to detect radionuclides:

1. No gamma or difficult to detect radionuclides were identified in piezometers, manholes, or groundwater monitoring wells at Perry Plant from January 2022 to October 2023.

2. From October 2023 to January 2024, Co-60 has been detected in Pz -6 and Pz-21 only. No other gamma or difficult to detect radionuclides have been identified in piezometers, manholes, or wells at Perry Plant.

3. Energy Harbor defines Isotopic Analysis as measuring a suite of difficult to detect radionuclides and other gamma emitting isotopes using gamma spectrometry.

VistraOps Response:

VistraOps confirms the above statements are correct with the following clarification. VistraOps defines isotopic analysis as measuring a suite of gamma-emitting isotopes using gamma spectrometry. Difficult-to-detect radionuclides (pure beta emitters) are analyzed by a contract laboratory.

References:

None

Associated E nc l os ur es:

None

Perry Nuclear Power Plant Docket No. 50-440 VistraOps Response to NRC RCI No. GW-7 L 083 Attachment 18 Page 1 of 2

Attachment No. 18

Groundwater (GW)

NRC RCI Number: GW-6

During the virtual audit, Energy Harbor provided clarifying information related to investigations of two recent releases of tritium at Perry Plant (June 2023 and January 2024). Please confirm the following statements:

1. A past leak was ruled out as the source of the June 2023 release. Other categories considered for investigation of potential sources include degraded underground piping with reactor interface and degraded plant building and piping integri ty.

2. It is currently unconfirmed if the June 2023 leak represents a cyclic leak or an active leak.

3. Low-volume pumping from piezometer 21 (PZ -21) began in July 2023 and was ongoing until the new leak investigation was launched in January 2024. The intent was to continue pumping from PZ -21 until activity in samples from that location were below 5000 pCi/L, at which point pumping would stop but monitoring would continue.

4. In response to the January 2024 leak, higher -volume pumps were installed in piezometers PZ-6, PZ-14, and PZ -21; these are being pumped to reduce the amount of contaminated water entering the underdrain system. Additional pumps may be installed depending on sampling results.

5. Groundwater pumped from piezometers associated with both the J uly 2023 and January 2024 tritium releases is discharged to the radwaste treatment building.

6. It is currently unconfirmed whether the leaks in July 2023 and January 2024 are related.

7. Total groundwater pumping at the site does not exceed 100 gpm.

VistraOps Response:

VistraOps confirms the above statements are correct.

Perry Nuclear Power Plant Docket No. 50 -440 VistraOps Response to NRC RCI No. GW -7 L 083 Attachment 18 Page 2 of 2

References:

None

Associated E nc l os ur es:

None

Perry Nuclear Power Plant Docket No. 50 -440 VistraOps Response to NRC RCI No. GW -7 L 083 Attachment 19 Page 1 of 1

Attachment No. 19

Groundwater (GW)

NRC RCI Number: GW-7

The NRC staff reviewed the Five -Year Update of Groundwater Flow Characteristics Report for Perry Nuclear Power Plant, December 24, 2020, prepared by Environmental Resources Management (Boston) during the audit period. Please confirm the following statements:

1. The 2020 report recomm ended Energy Harbor confirm consistency of management and reporting of groundwater results as described in REC -0104 and NOP -OP-2012, and fleet response to contaminated leaks/spills in NOP -OP-4705. In response, there is an open tracking action by Energy Harbor staff to revise procedures NOP -OP-2012 and NOP -

OP-4705to be aligned in reporting requirements. No revisions have been implemented as of February 14, 2023.

2. Energy Harbor completed an updated risk assessment of structures, systems, components most recently in 2019.

VistraOps Response:

VistraOps confirms the above statements are correct with the following clarifications.

Energy has two open tracking actions for revising procedures NOP-OP-2012 and NOP -OP-4705 to be aligned with reporting requirements with one tracking action per procedure revision.

• No revisions to these procedures have been implemented as of February 14, 2024.

VistraOps completed an updated risk assessment of structures, systems, and components most recently in 2022, which was finalized in 2023.

References:

None

Associated E nc l os ur es:

None

Perry Nuclear Power Plant Docket No. 50-440 VistraOps Response to NRC RCI No. HCR-2 L 083 Attachment 20 Page 1 of 1

Attachment No. 20

Historic and Cultural Resources (HCR)

NRC RCI Number: HCR-2

During the environmental audit, Energy Harbor was asked what steps were taken to identify historic properties as ER Section 3.8.3 did not describe any recent in-field surveys to identify historic properties within the 1,030- acre archaeological area of potential effect (APE). Energy Harbor answered that there have not been any cultural resource surveys done since the 1973 study described in license renewal (LR) ER section 3.8.5. Further, a review of the Ohio History Connection mapping system did not show any previously recorded archaeological site s within the Perry Plant site. Please confirm that three have been no in-field surveys to identify historic properties within the 1,030 archaeological APE since 1973.

VistraOps Response:

VistraOps confirms this statem ent is correct with the following clarification, replace three with there.

References:

None

Associated E nc l os ur es:

None

Perry Nuclear Power Plant Docket No. 50-440 VistraOps Response to NRC RCI No. HCR-3 L 083 Attachment 21 Page 1 of 1

Attachment No. 21

Historic and Cultural Resources (HCR)

NRC RCI Number: HCR-3

As part of the environmental audit, Energy Harbor was asked to provide a summary of its October 13, 2022, conversation with the Ohio State Historic Preservation Office (SHPO).

Energy Harbor summarized that after receiving the initial SHPO letter September 28, 2022, Energy Harbor requested a follow up meeting to discuss the SHPOs recommendation that an architectural survey be done as the power plant was constructed in 1974, approaching the age requirement to evaluate the facility for potential listing on the National Register of Historic Places (NRHP). In the follow up meeting, three Energy Harbor representativ es explained to the SHPO reviewer that although construction began in the early 1970s, the plant was not finished until around 1985. Therefore, the request to evaluate the plant for potential eligibility to be on the NRHP could be delayed until the buildings were closer to the 50- year mark. The SHPO reviewer agreed. Post -meeting, the SHPO reviewer sent an email to the three Energy Harbor representatives rescinding her original recomm endation and now recom mended waiting to do the architectural survey until the facility was closer to 45-50 years.

VistraOps Response:

VistraOps confirms this statement is correct.

References:

None

Associated E nc l os ur es:

None

Perry Nuclear Power Plant Docket No. 50-440 VistraOps Response to NRC RCI No. HCR-4 L 083 Attachment 22 Page 1 of 1

Attachment No. 22

Historic and Cultural Resources (HCR)

NRC RCI Number: HCR-4

During the environmental audit, Energy Harbor representatives were asked to clarify when construction of Perry Plant was com pleted. In response, they answered that th e construction was completed around 1985. They added that the caption for figure 3.8-10 should read Late Construction Photograph of the PNPP Site, August 1984. Further, they indicated that the text in LR ER Section 3.8.1 should read A general overview of the PNPP facility on the south shore of Lake Erie nearing the completion of construction of 1984 is presented in figure 3.8-10.

Please c on f irm that Perry Plant construction was completed in 1985, as well as th e change in the caption for figure 3.8-10.

VistraOps Response:

VistraOps confirms this statement is correct.

References:

None

Associated E nc l os ur es:

None

Perry Nuclear Power Plant Docket No. 50-440 VistraOps Response to NRC RCI No. HCR-5 L 083 Attachment 23 Page 1 of 1

Attachment No. 23

Historic and Cultural Resources (HCR)

NRC RCI Number: HCR-5

As part of the environmental audit, Energy Harbor was asked to provide copies of letters and other communication documents theyve received from consulting Tribes since Ma y 17, 2022, the date on the initial letters Energy Harbor issued. In response, Energy Harbor indicated that they have not received any correspondence from any consulting Tribes. Please confirm that Energy Harbor has not received any correspondence from Tribes regarding Perry Plant LR.

VistraOps Response:

VistraOps confirms this statement is correct.

References:

None

Associated E nc l os ur es:

None

Perry Nuclear Power Plant Docket No. 50-440 VistraOps Response to NRC RCI No. HCR-6 L 083 Attachment 24 Page 1 of 1

Attachment No. 24

Historic and Cultural Resources (HCR)

NRC RCI Number: HCR-6

As part of th e environmental audit, Energy Harbor was asked to provide the two procedures which aim to identify, protect, and minimize the potential of im pa c t to cultural resources within the PNPP facility. In response, Energy Harbor provided FENOC [FirstEnergy Nuclear O perating Company] Environmental Evaluations (NOP -OP-2010 R-9) and the Excavation and Trenching Controls (NOP-WM-4007 R-6) procedures for staff review.

During the environmental audit, staff inquired about whether the procedures have been im plemented before. Had they had a stop work? Were they aware if cultural resources have been encountered in past digging activities? Staff also asked for clarification in what the Chemistry Duty Manager position was (referenced in Excavation and Trenching Controls (NOP -

WM-4007 R-6).

Energy Harbor stated that steps are identified through their work process. They were unaware if any cultural resources have been found in the past. They clarified the role of the Chemistry Duty Manager and the responsibilities associated with the role. Energy Harbor mentioned that th e duty manager changes every week.

When asked if Energy Harbor had any staff who was knowledgeable in identifying cultural resources, they replied that they did not. If there was any digging to occur in undisturbed areas, they wo u ld reach out to their vendors, in particular, an environmental te am who gets pulled in to assist.

Please confirm whether the above summary is accurate. If not, clarify any in consisten cie s.

VistraOps Response:

VistraOps confirms that this statement is correct.

References:

None

Associated E nc l os ur es:

None

Perry Nuclear Power Plant Docket No. 50-440 VistraOps Response to NRC RCI No. HH-3 L 083 Attachment 25 Page 1 of 1

Attachment No. 25

Human Health (HH)

NRC RCI Number: HH-3

Please confirm as discussed during the Human Health breakout session of the January 2024 environmental virtual audit that a search of public data concerning waterborne diseases in Ohio in 2022 and 2023 was conducted and did not yield any new results from what was presented in the ER in se ct ion 3.10.1 fo r waterborne diseases in the vicinity of the plant. In addition, please confirm that no new data was available from the Centers for Disease Control and Prevention National Outbreak Reporting System and that plant records did not produce any instances of notification from local, state, or federal agencies relating to waterborne diseases or algal bloom growth and there have been no onsite observations of algae or reportable conditions of E. coli.

VistraOps Response:

VistraOps confirms this statement is correct.

References:

None

Associated E nc l os ur es:

None

Perry Nuclear Power Plant Docket No. 50-440 VistraOps Response to NRC RCI No. HH-4 L 083 Attachment 26 Page 1 of 1

Attachment No. 26

Human Health (HH)

NRC RCI Number: HH-4

Please confirm that the transmission line clearance evaluation as discussed in the ER section 3.10.2 and provided as requested for review during both the environmental virtual and onsite audit weeks for the Perry Plant license renewal application applied the 2017 issuance of the National Electrical Safety Code and all in-scope transmission lines were found to have adequate clearance. In addition, please confirm that Perry Plant defines the in-scope transmission lines shown in figure 2.2-2 and the associated text as transmission corridors with multiple transmission lines to include lines to the Perry Plant Unit 1 and Unit 2 startup transformers and the line to the main transformer.

VistraOps Response:

VistraOps confirms this statement is correct.

References:

None

Associated E nc l os ur es:

None

Perry Nuclear Power Plant Docket No. 50-440 VistraOps Response to NRC RCI No. SW-3 L 083 Attachment 27 Page 1 of 1

Attachment No. 27

Surface Water (SW)

NRC RCI Number: SW-3

Please confirm that the following monthly surface water withdrawal data are accurate.

VistraOps Response:

VistraOps confirms the monthly su rf a ce water withdrawal da ta above a re accurate.

References:

None

Associated E nc l os ur es:

None

Perry Nuclear Power Plant Docket No. 50-440 VistraOps Response to NRC RCI No. TE R -5 L 083 Attachment 28 Page 1 of 1

Attachment No. 28

Terrestrial Resources (TER)

NRC RCI Number: TER-5

From information gathered during the environmental audit, please confirm that the Perry Plant MET tower is 60 miles (m) above ground level and guyed, with steady red lights at 30m and blinking red lights at 60m.

VistraOps Response:

VistraOps confirms this statement with the exception that the Perry Plant MET tower is 60 meters (m) above ground level.

References:

None

Associated E nc l os ur es:

None

Perry Nuclear Power Plant Docket No. 50-440 VistraOps Response to NRC RCI No. WM -1 L 083 Attachment 29 Page 1 of 1

Attachment No. 29

Waste Management (WM)

NRC RCI Number: WM-1

As discussed during th e virtual audit, please c on f irm that there are no proposed changes or upgrades to the environmental m onitoring or effluent programs being considered during th e license renewal term.

VistraOps Response:

VistraOps confirms this statement is correct.

References:

None

Associated E nc l os ur es:

None

Perry Nuclear Power Plant Docket No. 50-440 VistraOps Response to NRC RCI No. WM -2 L 083 Attachment 30 Page 1 of 1

Attachment No. 30

Waste Management (WM)

NRC RCI Number: WM-2

Please c on f irm that in the event that m ixed wa ste is generated, it would be st o red in a designated storage locker and no other waste types would be stored with it. In addition, please confirm that Perry Plant staff would consult with a mixed waste treatment/ disposal vendor regarding potential disposal paths for the waste.

VistraOps Response:

VistraOps confirms this statement is correct.

References:

None

Associated E nc l os ur es:

None

Perry Nuclear Power Plant Docket No. 50-440 VistraOps Response to NRC RCI No. WM -3 L 083 Attachment 31 Page 1 of 1

Attachment No. 31

Waste Management (WM)

NRC RCI Number: WM-3

Please c on f irm that Perry Plant has adequate storage capacity to sto re th e low-level waste produced during the LR term. In addition, please confirm that the waste will be processed packaged and intermittently stored and that Perry Plant has no planned changes to how they manage the waste.

VistraOps Response:

VistraOps confirms this statement is correct.

References:

None

Associated E nc l os ur es:

None

Perry Nuclear Power Plant Docket No. 50-440 VistraOps Response to NRC RCI No. WM -4 L 083 Attachment 32 Page 1 of 1

Attachment No. 32

Waste Managem ent (WM)

NRC RCI Number: WM-4

Please c on f irm that there have been no reportable oil releases at Perry Plant under th e provisions of 40 CFR 110 in 2022, 2023 or through the audit took place in January 2024.

VistraOps Response:

VistraOps confirms this statement is correct.

References:

None

Associated E nc l os ur es:

None

Perry Nuclear Power Plant Docket No. 50-440 VistraOps Response to NRC RCI No. WM -5 L 083 Attachment 33 Page 1 of 1

Attachment No. 33

Waste Managem ent (WM)

NRC RCI Number: WM-5

Please confirm that the following describes the unplanned releases of radioactive materials since the ER was written.

a. The 2022 ARERR (ML23117A196), sections 15.1 and 15.2 describes that there were two abnormal liquid releases in 2022 associated with the Nuclear Closed Cooling and Auxiliary Boiler respectively. Both of these releases were accounted for in annual/monthly calculations, which do not exceed Offsite Dose Calculation Manual (ODCM) standards.

b. In 2023, one reportable event (reportable under 10 CFR 50.72(b)(2)(xi) occurred (NRC Event 56588). On June 23, 2023, Perry Plant reported elevated levels of tritium in the underdrain system to the State of Ohio as a non-voluntary reporting of tritium.

c. In 2024, an elevated tritium reading was identified on January 5, 2024. The 2024 occurrence was reported to the NRC under 10 CFR 50.72(b)(2)(xi) on January 4, 2024 (NRC Event 56914).

VistraOps Response:

VistraOps confirms this statement is correct with the following clarification. As documented in NRC Event 56914, the Perry Nuclear Power Plant (P NP P) staff reported to the NRC on January 5, 2024, the elevated tritium occurrence. Further, as noted in NRC Event 56914, PNPP reported elevated levels of tritium in the underdrain system to the State of Ohio as a non-voluntary reporting of tritium.

References:

None

Associated E nc l os ur es:

None

Perry Nuclear Power Plant Docket No. 50-440 VistraOps Response to NRC RCI No. WM -6 L 083 Attachment 34 Page 1 of 1

Attachment No. 34

Waste Management (WM)

NRC RCI Number: WM-6

Please confirm there have been no inadvertent releases or spills of non-radioactive contaminants at Perry Plant which would trigger a notification requirement as discussed in section 9.5.3.7 Reportable Spills [ORC 3750.06] of the ER in 2022, 2023, or through the audit in January 2024.

Vistra O ps Response:

VistraOps confirms this statement is correct.

References:

None

Associated E nc l os ur es:

None

Perry Nuclear Power Plant Docket No. 50-440 VistraOps Response to NRC RCI No. WM-7 and DECOM -1 L 083 Attachment 35 Page 1 o f 5

Attachment No. 35

Waste Management (WM) and D ecommissioning (DECOM)

NRC RCI Number: WM-7 and DECOM-1

During the virtual audit for Perry Plant, there was a detailed discussion during the waste management breakout session related to the Emergency Service Water (ESW) silt and sediment (referred to collectively here as sediment) that is being stored in the chemical cleaning lagoon and th e Unit 2 circulating water pumphouse flume area (WM -7). Because of the level of detail involved in the audit discussion, this request for confirmation of information is broken into multiple sections for ease of confirmation. Please confirm the NRCs unders tanding of the placement, storage, and monitoring of the sediment as noted in (a) through (k):

(a) Criteria to Ensure Regulatory Compliance - Placement and storage of the sediment is subject to the criteria specified by the plant Section 5.5.1 of the Plant Tec hnical Specifications (Tech Specs) which addresses the ODCM requirements to ensure compliance with 10 CFR 20, 10 CFR 50 and 40 CFR 190. These criteria are also contained in EI -200, SW/ESW Sediment Disposition.

(b) Brief History - In the early days of plant commercial operation, sediment from the ESW forebay was thought to be free from plant -derived radioactive material and was stored in a temporary pool which was breached and spilled into the storm drains. Low levels of contamination from a plant derived radionuclide (Co-60) were identified in the Minor Stream (currently called the Remnant Minor Stream) in March of 1992. The radioactivity was attributed to the precipitation of material at the liquid effluent discharge, which had already been accounted for as effluent discharge in the annual reports. The radioactive liquid effluent water entered the ESW forebay because of the design of the sluice gates between the liquid effluent and the ESW, which did not have a water - tight seal.

Sediment build up in the ESW forebay was therefore contaminated. The contaminated soil due to the overflow and spill from the retention pools and the sediments generated prior to December 1994 were processed and shipped for burial in December 1994.

Additional ESW sediment that was being stored in on site storage containers (OSSCs) remains stored at PNPPs OSSC yard. The chemical cleaning lagoon and the Unit 2 Circulating Water System Pumphouse flume area were also identified and used as storage locations for the ESW sediment.

Perry Nuclear Power Plant Docket No. 50-440 VistraOps Response to NRC RCI No. WM-7 and DECOM -1 L 083 Attachment 35 Page 2 of 5

(c) Frequency of Sediment Retrieval - Approximately every two to three years the site retrieves additional sediment. The ESW and Service Water (SW) Pump House (forebays and pump bays), the intake tunnels (normal ESW and SW tunnels) and ESW Alternate Intake tunnel are inspected at a frequency of two years or less (normally by divers or other appropriate means) per EMARP -0011, Emergency Service Water System Monitoring Program. The sediment is removed as needed to facilitate fluid flow and system operations and not to reduce the volume of radioactive materials as the sediment is produced from the lake and not from plant systems. The material removed is characterized by volume, isotopes, concentration, and total curie amount. The volume retrieved with each instance is roughly 200- 300 cubic yards on average but can range from less than 100 cubic yards to more than 400 cubic yards. The characterization data is tracked/logged in the site 10 CFR 50.75(g) file, which will be used to inform decommissioning activities.

(d) Designation - The current storage locations for the removed sediment are the Chemical Cleaning Lagoon and Unit 2 Circulating Water System Pumphouse flume area, which are located within the Protected Area, and are outside of the Radiologically Controlled Area, but they are designated as Radioactive Material Areas in accordance with 10 CFR 20 subpart I.

(e) Anticipated volume over the license renewal term - Future retrieval of the sediment throughout the period of extended operation is expected to continue at roughly same frequency and amount as during the initial licensing term. During the NRC audit, the site was asked if they had estimated the total amount of volume expected to be stored compared to the total capacity remaining in the two storage locations. A form a l calculation has not been completed to determine the ultimate storage capacity of the two storage locations for the period of extended operation, but it is reasonable to anticipate that site will need to address the issue of additional storage capacity at some point during this period of extended operation. The site does not currently have specific plans to store the sediment in additional locations. Per the procedural requirements of EMARP- 0013, Site and Environmental Inspection, the chemical cleaning lagoon, as well as other locations named in the procedure, are monitored at least once each week by qualified Chemistry staff or more frequently when significant impacts could have occurred (including but not limited to excessive rain or rainstorm erosion, construction excavating, vegetation clearance, debris, reported oil or chemical spills, etc.). If, during the period of extended operation, the capacity becomes an issue the site will address it in the corrective action program. Potential corrective actio ns may include shipping the sediment to a low -level waste facility or establishing additional onsite storage locations.

The use of any additional storage locations would undergo additional safety evaluations according to the site's 10 CFR 50.59 change eval uation process and environmental evaluation process.

Perry Nuclear Power Plant Docket No. 50-440 VistraOps Response to NRC RCI No. WM-7 and DECOM -1 L 083 Attachment 35 Page 3 of 5

(f) Corrective Action - One corrective action pursued in the 1990s was to try to reduce the contamination of the sediment by minimizing the discharge of liquid radioactive waste from the plant. The site continues to minimize the effluent concentration, but it is not feasible to reduce the levels to zero.

(g) Storage Locations for the Material - The site stated that the Unit 2 Cooling Water Pump House Basin is not being used as a storage location even though it was mentioned in a previous safety evaluation. The safety evaluation used several names to describe the Unit 2 storage area: pump house suction bay, Unit 2 circulating water pump house basin, Unit 2 circulating water suction bay, suction bay, and Unit 2 circulating water pump house. These terms are describing storage of sediment in the Unit 2 Circulatin g Water System Pumphouse flume area. The station is not storing contaminated sediment in the Unit 2 cooling tower basin (area directly under the cooling tower).

(h) Decanting/Removal of Water - The site may use both storage locations with each sediment retrieval campaign to allow for decanting water. For example, the site first pumps a portion of the sediment from the pump forebay or intake tunnel until the chemical lagoon is full of water and sediment. The site then allows for the settling of sediment from sol ution in the chemical lagoon, while they pump the sediment into the Circulating Water system pumphouse flume area. Prior to decanting the water from the chemical cleaning lagoon, it is sampled and analyzed to ensure it is in compliance with environmental release requirements in accordance with REC -0104, Chem istry Specification. The removal of water provides additional space to put more sediment in the next retrieval. Water may also be pumped out after rainfall events and is sampled in accordance with REC -0104.

(i) Extrem e Precipitation - In the event of extreme precipitation event that results in overflow of the Unit 2 Circulating Water system pumphouse flume area, the site would observe the affected results from the E 83 well and potentially Manhole #23. In the event of an extreme precipitation event that results in the overflow of the earthen berm from the Chemical Cleaning Lagoon, samples from the Remnant Minor Stream (water) would show affected results. These locations are selected directly in relationship to the Five-Year Update of Groundwater Flow Characteristics Report performed in 2020 by vendor Environmental Resource Management. The plant also performs weekly environmental surveillances of the Chemical Cleaning Lagoon, Minor Diversion Stream, and the Remnant Minor Stream, among other areas, in accordance with EMARP -0013, Site Environmental Inspection.

Perry Nuclear Power Plant Docket No. 50-440 VistraOps Response to NRC RCI No. WM-7 and DECOM -1 L 083 Attachment 35 Page 4 of 5

(j) Monitoring for Leaks - The site has certain indicators available to demonstrate if the storage locations are leaking (see above regarding extreme precipitation). If the sediment were to leak outside of the storage locations, the closes t Radiological Environmental Monitoring Program point is the Remnant Minor Stream which is sampled once every 184 days.

(k) Decanting Water and Shielding - In EI- 0200, section 6.3.1 it states, If the answer to Question 6 is NO, then determine the quantity of clean fill or water required to be placed over the sediments in the lagoon to provide shielding to reduce below the criteria. As discussed during the onsite audit, Perry has never had a need to provide shielding as noted in EI -200, but the site described that in the case that shielding with additional water were necessary to meet the ODCM limits, the site ensures they are still meeting these limits when decanting through (e.g., radiation protection programs, radiation protection procedures, etc.). If the calculated doses of the total sediment inventory in a storage location exceeds the CFR limits shown in EI -0200 section C, #6, (i.e., answer to Question 6 is NO), the storage location would be roped-off and posted in accordance with NOP-OP-4102, Radiological Posting and Labeling. Adequate shielding in the form of dirt or water would be applied in accordance with RPI -0122, Temporary Shielding Program. In accordance with RPI -0122, section 4.4.1.7.c, postings will alert personnel not to add, remove or alter temporary shielding. In addition, NOBP -OP-4009, Radworker Expectations, section 4.2.2.12 states that temporary shielding is not to be moved, modified, or removed without the approval and oversight of Radiation Protection.

A water layer used as shielding would not be decanted until the calculated dose of the sediment inventory met the regulatory limits per the requirements of EI -0200 (i.e.,

answer to Question 6 is YES). All Radiation Protection Program and Procedural requirements would remain in effect unt il that time.

Perry Nuclear Power Plant Docket No. 50-440 VistraOps Response to NRC RCI No. WM-7 and DECOM -1 L 083 Attachment 35 Page 5 o f 5

VistraOps Response:

VistraOps confirms the statements are correct with the following revised Item (e ):

(e) Anticipated volume over the license renewal term - Future retrieval of the sediment throughout the period of extended operation is expected to continue at roughly same frequency and amount as during the initial licensing term. During the NRC audit, the site was asked if they had estimated the total amount of volume expected to be stored compared to the total capacity remaining in the two storage locations. A formal calculation has not been completed to determine the ultimate stor age capacity of the two storage locations for the period of extended operation, but it is reasonable to anticipate that site will need to address the issue of additional storage capacity at some point during this period of extended operation. The site does not currently have specific plans to store the sediment in additional locations. Per the procedural requirements of EMARP -0013, Site and Environmental Inspection, the chemical cleaning lagoon, as well as other locations named in the procedure, are monit ored at least once each week by qualified Chemistry staff or more frequently when significant impacts could have occurred (including but not limited to excessive rain or rainstorm erosion, construction excavating, vegetation clearance, debris, reported oil or chemical spills, etc.). If, during the period of extended operation, the capacity becomes an issue the site will address it in the corrective action program. Potential corrective actions may include shipping the sediment to a low -level waste facility or establishing additional onsite storage locations. The use of any additional storage locations would undergo additional safety and environmental evaluations a s required.

References:

None

Associated E nc l os ur es:

None

Perry Nuclear Power Plant Docket No. 50- 440

PERRY NUCLEAR POWER PLANT UNIT 1

LICENSE RENEWAL APPLICATION ENVIRONMENTAL REVIEW

REQUESTS FOR ADDITIONAL INFORMATION Perry Nuclear Power Plant Docket No. 50-440 VistraOps Response to NRC RAI No. GEN-1 L 083 Attachment 36 Page 1 of 1 Attachment No. 36

General (GEN)

NRC RAI Number: GEN-1

REQUIREMENT: Title 10 of the Code of Federal Regulations (10 CFR) Part 51.53(c)(iv) requires that environmental reports contain any new and significant information regarding the environmental impacts of license renewal of which the applicant is aware.

ISSUE: Table B-2 of the draft Supplemental Environmental Impact Statement, Operating Permits and Other Requirements, will list the permits and licenses issued by Federal, State, and local authorities for activities at Perry, as identified in table 9.1-1 in section 9.9 in appendix E of the Perry Environmental Report (ER), dated July 3, 2023 (Agencywide Documents Access and Management System ML23184A081). As part of preparing the site-specific environmental impact statement, the staff must consider whether there have been any changes to operating permits or other requirements.

REQUEST: Please provide any relevant updates to table 9.1-1 that have transpired since the ER dated July 3, 2023. If any permits have expired since submitting the license renewal (LR) application to the U.S. Nuclear Regulatory Commission (NRC), please provide the status of those permits and/or renewals.

VistraOps Response:

The updated Table 9.1-1 is provided in Enclosure 1.

References:

None

Associated

Enclosures:

Table 9.1-1 Environmental Authorizations for Current PNPP Operations

Table 9.1-1 Environmental Authorizations for Current PNPP Operations (Sheet 1 of 2)

Agency Authority Requirement Number Expiration Date Authorized Activity Issued:

NRC Atomic Energy Act PNPP license to 11/13/1986 Operation of PNPP Unit 1.

[10 CFR Part 50] operate Unit 1 NPF-58 Expires:

11/7/2026 General license Storage of power reactor spent NRC NRC Regulations 10 for storage of fuel General License N/A fuel and other associated CFR Part 72 at power reactor radioactive materials in an ISFSI.

sites 49 USC 5180 USDOT [49 CFR Part 107, Registration Reg. No: 051922550116EG 6/30/2025 Hazardous material shipment Subpart G]

Tennessee Department of License to ship Shipment of radioactive material Environment TDEC Rule radioactive T-OH001-L24 12/31/2024 to a licensed disposal/processing and 0400-20-10-.32 material facility in Tennessee.

Conservation (TDEC)

State of Utah Authorizes waste generators, Department of Utah Administrative waste processors and waste Environmental Code Rule R313-14 Permit to ship 0112001216 5/21/2024 collectors to deliver radioactive Quality wastes to a land disposal facility located in Utah.

Hazardous waste EPA/OEPA ID #:

EPA and OEPA 40 CFR 262; OAC 3745-52 generator OHD025673518 N/A Small to large quantity generator of hazardous and mixed wastes.

registration

OEPA Clean Water Act Certification of OEPA ID No: Section 401 Water Quality Section 401 [33 USC water quality 154766 N/A Certification issued by the state 1341] standards for operation of PNPP.

Updated January 2024 Table 9.1-1 Environmental Authorizations for Current PNPP Operations (Sheet 2 of 2)

Agency Authority Requirement Number Expiration Date Authorized Activity

Federal Clean Water Act (33 USC 1251 et. Authorize discharges of PNPP OEPA Seq.), Ohio Water NPDES Permit 3IB00016*MD 9/30/2028 wastewaters and industrial Pollution Control Act stormwaters into Lake Erie.

(ORC Section 6111)

Federal Clean Air Act Air Pollution Permit-to-Install and OEPA and OAC Chapter Air Permit P0134322 8/24/2028 Operate (PTIO) natural draft 3745-31 cooling tower Permit to install OEPA OAC Chapter 3745-and operate air of 2 auxiliary boilers.

31 contaminant P0134521 6/18/2024 Operation source(s)

Ohio Department of Underground Registration of underground Commerce, OAC 1301:7-9-04 storage tank Facility #: Renewed storage Tanks T00001 through Division of registration 43007657 annually T00006.

State Fire Marshal A mineral rights lease that Lake Erie Halite prevents the extraction of the ODNR ORC Section 1506.11 Non-Extraction HNL-001-LA 5/14/2072 mineral halite within a 410-acre Lease submerged land area of Lake Erie.

ORC Section 1501.01 Lake Erie Covers approximately 3,500 ft of ODNR ORC Section 1506.10 Submerged Lands SUB-0528-LA 5/14/2072 shoreline protection and includes ORC Section 1506.11 Lease the intake and discharge tunnels.

Updated January 2024 Perry Nuclear Power Plant Docket No. 50-440 VistraOps Response to NRC RAI No. FPE-2 L 083 Attachment 37 Page 1 of 2

Attachment No. 37

Federally Protected Ecological Resources (FPE)

NRC RAI Number: FPE-2

REQUIREMENT: Licensees are required by 10 CFR 51.53(c)(3)(ii)(E) to assess the impact of refurbishment, continued operatio ns, and other license renewal -related construction activities on important plant and animal habitats. Additionally, the applicant shall assess the impact of the proposed action on threatened or endangered species in accordance with Federal laws protecting wildlife, including but not limited to, the Endangered Species Act (ESA). Additionally, the ESA regulations at 10 CFR 402.10 require Federal agencies to confer with the U.S. Fish and Wildlife Service (FWS) concerning species proposed for Federal listing under ESA Section 7.

ISSUE: The FWS published a proposed rule to list the tricolored bat (Perimyotis subflavus) as endangered under the ESA on September 14, 2022 (87 FR 56381).

REQUEST: Please provide an analysis of the potential impacts of the proposed Perr y Plant license renewal on the tricolored bat.

VistraOps Response:

The U.S. Fish and Wildlife Service (USFWS) published a proposed rule to list the tricolored bat (Perimyotis subflavus ) as endangered under the Endangered Species Act (ESA) in September 2022. The current known range for the tricolored bat overlaps with the PNPP site (USFWS 2023).

During the spring, summer and fall - collectively referred to as the non-hibernating seasons -

tricolored bats primarily roost among live and dead leaf clusters of live or recently dead deciduous hardwood trees. In the southern and northern portions of the range, tricolored bats will also roost in Spanish moss ( Tillandsia usneoides ) and Usnea trichodea lichen, respectively.

In addition, tricolored bats have been observed roosting during summer among pine needles, eastern red cedar ( Juniperus virginiana), within artificial roosts like barns, beneath porch roofs, bridges, concrete bunkers, and rarely within caves. Female tricolored bats exhibit high site fidelity, returning year after year to the same summer roosting locations. Female tricolored bats form maternity colonies and switch roost trees regularly. Males roost singly. During the winter, tricolored bats hibernate - which means that they reduce their metabolic rates, body temperatures and heart rate - in caves and mines; although, in the southern United States, where caves are sparse, tricolored bats often hibernate in road-associa ted culverts, as well as sometimes in tree cavities and abandoned water wells. Tricolored bats exhibit high site fidelity with many individuals returning year after year to the same hibernaculum. (USFWS 2023)

Perry Nuclear Power Plant Docket No. 50- 440 VistraOps Response to NRC RAI No. FPE-2 L 083 Attachment 37 Page 2 of 2

Tricolored bats have not been recorded as occurring on the PNPP site. However, PNPPs building structures and forested areas surrounding the plant potentially provide suitable roosting and maternity habitat for this species. PNPP does not currently have specific requirements to track bats on site and no specific assessment has been made of the extent or quality of tricolored bat habitat at the PNPP site. However, given the general habitat requirements of this species, it can be conservatively assumed that suitable habitat to varying degrees is present within the forested areas of the site as well as man-made structures at the site.

Potential impacts to the tricolored bat from the operations of PNPP are discussed below:

• Mortality or injury from collisions with plant structures : Bat collisions with plant structures at nuclear power plants are not well documented but are likely to be rare. There has been only one documented bat (species unknown) mortality incident at the PNPP site from 2013 through 2023.

• Loss, degradation, or disturbance of habitat : No co nstruction, land clearing, or other ground-disturbing activities are proposed for the proposed LR term that would potentially impact the habitat for the tricolored bat. Additionally, all plant operations are located in disturbed areas, and no tree clearing is proposed during the LR term that would potentially impact the habitat for the tricolored bat.

• Behavioral changes from refurbishment and/or construction activities : No construction, ground-disturbing activities, or license-related refurbishment activiti es have been identified or proposed at the PNPP site during the LR term that would potentially impact the habitat for the tricolored bat. Any bat species, if present on the PNPP site, has likely already acclimated to the noise, vibration, and general human disturbances associated with site maintenance, infrastructure repairs, and other site activities. Moreover, the undisturbed, forested areas surrounding the structures likely provide more suitable habitat; hence, it is unlikely that tri -colored bats would establish a colony in the man-made structures at PNPP. As such, behavioral changes from refurbishment and/or construction activities to tricolored bats during the LR term are unlikely.

If necessary, VistraOps would consult with USFWS to ensure compliance with th e ESA.

Compliance with all regulatory requirements associated with the federally listed species will continue to be an administrative control practiced by VistraOps for the life of the facility. The continued operation of the PNPP site for the proposed operating term will have NO EFFECT on the tricolored bat.

References:

U.S. Fish and Wildlife Service. 2023. Tricolored bat. Retrieved from

<https://www.fws.gov/species/tricolored-bat-perimyotis-subflavus> (Accessed on December 18, 2023).

Associated

Enclosures:

None Perry Nuclear Power Plant Docket No. 50-440 VistraOps Response to NRC RAI No. GE-3 L 083 Attachment 38 Page 1 of 1

Attachment No. 38

Geologic Environment (G E )

NRC RAI Number: GE-3

REQUIREMENT: 10 CFR 51.53(c)(2) requires an environmental report describe in detail the affected environment around the plant, the modifications directly affecting the environment or any plant effluents, and any planned refurbishment activities.

ISSUE: The environmental report includes figure 3.5-3, Geologic Cross -Section and Location at Perry Plant, that is of low resolution. This figure appears to be from the updated groundwater flow characteristics report (2020).

REQUEST: Provide a readable, high-resolution version of figure 6 ("Updated Conceptual Site Model Section View, Perry Nuclear Power Plant, Perry, OH) from the Energy Harbor Five-Year Update of Groundwater Flow Characteristics Report, Perry Nuclear Power Plant, dated Decem ber 24, 2020.

VistraOps Response:

A high-resolution version of the requested figure is provided in Enclosure 1.

References:

None

Associated

Enclosures:

Figure 3.5-3 Geologic Cross S ection

Perry Nuclear Power Plant Docket No. 50-440 VistraOps Response to NRC RAI No. GW-5 L 083 Attachment 39 Page 1 of 1

Attachment No. 39

Groundwater (GW)

NRC RAI Number: GW-5

REQUIREMENT: 10 CFR 51.53(c)(3)(ii)(P) requires an applicant to assess the impact of any documented inadvertent releases of radionuclides into groundwater. The assessment must include a description of any past inadvertent releases and the projected impact to the environm ent (e.g., aquifers, rivers, lakes, ponds, ocean) during the license renewal term.

ISSUE: Information was provided on the audit portal documenting the monitoring of tritium in groundwater wells, manholes, and piezometers during the period of time after the envi ronm ental report was published. This monitoring indicates the presence of radionuclides in groundwater at levels consistent with an inadvertent release.

REQUEST: Please provide on the docket the following files that were provided on the audit portal: 1) "GW wells.pdf"; 2) "Pz Manhole Tritium.pdf"; 3) "Pz and Manhole.pdf".

VistraOps Response:

The requested files that include tritium and be ta -em itte r isotopic data collected from monitoring wells, piezometers, and underdrain files are provided. Enclosure 1 inc ludes tritium and difficult-to-detect isotopic (beta em itter) analytical results for samples collected from groundwater monitoring wells and four outdoor quadrant piezometers between January 2022 and October 2023. Enclosure 2 includes tritium results for samples collected from underdrain manholes and indoor piezometers between January 2022 and January 9, 2024. Enclosure 3 includes gam ma emitter isotopic analytical results for samples collected from manholes and indoor piezom eters January 2022 through October 2023.

References:

None

Associated

Enclosures:

GW Wells Pz Manhole Tritium Pz and Manhole

MW1A IsotopicAnalysis Tritium Sampledate uCi/mL Fe55 Ni63 Sr89 Sr90 pCi/L 3/29/202211:45 < MDA <541 < 68 <0.8 <0.5 <170 11/7/20229:45 < MDA <160 6/6/20239:49 < MDA <162 7/5/20239:50 < MDA <451 < 70 <0.8 <0.5 <158 10/17/202311:50 < MDA <524 < 74 <0.6 <0.6 <171

MW1B IsotopicAnalysis Tritium Sampledate uCi/mL Fe55 Ni63 Sr89 Sr90 pCi/L 3/29/202211:30 < MDA < 554 <71 <0.9 <0.5 <170 11/7/202210:35 < MDA <160 6/6/202310:05 < MDA <162 7/5/202312:00 < MDA <454 < 70 <0.6 <0.4 <158 10/17/202311:00 < MDA <515 < 76 <0.6 <0.6 <171

MW1C IsotopicAnalysis Tritium Sampledate uCi/mL Fe55 Ni63 Sr89 Sr90 pCi/L 3/29/202212:35 < MDA <583 < 68 <0.7 <0.4 <170 11/7/20229:40 < MDA <160 6/6/202310:47 < MDA <162 7/5/202310:50 <MDA <500 < 78 <0.7 <0.5 <158 10/17/202310:45 < MDA <551 < 73 <0.6 <0.6 <171

MW2A IsotopicAnalysis Tritium Sampledate uCi/mL Fe55 Ni63 Sr89 Sr90 pCi/L 3/29/202216:05 < MDA <531 < 69 <0.8 <0.4 <170 11/7/202215:32 < MDA <160 6/6/202313:25 < MDA <162 7/6/202311:25 < MDA <467 < 71 <0.7 <0.5 <158 10/17/202314:40 < MDA <540 < 75 < 0.6 <0.6 <171

MW2B IsotopicAnalysis Tritium Sampledate uCi/mL Fe55 Ni63 Sr89 Sr90 pCi/L 3/29/202215:50 < MDA <579 < 70 <0.8 <0.5 <170 11/7/202214:25 < MDA <160 6/6/202312:27 < MDA <162 7/6/202310:30 < MDA <451 < 70 <0.7 <0.5 <158 10/17/202311:30 < MDA <512 < 74 <0.6 <0.6 <171

MW2C IsotopicAnalysis Tritium Sampledate uCi/mL Fe55 Ni63 Sr89 Sr90 pCi/L 3/31/202217:30 <MDA <531 < 68 <0.9 <0.6 <170 7/5/202314:30 < MDA <507 < 73 <0.9 <0.6 <158

• • This is adeepwellwith avery slow recharge rate, wasattemptedtosample2additional timeswith insufficientsamplepresent.

MW3A IsotopicAnalysis Tritium Sampledate uCi/mL Fe55 Ni63 Sr89 Sr90 pCi/L 3/30/202211:45 < MDA <582 < 70 <1< 0.5 <170 11/9/20229:35 < MDA 263 6/8/202311:10 < MDA 238 7/5/202311:36 < MDA <482 < 70 <0.8 <0.5 246 10/18/202310:30 < MDA <512 < 74 <0.6 <0.6 <171

MW3B IsotopicAnalysis Tritium Sampledate uCi/mL Fe55 Ni63 Sr89 Sr90 pCi/L 3/30/202211:30 < MDA <571 < 71 <0.8 < 0.5 <170 11/9/20229:30 <MDA <160 6/8/202310:35 < MDA <162 7/5/202311:25 < MDA <451 < 72 <0.7 <0.5 <158 10/18/202310:40 < MDA <524 < 76 <0.6 <0.6 <171

MW3C IsotopicAnalysis Tritium Sampledate uCi/mL Fe55 Ni63 Sr89 Sr90 pCi/L 3/30/202213:00 < MDA <564 < 69 <0.8 <0.5 <170 7/5/202312:40 < MDA <488 < 71 <0.7 <0.4 <158

• • This is adeepwellwith avery slow recharge rate, wasattemptedtosample2additional timeswith insufficientsamplepresent.

MW4A IsotopicAnalysis Tritium Sampledate uCi/mL Fe55 Ni63 Sr89 Sr90 pCi/L 3/30/202214:15 <MDA <531 < 71 <1< 0.5 <170 11/9/202211:00 < MDA 284 6/8/202312:13 < MDA 209 7/5/202313:30 < MDA <479 < 71 <0.6 <0.4 <158 10/17/202311:50 < MDA <512 < 75 <0.5 <0.5 <171

MW4B IsotopicAnalysis Tritium Sampledate uCi/mL Fe55 Ni63 Sr89 Sr90 pCi/L 3/30/202214:25 < MDA <554 < 72 <1< 0.5 <170 11/9/202211:35 < MDA <160 6/8/202312:05 <MDA <162 7/5/202313:45 < MDA <467 < 72 <0.7 <0.5 <158 10/17/202312:00 < MDA <506 < 74 <0.6 <0.6 <171

MW4C IsotopicAnalysis Tritium Sampledate uCi/mL Fe55 Ni63 Sr89 Sr90 pCi/L 3/30/202215:17 < MDA <550 < 71 <0.8 <0.4 <170 11/9/202211:55 < MDA <160 6/8/202312:40 < MDA <162 7/5/202313:50 < MDA <482 < 73 <0.7 <0.5 <158 10/17/202312:50 <MDA <527 < 74 <0.6 <0.6 <171 E283 IsotopicAnalysis Tritium Sampledate uCi/mL Fe55 Ni63 Sr89 Sr90 pCi/L 3/31/202211:23 < MDA 268 11/8/202211:20 < MDA 280 6/7/202311:55 < MDA 190 7/6/202311:20 < MDA <500 < 70 <0.6 <0.4 180 10/19/202310:30 < MDA <517 <75 <0.6 <0.6 <171

N383 IsotopicAnalysis Tritium Sampledate uCi/mL Fe55 Ni63 Sr89 Sr90 pCi/L 3/31/202210:46 < MDA 216 11/8/20229:45 < MDA 287 6/7/202311:25 < MDA 293 7/6/202310:55 < MDA <500 <71 <0.6 <0.4 352 10/19/202310:10 < MDA <527 < 76 <0.7 <0.7 217

S289 IsotopicAnalysis Tritium Sampledate uCi/mL Fe55 Ni63 Sr89 Sr90 pCi/L 3/31/202212:08 < MDA <170 11/8/202212:20 < MDA <160 6/7/202313:20 < MDA <162 7/6/202312:25 < MDA <491 < 71 <0.6 <0.5 <158 10/19/202311:45 < MDA <500 < 75 <0.6 <0.6 <171

W783 IsotopicAnalysis Tritium Sampledate uCi/mL Fe55 Ni63 Sr89 Sr90 pCi/L 3/29/202210:00 < MDA <170 11/7/202211:45 < MDA <160 6/6/202311:20 < MDA <162 7/5/202313:10 < MDA <470 < 70 <0.6 <0.4 <158 10/17/202312:50 < MDA <537 < 75 <0.6 <0.6 <171 Manhole20 TritiumAnalysis Manhole23 Tritium Analysis SampleDate uCi/mL SampleDate uCi/mL 1/1/20228:52 1.45E06 3/25/202210:31 < LLD 1/2/20227:44 1.26E06 6/16/202210:50 3.11E07 1/3/202212:15 1.49E06 6/30/202217:36 < LLD 1/4/202213:17 1.26E06 7/12/202210:40 < LLD 1/7/20229:44 2.02E06 7/21/202211:40 < LLD 1/10/202212:10 2.25E06 7/26/20229:04 < LLD 1/12/20229:20 1.84E06 8/2/20228:24 <LLD 1/14/202211:00 1.60E06 8/9/202211:48 < LLD 1/18/202215:10 1.86E06 8/16/202218:19 < LLD 1/19/202211:45 1.76E06 8/25/202210:56 < LLD 1/21/202211:21 7.31E06 8/31/20225:04 < LLD 1/22/202210:01 1.26E06 9/6/202214:04 < LLD 1/24/202211:17 1.74E06 11/4/202217:15 4.50E07 1/26/202210:40 1.44E06 11/17/202212:38 < LLD 1/28/202211:55 1.80E06 3/13/20238:55 1.16E06 1/31/202210:17 2.06E06 3/13/20238:55 1.17E06 2/2/202216:09 1.58E06 3/28/202315:20 6.24E07 2/4/202212:00 1.53E06 5/17/202310:34 2.25E07 2/7/202210:40 1.21E06 5/24/202316:19 < LLD 2/9/202212:00 1.06E06 5/29/20238:42 4.95E07 2/11/20229:10 1.60E 06 6/6/202310:57 <LLD 2/14/20229:30 1.40E06 6/9/202316:25 < LLD 2/16/202211:18 1.08E06 6/15/202314:15 6.54E07 2/21/202212:35 1.31E06 6/20/202314:35 2.70E07 2/23/202210:53 1.27E06 6/23/202311:27 3.60E07 2/25/202212:00 1.37E06 7/7/202315:55 2.50E07 3/2/202213:05 9.62E07 7/14/20239:37 < LLD 3/4/202211:30 9.90E07 7/21/202316:23 3.15E07 3/7/202214:20 1.26E06 7/28/202310:10 5.20E07 3/9/202212:00 1.11E06 7/29/202317:25 4.95E07 3/11/202211:40 1.07E06 8/1/202317:05 1.03E06 3/16/20229:00 1.05E06 8/4/202310:30 <LLD 3/18/202211:58 6.88E07 8/11/202314:20 6.30E07 3/21/202210:42 5.85E07 8/21/202311:50 9.00E07 3/23/202213:29 7.65E07 9/1/202311:38 1.21E06 3/31/202211:38 9.58E07 9/8/202315:29 < LLD 4/7/20229:54 8.17E07 9/15/20239:12 7.73E07 4/14/202210:41 < LLD 9/22/202314:38 < LLD 4/21/202215:25 1.02E06 10/3/202311:11 8.55E07 5/5/202210:56 < LLD 10/23/202311:31 2.48E 06 5/12/202215:58 < LLD 10/25/202314:35 3.44E 06 5/19/202213:58 < LLD 11/7/202316:35 1.76E06 6/16/202211:05 7.42E07 11/17/202316:04 1.60E 06 7/6/202214:00 7.20E07 12/6/202315:38 2.20E06 7/12/202210:15 5.22E07 12/20/202313:35 7.20E 07 Manhole20 TritiumAnalysis Manhole23 Tritium Analysis SampleDate uCi/mL SampleDate uCi/mL 7/21/202211:46 < LLD 1/3/20248:15 1.27E06 7/26/20229:13 < LLD 1/5/202411:46 2.57E06 8/2/20228:29 <LLD 1/7/202416:29 7.61E06 8/9/20229:38 <LLD 1/8/202410:40 2.90E06 8/14/202210:20 3.55E07 1/9/202412:45 1.20E06 8/16/202218:18 < LLD 8/25/202211:10 8.12E07 Pz15 TritiumAnalysis 8/31/20225:05 5.40E07 SampleDate pCi/L 9/6/202213:59 4.50E07 6/30/202311:26 1.08E+03 9/13/202213:15 7.64E07 7/5/202317:09 1.35E+03 9/20/202210:37 <LLD 7/12/202311:43 1.26E+03 9/27/20228:30 3.70E07 7/17/20239:26 1.33E+03 10/4/202210:30 5.73E07 7/23/20239:17 1.35E+03 10/11/202211:56 4.95E 07 7/30/20238:06 1.53E+03 10/25/202213:12 3.60E 07 8/6/202313:30 1.62E+03 11/4/202217:45 3.60E07 8/13/20239:00 1.92E+03 11/17/202212:50 6.30E 07 8/30/202314:37 < LLD 11/29/20229:44 < LLD 9/3/20239:49 1.93E+03 1/25/202310:10 1.39E06 9/17/202310:24 1.57E+03 1/31/202311:30 4.55E07 9/24/202314:30 1.17E+03 6/23/202311:36 < LLD 10/30/202310:47 1.64E+03 7/7/202316:05 2.79E07 11/8/202311:15 1.95E+03 7/14/20239:44 3.11E07 7/21/202316:13 2.70E07 Pz16 Tritium Analysis 7/28/202310:15 4.79E07 SampleDate pCi/L 7/29/202317:40 6.30E07 2/22/202214:36 < LLD 8/4/202311:27 1.36E06 7/5/202215:34 < LLD 8/11/202314:31 1.08E06 7/12/20228:22 < LLD 8/21/202311:57 7.20E07 7/19/20229:28 < LLD 9/1/202311:55 1.20E06 7/26/20229:38 < LLD 9/8/202315:22 < LLD 8/2/20228:43 4.56E+02 9/15/20239:23 < LLD 8/9/20229:33 <LLD 9/22/202314:46 < LLD 8/16/202214:45 < LLD 10/23/202311:41 1.23E 06 9/6/20229:18 4.50E+02 10/25/202314:50 1.10E 06 9/13/20228:24 7.20E+02 11/7/202316:39 1.15E06 9/20/202212:12 6.75E+02 11/17/202314:45 9.84E07 9/27/202210:25 8.13E+02 12/7/20238:50 6.75E07 10/5/20225:40 5.39E+02 12/20/202313:41 1.26E 06 11/29/202212:35 5.49E+02 1/3/20248:10 1.14E06 5/6/202313:55 4.38E+02 1/5/202411:52 9.53E07 6/27/202313:58 2.70E+02 1/7/202416:34 8.20E07 6/28/202312:48 < LLD 1/8/202410:57 < LLD 6/30/20238:48 <LLD 1/9/202410:55 < LLD 7/2/20239:17 <LLD 7/8/202311:35 3.79E+02 Pz21 Tritium Analysis Pz16 TritiumAnalysis SampleDate pCi/L SampleDate pCi/L 2/22/202214:49 4.50E+02 7/12/202311:07 2.25E+02 5/2/202317:00 4.28E+03 7/16/202312:33 3.14E+02 5/17/202315:36 6.21E+03 7/23/20239:19 4.95E+02 5/26/202315:09 8.28E+03 7/30/20238:08 6.75E+02 6/5/20239:42 1.12E+04 8/6/202313:32 8.10E+02 6/8/202314:18 1.12E+04 8/13/20239:02 7.77E+02 6/12/202315:40 1.21E+04 8/21/202316:36 1.55E+03 6/15/202317:39 1.60E+04 8/24/202317:53 9.85E+02 6/19/202316:09 1.68E+04 8/27/202310:40 1.10E+03 6/22/202315:19 4.08E+04 9/3/20239:46 1.10E+03 6/22/202315:19 3.61E+04 9/10/202311:57 9.04E+02 6/23/202310:34 1.86E+04 9/17/202310:19 8.67E+02 6/22/202315:19 4.03E+04 9/24/202314:33 9.95E+02 6/26/202310:13 3.53E+04 10/8/202310:22 9.00E+02 6/27/202314:02 2.47E+04 11/8/20239:33 2.37E+04 6/28/202312:42 2.96E+04 11/9/202312:00 2.38E+04 6/29/202315:57 3.07E+04 11/20/20239:23 2.24E+04 6/30/20238:43 3.11E+04 11/21/202316:28 2.60E+04 7/1/202312:25 3.32E+04 12/4/20230:42 2.37E+04 7/2/20239:20 3.42E+04 12/12/202311:21 2.25E+04 7/4/202315:40 3.80E+04 12/18/202315:06 2.53E+04 7/5/202316:57 3.43E+04 12/20/202314:16 2.52E+04 7/6/202317:00 3.50E+04 12/27/202310:02 2.51E+04 7/7/20239:15 4.66E+04 1/3/202413:21 2.34E+04 7/8/202311:40 5.06E+04 1/6/20241:35 2.51E+04 7/9/202316:05 5.17E+04 7/10/202318:18 5.51E+04 Pz8 TritiumAnalysis 7/11/202313:49 5.09E+04 SampleDate pCi/L 7/12/202311:10 5.12E+04 2/22/202213:56 3.60E+02 7/13/202316:38 5.19E+04 5/2/202316:50 7.20E+02 7/14/202315:25 5.50E+04 12/18/202314:39 < LLD 7/15/20236:46 5.60E+04 1/4/202413:55 4.05E+02 7/16/202313:02 4.96E+04 7/17/20239:22 5.03E+04 Pz2 TritiumAnalysis 7/19/202316:17 4.52E+04 SampleDate pCi/L 7/20/202317:36 5.44E+04 1/1/20227:52 1.96E+03 7/21/202316:49 4.98E+04 1/4/20229:38 2.00E+03 7/22/20238:13 5.10E+04 1/14/202211:49 2.10E+03 7/23/20239:22 4.90E+04 1/20/202215:40 1.83E+03 7/24/202316:45 4.76E+04 1/27/202213:45 1.62E+03 7/25/20239:13 4.60E+04 2/4/202214:55 1.48E+03 7/26/202313:30 4.83E+04 2/11/202212:56 1.52E+03 7/28/202313:30 4.94E+04 2/17/20229:30 1.21E+03 7/29/202311:30 5.43E+04 2/25/202215:45 1.76E+03 7/30/20238:13 4.87E+04 3/4/202213:18 1.17E+03 Pz21 Tritium Analysis Pz2 TritiumAnalysis SampleDate pCi/L SampleDate pCi/L 7/31/20238:00 5.10E+04 3/11/202213:06 1.31E+03 8/1/20238:10 5.19E+04 3/18/202213:05 1.19E+03 8/2/202314:35 5.10E+04 3/25/202215:20 8.55E+02 8/3/202315:45 5.27E+04 3/31/202214:15 1.17E+03 8/4/202311:35 5.10E+04 4/14/20228:57 < LLD 8/5/202316:00 4.90E+04 4/29/202216:18 1.98E+03 8/6/202313:34 4.85E+04 5/19/20229:44 7.96E+02 8/7/202315:45 5.20E+04 5/26/202213:37 1.54E+03 8/8/202314:14 5.40E+04 6/2/20228:43 1.17E+03 8/9/202317:17 5.23E+04 6/9/20229:05 1.38E+03 8/10/202314:19 5.52E+04 6/16/202213:12 1.49E+03 8/11/202315:19 4.96E+04 6/23/20229:46 3.37E+03 8/12/202311:54 4.83E+04 6/30/202214:39 3.19E+03 8/13/20239:04 5.20E+04 8/18/202222:00 3.00E+03 8/14/20239:04 5.04E+04 8/30/20228:52 2.83E+03 8/15/202310:16 5.29E+04 11/17/20228:01 3.04E+03 8/17/202314:11 5.09E+04 12/1/202214:06 3.12E+03 8/17/202322:00 5.08E+04 1/25/202310:40 2.17E+03 8/18/202323:50 3.57E+04 2/18/20234:12 1.71E+03 8/19/20230:10 3.81E+04 5/8/202317:03 2.10E+03 8/20/202317:06 5.15E+04 8/25/202321:07 2.18E+03 8/21/202316:30 4.87E+04 1/6/20248:20 1.95E+03 8/22/202317:45 4.20E+04 8/23/202317:50 4.41E+04 8/24/202317:38 4.67E+04 8/25/202320:35 3.96E+04 8/26/202313:59 4.24E+04 8/27/202310:45 3.94E+04 8/28/202323:01 3.46E+04 8/29/202323:28 3.29E+04 8/30/202314:37 3.26E+04 8/31/20230:40 3.24E+04 9/1/202316:01 1.07E+03 9/2/20238:31 3.43E+04 9/3/20239:53 3.16E+04 9/1/202316:01 3.28E+04 9/4/202315:25 2.73E+04 9/5/202314:21 3.01E+04 9/6/202315:24 2.89E+04 9/8/202315:54 2.78E+04 9/9/20237:11 2.67E+04 9/10/202311:59 2.42E+04 9/11/202315:45 2.63E+04 9/12/202310:28 2.41E+04 9/13/202310:55 2.63E+04 Pz21 Tritium Analysis SampleDate pCi/L 9/14/202323:58 2.57E+04 9/15/20230:08 2.38E+04 9/16/202310:55 2.44E+04 9/17/202310:17 2.42E+04 9/18/202313:05 2.31E+04 9/19/202312:50 2.29E+04 9/20/202316:31 2.39E+04 9/21/202312:30 1.08E+04 9/22/202316:30 9.79E+03 9/23/202313:45 2.43E+04 9/24/202314:35 2.38E+04 9/25/202316:50 2.46E+04 9/26/202314:13 2.42E+04 9/27/202316:40 2.34E+04 9/28/202316:20 2.15E+04 9/29/202310:05 2.18E+04 9/30/20238:35 2.23E+04 10/1/202313:09 2.20E+04 10/2/20239:06 2.22E+04 10/3/202310:03 1.68E+04 10/4/202311:40 1.42E+04 10/5/202316:27 1.39E+04 10/6/20239:18 1.43E+04 10/7/202313:59 1.34E+04 10/8/202310:23 1.39E+04 10/9/202315:56 1.32E+04 10/12/202315:15 1.31E+04 10/13/20237:35 1.35E+04 10/14/20236:15 1.39E+04 10/15/202311:17 1.48E+04 10/16/20238:38 1.06E+04 10/17/202314:12 1.47E+04 10/18/202316:54 9.58E+03 10/20/202312:33 1.20E+04 10/21/20238:05 1.47E+04 10/22/202312:45 1.68E+04 10/23/202315:30 1.52E+04 10/24/202312:24 1.48E+04 10/25/202311:06 1.48E+04 10/26/202315:48 1.61E+04 10/27/202310:38 1.77E+04 10/28/20236:56 1.56E+04 10/29/202310:23 1.50E+04 10/30/202310:52 1.58E+04 10/31/202313:46 1.52E+04 Pz21 Tritium Analysis SampleDate pCi/L 11/1/202311:00 1.48E+04 11/2/202312:19 1.62E+04 11/3/202313:45 1.48E+04 11/4/20231:02 1.58E+04 11/5/202310:44 1.66E+04 11/6/20239:02 1.54E+04 11/7/20238:20 1.47E+04 11/8/20239:30 1.58E+04 11/9/202311:58 1.67E+04 11/10/202314:33 1.73E+04 11/11/20238:52 1.55E+04 11/12/20239:20 1.60E+04 11/13/202310:20 1.54E+04 11/14/202311:13 1.62E+04 11/15/20239:13 1.50E+04 11/16/202318:47 1.59E+04 11/17/202314:02 1.51E+04 11/18/202311:28 1.55E+04 11/19/202310:03 1.69E+04 11/20/20239:20 1.57E+04 11/21/202316:26 1.64E+04 11/22/20231:30 1.43E+04 11/23/20232:37 1.65E+04 11/24/20231:20 1.51E+04 11/25/202311:03 1.65E+04 11/26/202310:11 1.57E+04 11/27/202314:11 1.62E+04 11/28/202317:18 1.59E+04 11/29/202312:35 1.64E+04 11/30/202310:00 1.60E+04 12/1/20233:00 1.58E+04 12/2/20233:08 1.52E+04 12/3/202313:02 1.62E+04 12/4/20230:47 1.61E+04 12/5/20237:55 1.56E+04 12/6/202313:42 1.66E+04 12/7/20238:52 1.77E+04 12/8/202310:01 1.75E+04 12/9/20236:44 1.84E+04 12/10/20238:19 1.52E+04 12/11/202311:54 1.89E+04 12/12/202311:18 1.91E+04 12/14/202310:19 2.07E+04 12/14/202313:50 2.18E+04 12/15/20238:37 2.32E+04 Pz21 Tritium Analysis SampleDate pCi/L 12/16/20238:16 2.43E+04 12/17/202311:06 2.19E+04 12/18/202315:08 2.28E+04 12/19/202313:23 2.29E+04 12/20/202314:18 2.34E+04 12/21/20238:30 2.35E+04 12/22/20238:25 2.46E+04 12/23/202311:29 2.50E+04 12/24/20239:00 2.38E+04 12/25/202312:57 2.40E+04 12/26/20239:04 2.38E+04 12/27/202310:00 2.50E+04 12/29/202313:45 2.06E+04 12/30/20237:58 2.33E+04 12/31/20237:20 2.41E+04 1/1/202413:14 2.46E+04 1/2/20249:36 2.59E+04 1/3/202413:23 2.45E+04 1/4/20248:29 2.39E+04 1/5/20248:16 2.49E+04 1/6/20249:31 2.65E+04 1/7/20248:07 8.37E+04 1/8/202413:19 8.85E+04 Pz1 TritiumAnalysis Pz10 TritiumAnalysis SampleDate pCi/L SampleDate pCi/L 1/1/20227:56 4.14E+03 2/22/202214:11 6.75E+02 1/4/20228:45 3.80E+03 5/9/202312:19 4.57E+02 1/14/202211:54 3.47E+03 1/5/202415:29 2.41E+03 1/20/202215:35 2.80E+03 1/27/202213:47 2.96E+03 Pz12 TritiumAnalysis 2/4/202214:46 2.65E+03 SampleDate pCi/L 2/11/202212:53 2.01E+03 2/22/202214:19 4.95E+02 2/16/202211:08 1.30E+03 4/21/20228:24 5.85E+02 2/16/202211:24 1.12E+03 6/1/202211:03 9.09E+02 2/25/202215:40 9.27E+02 6/6/20229:57 6.30E+02 3/4/202213:20 7.20E+02 6/8/202217:00 1.93E+03 3/11/202213:12 5.40E+02 6/13/202216:15 1.93E+03 3/18/202212:58 <LLD 6/15/202210:00 1.50E+03 4/21/20228:13 6.75E+02 6/22/202217:25 1.71E+03 5/8/20238:02 8.75E+02 6/29/20225:27 2.20E+03 1/6/20248:14 7.84E+02 7/6/202212:15 1.98E+03 5/2/202316:20 7.23E+02 Pz13 TritiumAnalysis 6/24/202310:50 4.05E+02 SampleDate pCi/L 6/30/202311:22 <LLD 1/3/202212:05 3.68E+03 1/5/202415:39 1.39E+03 1/6/202214:17 4.83E+02 1/17/202215:30 3.21E+03 Pz14 TritiumAnalysis 1/20/202217:15 2.19E+03 SampleDate pCi/L 1/27/202213:03 3.59E+03 2/22/202214:31 <LLD 2/4/202213:00 5.40E+03 4/21/20228:31 3.60E+02 2/11/202213:55 5.54E+03 6/1/202211:37 4.97E+02 2/17/202210:35 4.72E+03 6/6/202210:15 4.50E+02 2/25/202215:50 1.32E+03 6/8/202216:50 7.65E+02 3/4/202211:20 1.80E+03 6/13/202216:05 5.85E+02 3/11/202213:44 2.02E+03 6/15/20229:52 <LLD 3/18/202217:40 2.27E+03 6/22/202217:15 <LLD 3/25/202216:15 2.38E+03 6/29/20225:30 1.84E+03 3/31/202214:38 2.98E+03 7/5/202215:37 4.05E+02 4/7/202214:15 3.02E+03 7/12/20228:14 5.99E+02 4/14/202216:50 2.27E+03 7/19/20229:30 4.00E+02 4/21/20228:20 4.36E+03 7/26/20229:35 4.62E+02 4/29/202216:35 2.16E+03 8/2/20228:45 9.94E+02 5/5/202215:01 1.39E+03 8/9/20229:28 2.61E+03 5/12/202213:45 2.08E+03 8/16/202214:55 3.42E+03 5/19/202216:55 1.69E+03 8/30/20229:57 2.47E+03 5/26/202213:56 2.22E+03 9/6/20229:21 1.62E+03 6/1/202211:07 2.14E+03 9/13/20228:27 2.02E+03 6/6/20229:56 2.25E+03 9/20/202212:10 1.12E+03 6/8/202216:55 2.65E+03 9/27/202210:28 1.65E+03 6/13/202216:10 2.34E+03 10/5/20225:35 1.12E+03 Pz13 TritiumAnalysis Pz14 TritiumAnalysis SampleDate pCi/L SampleDate pCi/L 6/15/20229:57 1.38E+03 11/29/202212:33 2.17E+03 6/16/202214:05 1.31E+03 5/2/202316:55 5.09E+03 6/22/202217:20 1.35E+03 5/17/202315:45 3.78E+03 6/29/20225:25 <LLD 5/26/202315:15 3.55E+03 7/5/202215:45 2.61E+03 6/5/20239:45 3.51E+03 7/12/20228:28 2.91E+03 6/8/202314:12 3.53E+03 7/19/20229:34 3.63E+03 6/12/202315:35 3.42E+03 7/26/20229:43 3.80E+03 6/19/202316:05 3.27E+03 8/2/20228:37 3.41E+03 6/26/202310:16 2.97E+03 8/9/20229:38 2.18E+03 6/27/202313:54 2.88E+03 8/16/202215:07 3.86E+03 6/28/202312:55 3.28E+03 8/30/20229:52 4.36E+03 6/30/20238:52 3.47E+03 9/6/20229:13 2.74E+03 7/2/20239:13 3.19E+03 9/13/20228:32 3.33E+03 7/4/202314:50 3.09E+03 9/20/202212:17 3.01E+03 7/8/202311:33 3.58E+03 9/27/202210:18 3.27E+03 7/12/202311:04 3.42E+03 10/5/20225:30 2.65E+03 7/16/202312:27 3.65E+03 10/25/202211:45 1.79E+03 7/17/20239:18 3.82E+03 11/15/202213:11 2.26E+03 7/23/20239:14 4.81E+03 11/29/202212:39 1.66E+03 7/24/202316:25 4.41E+03 5/2/202316:25 2.58E+03 7/30/20238:03 3.96E+03 6/30/202311:20 1.62E+03 8/6/202313:27 4.05E+03 7/4/202314:42 2.08E+03 8/13/20238:58 4.26E+03 1/5/202410:30 1.13E+03 8/21/202316:44 3.61E+03 1/7/202411:39 1.09E+03 8/27/202310:38 3.97E+03 1/8/202415:48 2.30E+03 9/3/20239:39 3.44E+03 1/9/20249:35 2.96E+03 9/5/202314:17 2.88E+03 9/10/202311:52 2.38E+03 Pz3 TritiumAnalysis 9/17/202310:26 2.35E+03 SampleDate pCi/L 9/24/202314:28 1.24E+03 1/1/20227:49 1.36E+04 10/8/202310:12 1.93E+03 1/4/20228:50 1.33E+04 11/8/20239:35 1.77E+03 1/14/202211:56 1.39E+04 1/3/202413:16 7.89E+03 1/20/202215:30 1.17E+04 1/7/202411:15 8.61E+03 1/27/202213:50 1.15E+04 1/8/202413:55 8.58E+03 2/4/202214:42 1.18E+04 1/9/20249:59 8.11E+03 2/11/202212:50 1.14E+04 2/16/202211:54 1.20E+04 Pz4 TritiumAnalysis 2/16/202212:06 1.30E+04 SampleDate pCi/L 2/25/202215:37 8.26E+03 2/14/202210:15 7.92E+02 3/4/202213:14 6.12E+03 5/8/20238:00 3.03E+02 3/11/202213:14 5.77E+03 7/11/202313:21 <LLD 3/18/202212:55 7.10E+03 7/26/202316:00 1.26E+03 3/25/202215:10 6.79E+03 8/1/202310:59 6.30E+02 3/31/202214:17 5.79E+03 8/8/202312:40 <LLD Pz3 TritiumAnalysis Pz4 TritiumAnalysis SampleDate pCi/L SampleDate pCi/L 4/7/202215:16 5.69E+03 8/15/20239:50 1.12E+03 4/14/20228:46 5.09E+03 8/22/202317:27 1.11E+03 4/21/20228:10 6.34E+03 9/5/20238:56 8.10E+02 4/29/202216:15 5.25E+03 9/12/20239:05 <LLD 5/5/202215:00 4.29E+03 9/19/202313:20 <LLD 5/12/202213:30 5.08E+03 10/3/202315:08 4.95E+02 5/19/20229:41 3.66E+03 11/3/202315:45 <LLD 5/26/202213:39 4.24E+03 12/3/202119:31 4.95E+02 6/2/20228:39 3.86E+03 12/18/202315:02 < LLD 6/9/20229:08 4.33E+03 1/2/202411:08 1.02E+03 6/16/202213:06 3.96E+03 6/23/20229:54 4.05E+03 Pz5 TritiumAnalysis 6/30/202214:39 4.27E+03 SampleDate pCi/L 8/30/20228:54 3.68E+03 2/11/202213:50 1.11E+03 11/17/20228:03 3.90E+03 2/14/202211:20 8.97E+02 11/29/202214:15 3.85E+03 4/29/202216:30 6.12E+02 1/25/202310:35 1.52E+03 5/2/202316:45 <LLD 5/8/20237:59 1.08E+03 6/24/202310:42 <LLD 6/24/202311:12 1.08E+03 6/28/202312:19 <LLD 12/16/202312:17 9.00E+02 7/4/202314:56 <LLD 1/2/202411:05 1.26E+03 9/5/202314:10 7.06E+02 1/6/20248:06 8.77E+02 12/16/20238:22 <LLD 12/18/202314:41 < LLD Pz11 TritiumAnalysis 1/2/20249:42 <LLD SampleDate pCi/L 1/5/202410:53 <LLD 2/22/202214:15 <LLD 1/7/202411:18 <LLD 8/18/202216:00 6.71E+02 1/8/202413:48 <LLD 2/17/202315:14 5.40E+02 1/9/20249:53 <LLD 5/9/202314:57 4.07E+02 8/28/202323:20 1.57E+03 Pz7 TritiumAnalysis 1/5/202415:36 1.16E+03 SampleDate pCi/L 2/11/202213:52 <LLD 8/18/202222:15 <LLD 11/16/202216:26 < LLD 2/17/202314:28 4.05E+02 5/2/202316:40 6.75E+02 6/24/202310:45 2.25E+02 8/17/202322:25 3.60E+02 9/8/202312:00 <LLD 12/16/20238:26 <LLD 12/17/202311:02 3.93E+03 12/18/202311:43 < LLD 1/4/202414:00 <LLD Pz6 TritiumAnalysis Pz9 TritiumAnalysis SampleDate pCi/L SampleDate pCi/L 2/22/202213:51 4.95E+02 2/22/202214:01 <LLD 4/21/20228:29 4.05E+02 8/18/202216:24 6.75E+02 8/18/202216:11 1.08E+03 2/17/202314:23 4.50E+02 2/18/20233:30 6.96E+02 5/9/202312:05 5.00E+02 5/2/202316:35 2.65E+03 6/27/202313:45 1.80E+02 5/16/202317:19 2.00E+03 6/28/202312:11 <LLD 5/26/202315:04 1.89E+03 6/30/20239:26 <LLD 6/5/20239:48 1.71E+03 7/2/20239:05 <LLD 6/8/202314:08 1.83E+03 7/4/202315:02 <LLD 6/12/202315:30 1.44E+03 7/11/202314:55 <LLD 6/19/202316:15 1.64E+03 7/25/20239:19 4.78E+02 6/26/202310:19 1.53E+03 8/1/202311:00 1.26E+03 6/27/202313:51 1.17E+03 8/8/202314:07 <LLD 6/28/202312:25 1.56E+03 8/15/202310:23 6.75E+02 7/2/20238:58 1.47E+03 8/17/202322:17 3.60E+02 7/11/202315:03 1.40E+03 8/24/202318:02 9.06E+02 7/17/20239:15 1.08E+03 8/30/202314:28 <LLD 7/24/202316:22 1.53E+03 9/5/202314:13 1.01E+03 8/1/202311:05 1.84E+03 9/12/202310:22 <LLD 8/8/202314:02 1.15E+03 9/19/202312:40 3.47E+02 8/15/202310:19 8.55E+02 10/3/202310:16 9.90E+02 8/17/202322:07 9.45E+02 11/3/202313:50 8.10E+02 8/28/202322:55 1.53E+03 12/4/20230:40 7.29E+02 9/12/202310:25 8.29E+02 1/4/202413:57 1.17E+03 9/19/202312:36 6.99E+02 1/6/20245:19 1.21E+03 10/3/202310:09 1.39E+03 12/4/20230:42 1.25E+03 12/18/202314:45 8.42E+02 1/4/202414:03 2.91E+05 1/5/20248:13 5.50E+05 1/6/20249:34 7.99E+05 1/7/20248:02 9.39E+05 1/8/202421:30 9.46E+05 1/9/20249:55 9.38E+05 Manhole20 Isotopic Analysis Manhole23 IsotopicAnalysis Sampledate uCi/mL Sampledate uCi/mL 6/16/202211:05 0.00E+00 3/28/20220:55 0.00E+00 8/25/202211:10 0.00E+00 6/16/202216:52 0.00E+00 10/25/202213:12 0.00E+00 8/25/202216:57 0.00E+00 12/13/202214:38 0.00E+00 11/5/20221:11 0.00E+00 12/14/20228:30 0.00E+00 12/13/202214:15 0.00E+00 1/31/202311:30 0.00E+00 12/15/202213:50 0.00E+00 6/23/202311:36 0.00E+00 3/13/20238:55 0.00E+00 9/1/202311:55 0.00E+00 6/8/202316:25 0.00E+00 10/23/202311:41 0.00E+00 9/1/202311:38 0.00E+00 10/23/202311:31 0.00E+00

Pz21 IsotopicAnalysis Pz14 IsotopicAnalysis Sampledate uCi/mL Sampledate uCi/mL 6/8/202314:18 0.00E+00 6/8/202314:12 0.00E+00

Pz11 IsotopicAnalysis Pz2 IsotopicAnalysis Sampledate uCi/mL Sampledate uCi/mL 8/18/202216:00 0.00E+00 8/18/202222:00 0.00E+00 2/17/202315:14 0.00E+00 2/18/20234:12 0.00E+00 8/28/202323:20 0.00E+00 8/25/202321:07 0.00E+00

Pz6 IsotopicAnalysis Pz7 IsotopicAnalysis Sampledate uCi/mL Sampledate uCi/mL 8/18/202216:11 0.00E+00 8/18/202222:15 0.00E+00 2/18/20233:30 0.00E+00 2/17/202314:28 0.00E+00 6/8/202314:08 0.00E+00 8/17/202322:25 0.00E+00 8/17/202322:07 0.00E+00

Pz9 IsotopicAnalysis Manhole18 IsotopicAnalysis Sampledate uCi/mL Sampledate uCi/mL 8/18/202216:24 0.00E+00 10/9/202314:38 0.00E+00 2/17/202314:23 0.00E+00 10/20/20238:47 0.00E+00 8/17/202322:17 0.00E+00

Manhole21 Isotopic Analysis Manhole22 IsotopicAnalysis Sampledate uCi/mL Sampledate uCi/mL 12/13/202213:14 0.00E+00 12/13/202213:06 0.00E+00 Manhole24 Isotopic Analysis Manhole6 IsotopicAnalysis Sampledate uCi/mL Sampledate uCi/mL 1/15/202210:52 0.00E+00 10/19/20238:42 0.00E+00 3/16/202216:52 0.00E+00 10/19/20238:43 0.00E+00 3/23/202213:34 0.00E+00 3/30/202214:12 0.00E+00 Manhole7 IsotopicAnalysis 4/6/202217:30 0.00E+00 Sampledate uCi/mL 4/17/20228:30 0.00E+00 9/7/202317:40 0.00E+00 4/21/202214:05 0.00E+00 10/19/20238:54 0.00E+00 Perry Nuclear Power Plant Docket No. 50-440 VistraOps Response to NRC RAI No. HCR-1 L 083 Attachment 40 Page 1 of 2

Attachment No. 40

Historic and Cultural Resources (HCR)

NRC RAI Number: HCR-1

REQUIREMENT: Section 106 of the National Historic Preservation Act [54 USC §306108])

directs Federal agencies to take into account the effect of the undertaking on any district, site, building, structure, or object that is included in or eligible for the National Register of Historic Places within the area of potential effect.

ISSUE: As part of information needs provided to Energy Harbor, HCR -1 asked about potential ground-disturbing activities that would be part of ongoing maintenance, inspection, and refueling activities as part of the proposed action. Many times, ongoing maintenance includes ground disturbance. Energy Harbor was asked what procedures were in place to guarantee that historic and cultural resources would not be impacted by those activities.

Energy Harbor responded in writing that there werent current plans to do ground-disturbing activities as part of the license renewal application except those to maintain existing structures and operations. Any digging that would be associated with those actions would be in previously disturbed areas. If any projects were to occ ur in undisturbed portions of their site, the project would undergo an environmental review, and if applicable, cultural resource surveys would be conducted.

During the environmental audit, staff inquired if there had ever been a project that occurred in undisturbed areas, and if so, how were their procedures applied. Specifically, did they do a cultural resource survey and if one was done, what were the results of the survey?

REQUEST: Answer the following:

1. Has there been an instance within Energy Harbor property, specifically the 1,030- acre project area, were a ground disturbing activity occurred outside disturbed areas?

2. If so, how were Energy Harbors procedures applied?

3. If an environmental review was done and a cultural resource survey was applicable, provide the results of that survey.

Perry Nuclear Power Plant Docket No. 50- 440 VistraOps Response to NRC RAI No. HCR-1 L 083 Attachment 40 Page 2 of 2

VistraOps Response:

1. The boundaries of previously disturbed areas have not been officially established. The work process does not require advance preparation for activities that may occur in previously undisturbed areas. Work control documents require activities to cease if Archaeological, Cultural or Historical Resources are encountered. If such a situation arises, the PNPP environmentalist is notified, and the appropriate experts are notified.

The project to relocate the Minor Stream likely occurred, at least in part, in previously undisturbed areas.

2. As stated above, VistraOps procedures would have directed actions if artifacts or remains were discovered.

3. An environmental review was performed prior to the Diversion Stream Implementation Project. No Cultural Resource Survey was performed.

References:

None

Associated E nc l os ur es:

None

Perry Nuclear Power Plant Docket No. 50-440 VistraOps Response to NRC RAI No. HCR-6 L 083 Attachment 41 Page 1 of 2

Attachment No. 41

Historic and Cultural Resources (HCR)

NRC RAI Number: HCR-6

REQUIREMENT: 10 CFR 51.41 indicates that NRC may direct the applicants to provide NRC information to complete the National Environmental Policy Act process. NUREG -1555 states that the applicants cultural resource protection procedures or Cultural Resource Management Plans may be requested.

ISSUE: In reviewing the two procedures Energy Harbor provided to identify, protect, and minimize the potential of impact to cultural resources within the Perry Plant facility, neither procedure mentioned the work process that would occur in the event that human remains were to be inadvertently discovered.

REQUEST: Describe what workflow process would be enacted if human remains were to be encountered in the field, including coordination with the local coroners office and the State Historic Preservation Offices. If the process is captured in a procedure other than FENOC

[FirstEnergy Nuclear Operating Com pany] Environmental Evaluations (NOP -OP-2010 R-9) and Excavation and Trenching Controls (NOP -WM-4007 R-6), provide excerpts from the procedure for NRC staffs review, it possible.

VistraOps Response:

Section 3.2 of NOP-WM-4007 R-6, Excavation and Trenching Controls, defines an Archaeological, Cultural and Historical (AC&H) Resource:

Archaeological, Cultural and Historical (AC&H) Resource - Item considered to be of cultural importance to the community, state or nation, including but not limited to graves, ar chaeological sites, pottery, tools, weaponry and other implements, ritual artifacts and discarded materials (i.e., Indian mounds with shells and animal bones) typically, 50 or more years old.

In this description, human remains would be included in the contents of graves. If a grave is encountered, NOP -OP-4007, Section 4.5.16 requires the work to stop. Section 4.5.17 r equires an evaluation, and notifications as necessary. Work may not continue until the situation is addressed and a course of action is deter m ined.

If an AC&H Resource is discovered during any excavation, it would meet the threshold for generating a condition report and be tracked in the correcti ve action program.

Perry Nuclear Power Plant Docket No. 50- 440 VistraOps Response to NRC RAI No. HCR-6 L 083 Attachment 41 Page 2 of 2

References:

None

Associated E nc l os ur es:

None

Perry Nuclear Power Plant Docket No. 50-440 VistraOps Response to NRC RAI No. TER-1 L 083 Attachment 42 Page 1 of 1

Attachment No. 42

Terrestrial Resources (TER)

NRC RAI Number: TER-1

REQUIREMENT: 10 CFR 51.53(c)(iv) requires that environmental reports contain any new and significant information regarding the environmental impacts of license renewal of which the applicant is aware.

ISSUE: As part of information needs provided to Energy Harbor, TER -1 asked about records of bird mortality and nesting from the Perry Plant site from 2013-2023. Energy Harbor provided a summary of these incidents, along with individual condition reports prepared for each incident.

REQUEST: Please provide a complete Perry Plant site bird incident report from 2013-2023, in chronological order, that contains all incidents (at least 22 incidents): (a) Add the following 5 incidents to the draft incident report: 08191016, 10272017, 05172018, 01282018, 07262021, (b) injured peregrine falcon described in the ER 3.7.7.2 (discovered at PNPP on January 28,2022 and taken to a rehab center), (c) If avian incidents occurred in 2014, 2019, 2020, or 2023, add them to the report. Otherwise, provide a statement that no avian incidents occurred during these years.

VistraOps Response:

The updated PNPP Bird Incident Report, included in Enclosure 1, contains all bird incidents at PNPP from 2013 -2023. There was a total of 20 (not 22) bird incidents from this time period, as explained below in (a).

(a) Incidents 08191016 and 01282018 correspond to CR -2016-10009 and CR -2018-000814 that were part of the 16 incidents summarized in the initial summary provided. T h ree additional incidents (10272017, 05172018, 07262021) and the injured peregrine falcon information have been added to the new PNPP B ird Incident Report provided in Enclosure 1.

(b) Added, as stated above in (a).

(c) No avian incidents were repor ted at PNPP during 2014, 2019, 2020 and 2023.

References:

None

Associated

Enclosures:

PNPP B ird Incident Report Sl.No Avian Incident Report#CR Identifier Origination Date Originator DueDate Title DiscoverDate EventDate Description ImmediateActions Taken RecommendedActions AssignedOrganization Contact CorrectiveActions Taken

1 N/A CR201313211 08/26/2013 Henslee, Dianna L 09/25/2013 Twodeceased birds were found on PNPP property 08/22/2013 08/22/2013 Problem Statement: twodeceasedbirds were found on PNPP property.Contactedregulatory affairs priortoproceedingwith anytelephone conversations toanyDocumentedfortrackingand trendingno furtheraction PYOPCHEM;PYChemistry DiannaHenslee agencyperprocedurePAP 0808Section 4.2.1. required.

Consequences:None Contacted Control Room Contacted the bird bandingoffice toreportboth deceased birds.

Detail:Anemployeeworkingbyunit 2cooling tower contactedtheenvironmental specialist regardingadeceased peregrine falcon. The environmental specialist(s) verified the carcass was indeed a peregrine falcon (ID No. 1126 14021/ 24B). On the same day, another employee working in the Unit 1 transformer yard also contacted the environmental specialist regarding another deceased bird. The environmental specialist verified the deceasedbird but due to the decomposition was unable to identify the species (ID No. AU 2012 MAL 527).

The telephone number on the bird was contacted by regulatory affairs representative, chemistrysupervisorand environmental specialist. The peregrine falcon found by the U2 cooling tower is not an endangered species and no reporting requirements are required. Per the banding hotline the peregrine falcon was banded in Ohio in CY 2010.

The bird found in the transformer yard was a pigeon. The proper owner of the pigeon was contacted regarding the death of his bird.

2 N/A CR201516350 12/04/2015 Gehring Ohrablo, 01/01/2016 Deadhawkfound atISFSI pad 12/04/2015 12/04/2015 Areportwasmadeto Chemistrythatadeadbird wason theISFSI pad. Inaccordancewith guidance in PAP 0808, RetrieveddeadbirdfromISFSI pad.AC.Nofurtheractions necessary. PYOPCHEM;PYChemistry Veitch KristineM CorporateEnvironmental wascontacted. CorporateEnvironmental indicated thatthedeadbird should bePhotos sent to Corporate Environmental.

retrieved and photographed. The bird was retrieved and photos were taken and sent to Corporate Environmental. Corporate Environmental identified dead birdasabroad winghawknot anendangered Corporate Environmental identified the dead bird as a broad wing hawk. They indicated that this bird is NOT an species.

endangered species. CorporateEnvironmental contactedtheOhio DepartmentofNaturalResources(ODNR) regarding the dead hawk.

PotentialConsequence:None,asbird is not ofanendangeredspecies. ODNRindicated thatthecorpseshould bedouble baggedand disposed ofin thetrash.Asper the Migratory Bird Treaty Act, no parts of the hawk can be possessed by anyone.

NotifiedCorporateEnvironmental, Perry Environmental Specialist, ChemistryManager, and Shift Manager of event and resolution.

3 N/A CR201516494 12/08/2015 Zak, Timothy J 01/07/2016 Dead bird found on driveway westoftheWater Treatment 12/08/2015 12/08/2015 Problem:Corporate Environmental SME was notifiedperPAP 0808.Pictureswere senttotheSME ofboth PYOPCHEM;PYChemistry TimZak Building DeadbirdfoundonPlantsite. the bird and numbering on the band. SME emailed back that the bird was a carrier pigeon with band number LM 301 and should be discarded. She further stated that she would report the Consequences: band number to the owner on their website.

Corporate Environmentalno"ed,SMEtracksallavian(bird)eventsandgivesdireconastohandling.

ControlRoomwasnotified.

Details:

Adeadbird wasfound westoftheWater treatment Building on thedriveway.Chemistrywasnotified.

4 N/A CR201600074 01/04/2016 Zak, Timothy J 02/03/2016 Dead bird found in theCirc. Water Building 01/04/2016 01/04/2016 Problem:ApicturewassenttotheCorporateSME,perPAP0808.ACRwaswrittentotrack this event. ACNofurtheractions necessary. PYOPCHEM;PYChemistry DavidDuesing DeadbirdfoundintheCirc.Wa terBuilding.

Consequences:

Corporate Environmentalwasnotified, picturewassentviaemail. SME tracks all avian(bird events, and gives direcon as to handling.

Details:

A dead birdwasfound in theCirc. Water Building. Chemistrywasnotified and apicturewassenttotheCorporate SME. This CR was written to track this event.

5 N/A CR201602189 02/15/2016 Zak, Timothy J 03/16/2016 Dead bird wasfound in theRadWastealleyway 02/15/2016 02/15/2016 Problem:ApicturewassenttotheCorporateSME,perPAP0808.ACRwaswrittentotrack this event. PY OPCHEM;PYChemistry TimZak DeadbirdwasfoundintheRadWa stealleyway.

Consequences:

Corporate Environmentalwasnotified, picturewassentviaemail. SME tracks all avianbird events, and provides direcon on how to handle.

Detail:

A dead birdwasfound in theRadWastealleyway.Chemistrywasnotified and apicturewassenttotheCorporate SME. This CR was written to track the event.

6 N/A CR201602539 02/23/2016 Zak, Timothy J 03/24/2016 Dead bird found in frontoftheWarehouse6Kinneardoor 02/23/2016 02/23/2016 Problem:Pictureswere senttotheCorporateSME,perPAP0808.This CRwaswrittentotracktheevent. PYOP CHEM;PYChemistry TimZak Dead birdwasfound in frontoftheWarehouse6Kinneardoor.

7 N/A CR201603804 03/23/2016 Zak, Timothy J 04/22/2016 Dead birds found eastoftheFuel Handling Building 03/23/2016 03/23/2016 Problem:Awrittendescription oftheeventand pictureswere senttotheCorporateEnvironmental SME,PYOPCHEM;PYChemistry TimZak Therewere seven deadbirds foundon theeastsideoftheFuel Handling Building. per PAP0808.

8 N/A CR201604489 04/03/2016 Hudson, Warren D 05/03/2016 HousekeepingIssueTB#2647levelhasdeadbirds and bird 04/03/2016 04/03/2016 Problem:Deadbirds and bird droppings nexttotravelpath could causehealth concerns.NotifiedSecurityShift Supervision CleaningcrewwithproperPPEand cleaning equipment PYOPIS;PYIndustrial Safety CurtisRobinson Problem:While heading toasecuritypost traversing on the droppingsnexttotravel path remove the dead birds and droppings from the area. Place walkway on Turbine Bldg #2 647 level there were dead birds Whileheading toasecuritypost traversing on thewalkway on Turbine Bldg#2647levelthere were deadbirds and hand sanitizers at the top of the stairs and bottom of the and piles of bird droppings covering a major portion of the piles of bird droppings covering a major portion of the deck on and near the walkway which is traversed by security stairs. deck.

headed to and from a security position near by. This is not only a housekeeping issue but could create health concerns. Answer:Safety conductedawalkdown ofthearea.Safety concur with the bird droppings and carcass on the Unit 2 Turbine Deck. Safety contacted the Perry Environmental which will use the vendor (Clean Harbors) which will provide the cleaning and removal or carcass on the Unit2 Turbine Deck. Generated notification 601039624.

9 8191016 CR201610009 08/19/2016 Zak,TimothyJ 09/16/2016 Dead bird found nearUnit2Heater BayBldg. (east) 08/19/2016 08/19/2016 Problem:TheCorporateSME wasnotified perPAP 0808and pictureswere sent.TheSME will providePY OPCHEM;PYChemistry Tim Zak Adeadbird wasfound neartheUnit2Heater BayBldg. (east) direction as to how the bird is handled.

10 N/A CR201703416 03/25/2017 Zak, Timothy J 04/24/2017 Dead BirdEntangled in RazorWire 03/25/2017 03/25/2017 Problem:CorporateEnvironmental AvianSME wasnotified perPAP 0808.Pictureswere sentofthebird PYOPCHEM;PYChemistry E.Rasmussen Deadbird found on Plantsite. for identification and handling instructions.

11 N/A CR201705853 05/22/2017 Zak, TimothyJ 06/21/2017 DeadbirdfoundindrivewayeastofthePAF 05/22/2017 05/22/2017 Problem: TheControl Room,l h b fdRegulatoryAffairsand theCorporateavian SMEwascontacted. Update: PYOPCHEM;PYChemistry Rasmussen Deadbird foundontheplant siteeastofthePAFnearthedriveway. ODNRstatedthatthereare noreporting requirementsand thebirdcanbediscarded.

12 N/A CR201710457 10/16/2017 Brockway,AdamJ 11/15/2017 Dead birddiscoveredOFFGAS 635'behindductwork 10/16/2017 10/16/2017 WhileperforminghousekeepingOffgas635' adeadbird wasidentified. Thebirdwastransportedtochemistry.ChemistrycontactedtheDutyTeamManager,and the PYOPCHEM;PYChemistry N.Bishop birdwillfrozenatthistime.

13 N/A CR201710740 10/25/2017 Olmstead, MichaelJ 11/22/2017 Unit2Turbine BuildingandTurbineTrackBayOctober 10/25/2017 10/25/2017 Performedhousekeepingwalkdown oftheUnit2Turbine BuildingandUnit2Turbine PowerComplex.Unit2 MaintenanceServicesnotifiedoftheissues withregardstocleanliness inthebuilding and PYMNSERV; PYMaintenance Services JeanAPasko HousekeepingInspection TurbinePowerComplexissatisfactory.TheUnit2Turbine Buildingcontinuestonot meethousekeepingstandards. Notification601079115updatedwithspecificitemsofconcern.

Basicitemssuchastrashbeingthrownontheground,deadbirds,birdfeces,andimproperstorageofmaterials throughoutthebuildingcontinuetobeanissue.

14 10272017 N/A 10/27/2017 Meeks,LeonardC Decasedbird foundoutsideTrainingandEducationCenter. 10/27/2017 10/27/2017Adeceasedbirdwasfound earlyinthemorning ontheeastsideoftheTraining andEducationCenternearthe mainentrance.Poissbly collidedwithwindow.

15 1282018 CR201800814 01/30/2018 Meeks, LeonardC 03/01/2018 Birdfounddeadonsite 01/30/2018 01/30/2018Abirdwasdiscovereddeadon thenorth sideoftheIFSI pad. Chemistrywascontactedand thebird waspackagedand retainedin thefreezer until Nofurtheractions. PYOPCHEM;PYChemistry LeonardMeeks identificationandeventuallythrownaway. Anavianincidentreportwascreatedandsentto CorporateEnvironmental.

16 N/A CR201802229 03/10/2018 Brockway, AdamJ 04/09/2018 Deceased birdidentifiedoutsideISFSIyardNW corner 03/10/2018 03/10/2018 Notification601154625 PAP0808referenced PYOPCHEM;PYChemistry N.Bishop FieldSupervisorNotified Adeceasedbirdwasidentified outsideoftheISFSI yard,alongthenorth fenceline,4posts fromthecorner, ChemistryNotified approximately6feetfromthefence. Notification601154625 17 5172018N/A 5/18/2018 Meeks,LeonardC Deceasedturkeyvulture. 5/17/2018 5/18/2018Turkeyvulturepossibly collidedintobuilding.

18 N/A CR202107112 09/22/2021 Zak, TimothyJ 10/22/2021 SkeletonizedBirdsfoundonCirc.WaterBasinscreens 09/17/2021 09/17/2021 ProblemStatement: ContactedtheControl Roomand RegulatoryAffairs. None PYOPCHEM;PYChemistry TimZak Itwasreportedthatwhile cleaningtheCirc. WaterBasinscreensdeadalgae,along withapproximately60 skeletonizedbirdswerediscoveredupagainstthescreens.Theorigin,timingorspeciesofbirds(exceptiononeERM andtheEHFleetEnvironmental Managerwerecontactedbird asapeercheck.

wasidentifiedbybandonleg)thatwereimpactedwasunknownduetothedecomposition,orlackofcarcassesfor examination.

Details:

AhighdifferentialalarmacrosstheCirculation WaterBasincameupin theControl Roomon Thursday,September 16th. TheControlRoomcontactedConstructionServicestohaveacontracteddivingcompanycomeoutto vacuum/cleanthescreensonFriday,September17th. Thescreenswerelastvacuumed/cleanedonSeptember9th.

Whilevacuuming/cleaningthescreensitwasnotedbythediversthatapproximately60skeletonizedbirdsalong withdeadalgaewasthecontributingfactorincausingthehighdifferentialacrossthescreens.Thebirdswere describedassmallinnatureandonebirdwasidentifiedbythebandonitlegasbeingaracingpigeon.

19 7262021N/A 7/24/2021 Zak,TimothyJ Deceasedyellowwarbler. 7/24/2021 7/24/2021Yellowwarblerdiscovereddeadoutside ofPAF. Notlisted asThreatenedorEndangeredspecies.Will disposeofin tallgrassalongside of ChemicalWasteLagoonsinthePAF.

20 N/A N/A 1/28/2022 Zak,TimothyJ Injuredperegrine falcon. 1/28/2022 1/28/2022 Aninjured peregrinefalconwasdiscoveredon themain roadleading toPNPP site. PNPPstaffsafelyrelocatedtheinjuredbirdtoalocal wildliferehabilitationcenter(Lake MetroparksKirtlandPenitentiaryGlenReservation'snaturerehabcenter).

Perry Nuclear Power Plant Docket No. 50-440 VistraOps Response to NRC RAI No. TER-2 L 083 Attachment 43 Page 1 of 2

Attachment No. 43

Terrestrial Resources (TER)

NRC RAI Number: TER-2

REQUIREMENT: 10 CFR 51.53(c)(iv) requires th at environmental reports contain any new and significant information regarding the environmental impacts of license renewal of which the applicant is aware

ISSUE: TER-2 asked for clarification regarding specific procedures when handling migratory birds and their nests. In reviewing corporate avian handling procedures and incidents Energy Harbor provided during the audit, no procedures defined the exact workflows that occur on-site at the Perry Plant when avian incidents occur, or specific procedures involved in determining an avian incident is a Significant or Unusual Environmental Event.

REQUEST: Please clarify whether any staff on-site are knowledgeable in handling or identifying birds, how remains are handled and identified on-site and by off -site vendor, whether the identification process includes noting whether or not the species are protected by the Migratory Bird Treaty Act (MBTA), how long identification typically takes, and describe any other avian transport, nest handling, or disposal processes. Please provide the following: (a) thresholds or other definitions of Significant or Unusual Envir onm ental Event when the avian species are not federally listed or sta te-listed as Endangered or Threatened, (b ) whether th e threshold varies if the species is protected by the MBTA but is not listed as Endangered or Threatened by FWS or the state, (c) whether th e threshold varies if the mortality ca u se is a collision versus an impingement, (d) a description of how the two different avian reporting forms are generated (those beginning with CR versus those with dates of incident only), (e) which Energy Harbor staff make the determination that an avian incident is a Significant or Unusual Environmental Event, (f) specific procedures and regulatory authorities contacted when the avian incident is determined to be a Significant or Unusual Environmental Even t.

VistraOps Response:

(a) A ttachm ent 64 (EP.1 Significant Environmental Impact -PY) of the Event Notifications procedure (NOBP-OP-1015) sta te s that bird impaction events exceeding 100 impact events within one day meets the "Excessive bird impaction events" trigger. Th is procedure also considers mortality or unusual occurrence of any species protected by the Endangered Species Act as an unusual or important event.

(b) This variation in threshold between MBTA versus federal or state listed birds has not been defined.

(c) Similarly, differences in mortality thresholds due to impingement versus collisions have not been defined.

Perry Nuclear Power Plant Docket No. 50-440 VistraOps Response to NRC RAI No. TER-2 L-24-083 Attachment 43 Page 2 of 2

(d) CR designation indicates the entry of the issue into the corrective action program database. An Avian Incident Report was generated based on FirstEnergy guidance. That guidance was not incorporated into PNPPs processes.

(e) The VistraOps staff who makes this determination is the Chemistry Specialist/

Environmentalist.

(f) The U.S. Fish and Wildlife Service and the Ohio Department of Natural Resources are the regulatory agencies that are contacted when an avian incident is determined to be a Significant or Unusual Environmental Event. The specific procedures used are NOBP-OP-1015 (Event Notifications) and PAP-0808 (Environmental Programs and Reports).

References:

None

Associated

Enclosures:

None