ML101240734

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2010/04/21 Watts Bar 2 OL - RAI Response
ML101240734
Person / Time
Site: Watts Bar Tennessee Valley Authority icon.png
Issue date: 04/21/2010
From:
Office of Nuclear Reactor Regulation
To:
Division of Operating Reactor Licensing
References
Download: ML101240734 (43)
v • d • e


Text

1 WBN2Public Resource From: Wiebe, Joel Sent: Wednesday, April 21, 2010 7:55 AM To: 'Stegen, Amanda'; 'Keller, Tonya K' Cc: WBN2HearingFile Resource; Beissel, Dennis

Subject:

RE: RAI Response Attachments:

TVA Motion to Dismiss Contention 1.pdfAmanda/Tonya, TVA has filed a motion to dismiss contention 1 based on the April 9, 2010, submittal. The enclosures to the April 9, 2010, submittal appear to be included at the end of the attached document.

Joel From: Stegen, Amanda [1]

Sent: Tuesday, April 20, 2010 12:22 PM To: Wiebe, Joel; Keller, Tonya K; Imboden, Andy Cc: WBN2HearingFile Resource; Beissel, Dennis; Krieg, Rebekah; Bryce, Robert W; Cort, Katherine A

Subject:

RE: RAI Response ThanksJoel, ManyoftheRAIresponsesTVAsubmittedrefertotheattachments,sothesoonerwegetthemthebetter.StaffhavebeenreviewingtheletterthatTVAsentandtherearesomequestions/clarificationsthathavecomeup.Oncewereviewthewholepackage,wewouldliketoscheduleacallwithTVAtodiscusssomeoftheitems.Atthistime,Iknowwewillneedtodiscussafewhydrology,landuse,andaquaticquestions.Onceweseetherestofthesubmittal,theremaybeafewmoreareasthatneedclarification,butwewillletyouknow.Thanks, AmandaFrom: Wiebe, Joel [2]

Sent: Tuesday, April 20, 2010 8:31 AM To: Keller, Tonya K; Imboden, Andy Cc: Stegen, Amanda; WBN2HearingFile Resource

Subject:

RE: RAI Response This is another large hardcopy submittal. It will take some time for the attachments to be processed into ADAMS.

From: Keller, Tonya K [3]

Sent: Monday, April 19, 2010 12:30 PM To: Wiebe, Joel; Imboden, Andy Cc: Stegen, Amanda

Subject:

FW: RAI Response JoelandAndy,IunderstandthatDennisisoutthisweek,caneitherofyoupleasecheckonthisforme.WeneedtheattachmentsthatgowiththeRAIresponse.

2Thanks,__________________________________________________Tonya KellerProgram SpecialistPacific Northwest National LaboratoryFrom: Stegen, Amanda Sent: Friday, April 16, 2010 9:30 AM To: Beissel, Dennis; Keller, Tonya K; Krieg, Rebekah Cc: Bryce, Robert W

Subject:

RE: RAI Response HiDennis, DoyouhavealltheattachmentsthatgowiththisRAIresponse?Thisisonlypartofthesubmittalandmanyoftheresponsesreferencetheattachments.Iwillcheckwiththeteamabouttheavailabilitytheweekofthe24 thandgetbacktoyou.ItlookslikeTVAhasansweredallthequestions,withtheexceptionofH 16,whichtheysaytheywillhavetoNRCbyApril23 rd.Iwillalsosendtheseouttotheteamtohavethemcheckoncompletenessoftheresponses.IwillletyouknowifweneedclarificationonanyoftheRAIresponses.Thanks-Amanda From: Beissel, Dennis [4]

Sent: Friday, April 16, 2010 6:35 AM To: Stegen, Amanda; Keller, Tonya K; Krieg, Rebekah Cc: Bryce, Robert W

Subject:

FW: RAI Response Is this the remainder of what we need? Can we do the writing session the week of May 24th??

From: Milano, Patrick Sent: Friday, April 16, 2010 8:08 AM To: Beissel, Dennis Cc: Wiebe, Joel; WBN2HearingFile Resource

Subject:

RAI Response In case you haven't seen this yet.

Hearing Identifier: Watts_Bar_2_Operating_LA_Public Email Number: 12 Mail Envelope Properties (F371D08C516DE74F81193E6D891DC4AF304C31137F)

Subject:

RE: RAI Response Sent Date: 4/21/2010 7:55:16 AM Received Date: 4/21/2010 7:55:19 AM From: Wiebe, Joel Created By: Joel.Wiebe@nrc.gov Recipients: "WBN2HearingFile Resource" <WBN2HearingFile.Resource@nrc.gov>

Tracking Status: None "Beissel, Dennis" <Dennis.Beissel@nrc.gov>

Tracking Status: None "'Stegen, Amanda'" <Amanda.Stegen@pnl.gov> Tracking Status: None

"'Keller, Tonya K'" <Tonya.Keller@pnl.gov> Tracking Status: None

Post Office: HQCLSTR02.nrc.gov Files Size Date & Time MESSAGE 3232 4/21/2010 7:55:19 AM TVA Motion to Dismiss Contention 1.pdf 377442 Options Priority: Standard Return Notification: No Reply Requested: No Sensitivity: Normal Expiration Date: Recipients Received:

DB1/64684625.1UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD ) In the Matter of )

) Docket No. 50-391-OL TENNESSEE VALLEY AUTHORITY )

) April 19, 2010 (Watts Bar Nuclear Plant Unit 2) )

)TENNESSEE VALLEY AUTHORITYSMOTION TO DISMISS SOUTHERN ALLIANCE FOR CLEAN ENERGYS CONTENTION 1 AS MOOTI.INTRODUCTION In accordance with 10 C.F.R. § 2.323(a), Tennessee Valley Authority (TVA), Applicant in the above-captioned matter, submits this Motion requesting that the Atomic Safety and Licensing Board (Board) dismiss Southern Alliance for Clean Energys (SACEs)

Contention 1 as moot. As admitted by the Board, Contention 1 is a contention of omission alleging that TVAs Final Supplemental Environmental Impact Statement (FSEIS) for the Completion and Operation of Watts Bar Nuclear Plant (WBN) Unit 2 1 failed to list and discuss the status of compliance with applicable permits, approvals, and environmental quality standards.

2 As discussed below, TVA recently submitted this list, including a discussion of compliance with applicable permits, approval, and environmental quality standards, in response 1 Final Supplemental Environmental Impact Statement, Completion and Operation of Watts Bar Nuclear Plant Unit 2, Rhea County, Tenn. (June 2007), available at http://www.tva.gov/environment/reports/wattsbar2/

seis.pdf.

2Tenn. Valley Auth. (Watts Bar Unit 2), LBP-09-26, 70 NRC __, slip op. at 15-21 (Nov. 19, 2009), affd on other grounds, CLI-10-12, 71 NRC __ (Mar. 26, 2010); Petition to Intervene and Request for Hearing at 6-8 (July 13, 2009) (Petition).

2to a U.S. Nuclear Regulatory Commission (NRC) Staff request for additional information (RAI).3 Thus, Contention 1 has been rendered moot and should be dismissed. II.PROCEDURAL BACKGROUND On July 13, 2009, SACE (along with several other petitioners that were not admitted as parties to this proceeding) filed a Petition to Intervene in this 10 C.F.R. Part 50 operating license

(OL) proceeding for WBN Unit 2. The Petition included seven proposed contentions, including Contention 1, which claimed that TVA failed to comply with 10 C.F.R. §§ 51.53(b) and 51.45(d) because the FSEIS did not list or discuss compliance with permits, approvals, and environmental standards.

4 SACE provided two examples of permits or approvals that TVA allegedly should have listed in the FSEIS: (1) an Interagency Agreement between TVA, the U.S.

Army Corps of Engineers, the U.S. Department of Energy, the U.S. Environmental Protection Agency, and the Tennessee Department of Health and Environment; and (2) TVAs National Pollution Discharge Elimination System (NPDES) permit.

5 SACE also claimed that [t]here may be other federal permits, approvals, and environmental quality standards applicable to WBN Unit 2 and TVA should list and discuss all of them as well.

6 3 SeeLetter from M. Bajestani, TVA, to NRC Document Control Desk, Enclosure 1, Response to NRC Request for Additional Information Regarding Environmental Review at E1-6 (Apr. 9, 2010) (RAI Response); Id.,Attachment 2 to Enclosure 1, Table G-5, Federal, State, and Local Authorizations (Table G-5); see also Letter from J. S. Wiebe, NRC, to A. S. Bhatnagar, TVA (Dec. 3, 2009), available at ADAMS Accession No. ML093030148; Id., Enclosure, RAIs Watts Bar 2, at 8, available at ADAMS Accession No. ML093290073 (NRC Staff Watts Bar 2 RAI). Counsel for SACE was provided with a copy of the RAI Response, including Table G-5, via e-mail on April 13, 2010. The RAI Response and Table G-5 are provided as an attachment to this Motion.

4 Petition at 6.

5Id. at 7-8. 6Id. at 8.

3 On November 19, 2009, the Board granted SACEs Petition and admitted Contention 1.

7The Board concluded that SACE raised a genuine issue concerning TVAs compliance with 10 C.F.R. § 51.45(d).

8 As the Board noted, that regulation requires that an applicant for an OL list in the license application all federal permits, licenses, approvals and other entitlements that must be obtained in connection with the issuance of an operating license . . . and adequately discuss the status of compliance with these requirements.

9 In ruling on the admissibility of Contention 1, however, the Board rejected SACEs claims involving the Interagency Agreement and TVAs NPDES permit.

10 Thus, although the Board admitted Contention 1 as a contention of omission, it acknowledged that only the allegation regarding the additional, unspecified and unlisted permits supports the admission of this contention.

11 On December 3, 2009, the NRC Staff issued an RAI asking that TVA [p]rovide a list of all authorizations, consultations, and environmental permits and approvals needed for operation of [WBN] Unit 2 and provide a status for each item.

12 On April 9, 2010, TVA responded to this RAI by providing Table G-5, Federal, State, and Local Authorizations, which lists and describes [a]ll federal, state, and local authorizations, consultations, and environmental permits

needed for operation of Unit 2 and the status of each.

13 7 LBP-09-26, slip op. at 2-3, 18-21.

8Id. at 18. 9Id.10Id. at 19-20.

11Id. at 19, 21.

12 NRC Staff Watts Bar 2 RAI at 8.

13 RAI Response at E1-6; Table G-5.

4III.LEGAL STANDARD The Commission has held that [w]here a contention alleges the omission of particular information or an issue from an application, and the information is later supplied by the applicant or considered by the Staff in a draft EIS, the contention is moot.

14 Similarly, the Commission has stated that where a contention is superseded by the subsequent issuance of licensing-related documentswhether a draft EIS or an applicants response to a request for additional informationthe contention must be disposed of or modified.

15 As explained below, TVAs April 9, 2010 RAI Response provides the information that the Board determined to be omitted from the FSEIS, thus rendering Contention 1 moot. IV.CONTENTION 1 IS MOOT Contention 1 is a contention of omission regarding TVAs compliance with 10 C.F.R.

§ 51.45(d).

16 Specifically, the Board admitted Contention 1 only to the extent SACE claimed that TVA does not identify . . . or discuss the current compliance status of additional, unspecified and unlisted permits.

17 TVAs April 9, 2010 RAI Response fully cures this omission and renders Contention 1 moot. As discussed above, the RAI Response augments TVAs FSEIS by providing a new Table G-5 that lists all Federal, state, and local authorizations, consultations, and environmental permits related to operation of WBN Unit 2. Table G-5 also discusses the current compliance status of each of these permits. In other words, this RAI Response includes precisely the 14Duke Energy Corp. (McGuire Nuclear Station, Units 1 & 2; Catawba Nuclear Station, Units 1 & 2), CLI-02-28, 56 NRC 373, 383 (2002) (citing Private Fuel Storage, L.L.C. (Indep. Spent Fuel Storage Installation), LBP-01-26, 54 NRC 199, 207-09 (2001); LBP-01-23, 54 NRC 163, 171-72 (2001); LBP-02-2, 55 NRC 20, 29-30 (2002)).

15Id. at 382 (emphasis added).

16 LBP-09-26, slip op. at 18, 21.

17Id. at 19, 21.

5information alleged to be required pursuant to 10 C.F.R. § 51.45(d) and thereby cures the omission.

The Commission has clearly held that when a contention alleges the omission of specific information from an application and the information is later supplied by the applicant, the contention is moot.

18 As the Licensing Board recently explained in the South Texas COLproceeding, the Commission has not established any prerequisite, such as assessment of the information submitted, that must be met before a finding of mootness can be made. Rather, submittal of the information is the basis for the finding of mootness . . . .

19 In the instant case, Contention 1 has been mooted by TVAs April 9, 2010 RAI Response and should be dismissed. V.CONCLUSION For the foregoing reasons, Contention 1 as admitted by the Board is moot and the Board should grant TVAs request to dismiss this contention.

18McGuire-Catawba, CLI-02-28, 56 NRC at 383.

19S. Tex. Project Nuclear Operating Co. (S. Tex. Project Units 3 & 4), LBP-09-21, slip op. at 11 n.59 (Aug. 27, 2009).

6CERTIFICATION OF CONSULTATION UNDER 10 C.F.R. § 2.323(b) Counsel for TVA conferred with SACE and the NRC Staff in an attempt to resolve the issues raised in this motion. On April 13 and 16, 2010, counsel for TVA corresponded with counsel for SACE via e-mail regarding this motion. Counsel for TVA also discussed this motion with counsel for SACE on April 19, 2010. TVA and SACE were unable to reach agreement on this motion. The NRC Staff does not oppose the filing of this motion.

Respectfully submitted, Signed (electronically) by Paul M. Bessette Kathryn M. Sutton, Esq.

Paul M. Bessette, Esq.

Morgan, Lewis & Bockius LLP 1111 Pennsylvania Avenue, N.W.

Washington, D.C. 20004

Phone: 202-739-3000

Fax: 202-739-3001 E-mail: ksutton@morganlewis.comE-mail: pbessette@morganlewis.com Edward J. Vigluicci, Esq.

Christopher C. Chandler, Esq.

Office of the General Counsel Tennessee Valley Authority 400 W. Summit Hill Drive, WT 6A-K Knoxville, TN 37902

Phone: 865-632-7317

Fax: 865-632-6147 E-mail: ejvigluicci@tva.govE-mail: ccchandler0@tva.gov Counsel for TVA Dated in Washington, D.C.

this 19th day of April 2010 T02 100409 001 April 9, 2010 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, D.C. 20555-0001 Watts Bar Nuclear Plant, Unit 2 NRC Docket No. 50-391

Subject:

Watts Bar Nuclear Plant (WBN) Unit 2 - Response to U.S. Nuclear Regulatory Commission (NRC) Request for Additional Information Regarding Environmental Review (TAC No. MD8203)

References:

1. NRC letter to TVA dated December 3, 2009, Watts Bar Nuclear Plant, Unit 2 - Request for Additional Information Regarding Environmental Review (TAC No. MD8203) [ML093030148 / ML093290073] 2. TVA letter to NRC dated February 15, 2008, Watts Bar Nuclear Plant (WBN) - Unit 2 - Final Supplemental Environmental Impact Statement for the Completion and Operation of Unit 2 [ML080510469] 3. TVA letter to NRC dated July 2, 2008, Watts Bar Nuclear Plant (WBN) - Unit 2 - Final Supplemental Environmental Impact Statement

- Request for Additional Information (TAC MD8203) [ML081850460] 4. TVA letter to NRC dated January 27, 2009, Watts Bar Nuclear Plant (WBN) Unit 2 - Final Supplemental Environmental Impact Statement -

Severe Accident Management Alternatives (TAC MD8203)

[ML090360588] 5. TVA letter to NRC dated December 23, 2009, Watts Bar Nuclear Plant (WBN) Unit 2 - Additional Information Regarding Environmental Review (TAC No. MD8203) [ML100210350] 6. TVA Letter to NRC dated February 25, 2010, Watts Bar Nuclear Plant (WBN) Unit 2 - Additional Information Regarding Environmental Review (TAC No. MD8203) [ML100630115]

The purpose of this letter is to provide additional information in support of NRCs environmental review of WBN Unit 2 as requested by the NRC in Reference 1 subsequent to a site audit in October 2009.

U.S. Nuclear Regulatory Commission Page 2 April 9, 2010 The WBN Unit 2 Final Supplemental Environmental Impact Statement (June 2007) was submitted to the NRC on February 15, 2008 (Reference 2). By letter dated July 2, 2008 (Reference 3), TVA responded to an NRC request for additional information. By letter dated January 27, 2009 (Reference 4), TVA provided the Severe Accident Management Alternatives analysis report for WBN Unit 2. By letter dated December 23, 2009 (Reference 5), and February 25, 2010 (Reference 6), TVA provided additional information in support of NRCs environmental review of WBN Unit 2. Enclosure 1 provides the NRC environmental review requests for additional information and TVAs responses as of April 7, 2010. Attached to Enclosure 1 is an Optical Storage Media (OSM) containing supporting files and documents as listed below. Paper copies of the documents, as applicable, are also attached. TVA expects to provide the remaining RAI response by April 23, 2010. Enclosure 2 identifies those actions committed to by TVA in this letter. If you have any questions, please contact me at (423) 365-2351.

Sincerely,Original signed by Masoud Bajestani Watts Bar Unit 2 Vice President

Enclosures:

1. Response to NRC Request for Additional Information Regarding Environmental Review 2. List of Regulatory Commitments Attachments to Enclosure 1
1. Groundwater Investigation Report, Watts Bar Nuclear Plant, Spring City, Tennessee, Prepared by ARCADIS G&M Inc. for TVA, August 2004 2. Table G-5, Federal, State, and Local Authorizations 3. TVA Nuclear Power Group (NPG) Calculation WBNTSR-008 R11, Control Room Operator and Offsite Doses Due to a Steam Generator Tube Rupture 4. FENCDOSE Run, Time Dependent Releases, 21 uCi/g I-131 equivalent preaccident Iodine spiking case (TSR8F11Aout.txt)

U.S. Nuclear Regulatory Commission Page 3 April 9, 2010 5. FENCDOSE Run, Time Dependent Releases, 0.265 uCi/g I-131 equivalent accident initiate Iodine spike case (TSR8FBout.txt) 6. TVA NPG Calculation WBNTSR-009 R11, Control Room Operator and Offsite Doses from a Fuel Handling Accident 7. TVA NPG Calculation WBNTSR-080 R6, Control Room Operator and Offsite Doses Due to a Loss of AC Power 8. FENCDOSE File, Time Dependent Releases, realistic case (TSR80FA6.txt) 9. FENCDOSE File, Time Dependent Releases, 1% failed fuel case (TSR80FB6.txt) 10. TVA NPG Calculation WBNAPS3-077 R11, Offsite and Control Room Operator Doses Due to a Main Steam Line Break 11. FENCDOSE Run, Time Dependent Releases, preaccident 21 uCi/gm I-131 equivalent case (APS77F10A.txt) 12. FENCDOSE Run, Time Dependent Releases, 0.265 uCi/gm I-131 accident initiated Iodine spike (APS77F10B.txt) 13. TVA NPG Calculation WBNTSR-064 R8, Offsite and Control Room Operator Doses Due to a Waste Gas Decay Tank Rupture 14. TVA NPG Calculation TI-RPS-197 R21, Offsite Doses Due to a Regulatory Guide 1.4 Loss of Coolant Accident 15. Met files used in the ARCON96 X/Q calculations 16. 1976 TVA Report, Impingement at Watts Bar Steam Plant 17. Table 3-7, Total Numbers of Each Native Mussel Species Collected During Preoperational (1983-1994) and Operational (1996-1997) Surveys Near Watts Bar

Nuclear Plant 18. Appendix A-2, Results of 14 Native Mussel Surveys at 12 Sites in the Vicinity of Watts Bar Nuclear Plant, 1983-1997 U.S. Nuclear Regulatory Commission Page 4 April 9, 2010 cc (Enclosures): U. S. Nuclear Regulatory Commission Region II Sam Nunn Atlanta Federal Center 61 Forsyth Street, SW, Suite 23T85 Atlanta, Georgia 30303-8931 NRC Resident Inspector Unit 2 Watts Bar Nuclear Plant 1260 Nuclear Plant Road Spring City, Tennessee 37381 U.S. Nuclear Regulatory Commission Page 5 April 9, 2010 GPA:ETM:SKL:CLH bcc (Enclosures): Lakshminarasimh Raghavan U.S. Nuclear Regulatory Commission MS 08H4A One White Flint North 11555 Rockville Pike

Rockville, Maryland 20852-2738 Patrick D. Milano, Senior Project Manager U.S. Nuclear Regulatory Commission MS 08H4 One White Flint North 11555 Rockville Pike

Rockville, Maryland 20852-2738 Loren R. Plisco, Deputy Regional Administrator for Construction U. S. Nuclear Regulatory Commission

Region II Sam Nunn Atlanta Federal Center 61 Forsyth Street, SW, Suite 23T85 Atlanta, Georgia 30303-8931 G. P. Arent, EQB 1B-WBN* M. Bajestani, EQB 1B-WBN*

R. R. Baron, EQB 1B-WBN*

A. S. Bhatnagar, LP 6A-C* M. K. Brandon, ADM 1L-WBN*

D. E. Grissette, ADM 1V-WBN*

R. M. Krich, LP 3R-C*

A. L. Sterdis, LP 5A-C*

E. J. Vigluicci, WT 6A-K K. W. Whittenburg, SP 2B-C*

EDMS, WT 3B-K (Re: A02 091208 001; T02 080215 001; T02 080702 003; T02 090127 001; T02 091223 001; T02 100225 001) *These ccs received only Enclosures 1 and 2, not the attachments to Enclosure 1. The attachments to Enclosure 1 are available by contacting the WBN Unit 2 Licensing office. Response to NRC Request for Additional Information Regarding Environmental Review E1-1Tennessee Valley Authority Watts Bar Nuclear Plant - Unit 2, Docket No. 50-391 Socioeconomics S-3 NRC RequestProvide recent information on the total number of Watts Bar Unit 1 and 2 permanent operations-related employees and describe where these employees live (county-level residence is sufficient). TVA ResponseTVA reviewed the records of approximately 700 permanent employees to obtain the following county-level residence information: County of Residence Percentage Rhea 22.1 Hamilton 15.2 Knoxville 12.6 McMinn 12.5 Roane 7.5 Meigs 5.7 Loudon 5.4 Monroe 4.1 Bradley 3.2 Blount 2.0 Cumberland 2.0 Hydrology H-1 NRC RequestDuring the site audit, staff reviewed a document titled Groundwater Investigation Report prepared by ARCADIS G&M Inc. for TVA August 12, 2004. Provide this document in a referenceable format. TVA Response An electronic and paper copy of the ARCADIS report is attached (Attachment 1).

H-2 NRC RequestIf the ARCADIS report cannot be provided, provide a current water-table map of the Watts Bar site including locations of monitoring wells. Response to NRC Request for Additional Information Regarding Environmental Review E1-2 TVA Response An electronic and paper copy of the ARCADIS report is attached.

H-3 NRC RequestIf the ARCADIS report cannot be provided, provide an analysis of groundwater travel time from WBN Unit 2 facilities to nearby surface water bodies (accessible environment) taking into account the properties of the site following construction

of Unit 2. TVA Response An electronic and paper copy of the ARCADIS report is attached.

H-4 NRC RequestProvide a current summary of tritium distribution in groundwater at the WBN site. TVA ResponseTVA provides results and a summary of tritium distribution in groundwater at the WBN site in the Annual Radiological Environmental Operating Report (AREOR) and the Annual Radioactive Effluent Release Report (ARERR). The 2008 AREOR (ML091390288) and the 2008 ARERR (ML091260369) were submitted to the NRC April 30, 2009. Since the 2004 ARCADIS report was issued, TVA has provided the following AREORs and ARERRs to the NRC: Year AREOR ARERR 2004 ML051380366 ML051250623 2005 ML061290369 ML061220258 2006 ML071280378 ML071230082 2007 ML081430029 ML081300025 H-16 NRC RequestThe figure included in Appendix B of the 2007 TVA EIS shows water flow rates for plant systems with one unit in operation. Provide an update of this figure showing the flow rates for the system with WNB Unit 1 and 2 in operation. Provide an update to the table on page 3-3 of 1978 EIS to include values that include the flow rates needed for both units in operation. Response to NRC Request for Additional Information Regarding Environmental Review E1-3 TVA ResponseTVA will provide this information on or before April 23, 2010.

H-19 NRC RequestESRP 5.2.1 directs staff to consider hydrologic alterations such as maintenance dredging. Is periodic maintenance dredging of the intake canal required/planned? If so, how are intake operations conducted to supply the plant's raw water demand while dredging of the intake channel. Would maintenance dredging of the barge unloading facility be required prior to future use? Are any other dredging actions associated with operation of WBN Unit 2 being considered? How would dredged material be disposed of? TVA ResponseTVA routinely (every two years) inspects the river channel for silt formation in the forebay of the Intake Pumping Station (IPS) channel. The results of this inspection determine if dredging is required and if there should be an increase in monitoring. A calculation specifies that flow will be maintained if the average depth at Elevation 663.0 feet is available. The review was last performed in October 2008. The data satisfied the requirement, and no dredging is required or planned. H-22 NRC RequestThe ER states that potable water will be obtained from the Watts Bar Utility District. What is the volume of water provided by WBUD to support the operation of Unit 1 and what is the anticipated additional increment of water needed from the utility district to support the operation of Unit 2? What is the total anticipated water need from the district in the future? What are the environmental impacts associated with the WBUD obtaining and providing the additional water. TVA ResponseThe steady state staffing level for WBN Units 1 and 2 after Unit 2 construction is completed and is currently targeted at 1,200 excluding major project and outage staffing. Therefore, assuming a normal daily volume at approximately 20 gallons per person would equal 24,000 gallons per day to support the steady state staffing target. The peak staffing for Unit 2 completion and a Unit 1 Refueling Outage at the same time is estimated to be approximately 4,000, which would result in a volume of 80,000 gallons per day using the 20 gallons per person daily factor. Watts Bar Utility District has a capacity of 1.8 million gallons per day. WBN is a small fraction of this capacity, and thus no environmental impact is expected. Response to NRC Request for Additional Information Regarding Environmental Review E1-4 H-29 NRC RequestProvide a recent analysis of groundwater quality on the WBN site. ESRP 2.3.3 calls for staff to review water quality parameters including total dissolved solids, hardness, odor, conductivity, phosphorus forms (total and orthophosphate),

nitrogen forms (ammonia, nitrate, nitrite, organic), alkalinity, chlorides, sulfate, sodium, potassium, calcium, magnesium, heavy metals (e.g., Hg, Pb), pH, silica, iron, carbon dioxide, and bicarbonate. How will the operation of Unit 2 impact groundwater quality on the WBN site?

TVA ResponseThe results of groundwater samples taken February 2010 are shown in the table on the following page. TVA Nuclear Power Group (NPG) Ground Water Protection Program (GWPP), defined in SPP-5.15, Fleet Ground Water Protection Program, implements the requirements specified in Nuclear Energy Institute (NEI) 07-07. The fleet GWPP provides guidance and instructions for implementing requirements of NEIs Industry Ground Water Protection Initiative - Final Guidance Document (August 2007). SPP-5.15 minimizes the potential for inadvertent releases to the environment from plant activities. Implementation of this initiative further demonstrates TVAs commitment to the control of licensed material through prevention, early detection, and mitigation and remediation of impacts associated with potential ground water and subsurface contamination. SPP-5.15 also incorporates as applicable the guidance set forth in the EPRI Report 1015118, Ground Water Protection Guidelines for Nuclear Power Plants, for implementing a GWPP. Response to NRC Request for Additional Information Regarding Environmental Review E1-5Results of Groundwater Samples Taken February 2010 Parameter Result Det.Limit Units Method Prep PID Analyzed Chloride 9.6 1.0 mg/l 9056 02/04/10 1007 245 02/04/10 1855 Nitrate BDL 0.10 mg/l 9056 02/04/10 1007 245 02/04/10 1855 Nitrite BDL 0.10 mg/l 9056 02/04/10 1007 245 02/04/10 1855 Sulfate 78. 5.0 mg/l 9056 02/04/10 1007 245 02/04/10 1855 Alkalinity, Bicarbonate 120 20. mg/l 2320B 02/09/10 1306 397 02/09/10 1317 Alkalinity, Carbonate BDL 20. mg/l 2320B 02/09/10 1306 397 02/09/10 1315 Alkalinity 120 20. mg/l 2320B 02/09/10 1155 397 02/09/10 1230 Free Carbon Dioxide 390 0.020 mg/l 406B 02/09/10 1305 397 02/09/10 1326 Hardness, Total (mg/L as CaCO3) 210 30. mg/l 130.1 02/10/10 1009 234 02/10/10 1438 Ammonia Nitrogen 0.13 0.10 mg/l 350.1 02/08/10 1009 397 02/09/10 1334 Odor BDL 1.0 T.O.N. 140.1 02/04/10 1754 477 02/05/10 0730 pH 5.8 su 9040C 02/05/10 1645 477 02/06/10 1004 Organic Nitrogen 0.52 0.10 mg/l CALC. 02/05/10 1741 494 02/09/10 0000 Phosphate, Ortho 0.032 0.025 mg/l 4500P-E 02/05/10 1655 477 02/06/10 1154 Phosphorus, Total BDL 0.10 mg/l 365.1 02/05/10 1742 494 02/09/10 0537 Specific Conductance 440 umhos/cm 9050A 02/05/10 1808 494 02/09/10 1140 Kjeldahl Nitrogen, TKN 0.65 0.10 mg/l 351.2 02/08/10 1356 494 02/10/10 1107 Dissolved Solids 280 10. mg/l 2540C 02/08/10 1001 36 02/09/10 1238 Lead BDL 0.0010 mg/l 6020 02/05/10 1545 388 02/06/10 1625 Mercury BDL 0.00020 mg/l 7470A 02/05/10 0856 429 02/06/10 1642 Calcium 51. 0.50 mg/l 6010B 02/04/10 2132 117 02/07/10 1355 Iron 1.4 0.10 mg/l 6010B 02/04/10 2132 117 02/07/10 1355 Magnesium 14. 0.10 mg/l 6010B 02/04/10 2132 117 02/07/10 1355 Potassium 2.7 0.50 mg/l 6010B 02/04/10 2132 117 02/07/10 1355 Silicon 7.1 0.20 mg/l 6010B 02/04/10 2132 117 02/07/10 1355 BDL - Below Detection Limit Det. Limit - Practical Quantitation Limit (PQL) Response to NRC Request for Additional Information Regarding Environmental Review E1-6 H-30 NRC RequestIdentify the survey datum used to establish elevations reported for the WBN site and facilities (for example NAVD88 or NGVD29). TVA ResponseIn general, WBN site elevations were established on National Geodetic Vertical Datum (NGVD) 1929 prior to site construction.

GeneralG-5 NRC RequestProvide a list of all authorizations, consultations, and environmental permits and approvals needed for operation of Unit 2 and provide a status for each item. TVA Response All federal, state, and local authorizations, consultations, and environmental permits needed for operation of Unit 2 and the status of each is provided in

.

Design Basis Accidents (DBAs)DBA-1 NRC RequestAs discussed at the site audit, provide analyses of the DBAs considered in the FSAR that use realistic (50 percent) X/Qs with sufficient information to permit staff to independently evaluate the doses. TVA Response The following documents and files (Attachments 3 through 15) provide analyses of the DBAs considered in the Final Safety Analysis Report (FSAR) that use conservative FSAR X/Qs. The calculations may be used as input to the PNNL analyses of realistic offsite doses for environmental assessment using more realistic (50 percent) X/Qs: TVA NPG Calculation WBNTSR-008 R11, Control Room Operator and Offsite Doses Due to a Steam Generator Tube Rupture FENCDOSE Run, Time Dependent Releases, 21 uCi/g I-131 equivalent preaccident Iodine spiking case (TSR8F11Aout.txt) Response to NRC Request for Additional Information Regarding Environmental Review E1-7 FENCDOSE Run, Time Dependent Releases, 0.265 uCi/g I-131 equivalent accident initiate Iodine spike case (TSR8FBout.txt) TVA NPG Calculation WBNTSR-009 R11, Control Room Operator and Offsite Doses from a Fuel Handling Accident TVA NPG Calculation WBNTSR-080 R6, Control Room Operator and Offsite Doses Due to a Loss of AC Power FENCDOSE File, Time Dependent Releases, realistic case (TSR80FA6.txt) FENCDOSE File, Time Dependent Releases, 1% failed fuel case (TSR80FB6.txt) TVA NPG Calculation WBNAPS3-077 R11, Offsite and Control Room Operator Doses Due to a Main Steam Line Break FENCDOSE Run, Time Dependent Releases, preaccident 21 uCi/gm I-131 equivalent case (APS77F10A.txt) FENCDOSE Run, Time Dependent Releases, 0.265 uCi/gm I-131 accident initiated Iodine spike (APS77F10B.txt) TVA NPG Calculation WBNTSR-064 R8, Offsite and Control Room Operator Doses Due to a Waste Gas Decay Tank Rupture TVA NPG Calculation TI-RPS-197 R21, Offsite Doses Due to a Regulatory Guide 1.4 Loss of Coolant Accident Met files used in the ARCON96 X/Q calculations Aquatic EcologyAE-1 NRC RequestAdditional data has been collected since the publication of the FES-CP. The vast majority of the impingement in 2005 to 2006 was due to threadfin shad. The ESRPs state that cropping rates in relation to standing stock estimates for species populations should be considered. As discussed at the site audit, provide a population estimate of threadfin shad in the Watts Bar Reservoir to use as a metric for standing stock estimates. TVA ResponseThreadfin shad constitute a high percentage of total fish impinged at most power plants in the Southeastern United States. Extreme population fluctuations which result from their low tolerance of cold water and high reproductive potential often

mask the effect of impingement, which is normally a relatively small proportion of Response to NRC Request for Additional Information Regarding Environmental Review E1-8 the population. It is highly unlikely that impingement significantly affects the Watts Bar Reservoir population of threadfin shad.

Schneider and Tuberville (1980) reported mean annual standing stock estimates (No/ha) of young and adult threadfin shad collected with rotenone in Watts Bar Reservoir from 1960 to 1980. Based on the eight years of cove rotenone data collected from 1960 to 1980, an average of 4,933.6 threadfin shad per hectare (ha) was derived. Of the total area of Watts Bar Reservoir (15,621 ha), a total of 4,100 ha consists of cove and embayment habitat similar to the study areas. Given this information, it was estimated that a total of 20,227,274.9 threadfin shad inhabit the cove and embayment area of the reservoir, which is 26 percent of the total area of the reservoir. The remaining 74 percent of the reservoir consists of pelagic areas that were not sampled for standing stock information due to the lack of proper estimation collection techniques for large bodies of water. The threadfin shad population of Watts Bar Reservoir is estimated to be much greater than the 20 million found in cove and embayment habitats. The presence of a quality largemouth bass population in Watts Bar Reservoir indicates that forage species, such as threadfin shad, are abundant.

The Sport Fishing Index (SFI) was developed by TVA and state fishery resource agencies in the Tennessee River Valley. The SFI uses data from each of these agencies to measure sport fishing quality for individual sport fish species (Hickman 2000). In 2008, the SFI score for largemouth bass in Watts Bar Reservoir (40) was higher than the Valley-wide average of SFI scores for largemouth bass (35) (TVA 2010). This information suggests an abundant forage base to support a quality largemouth bass fishery in Watts Bar Reservoir.

TVA Unpublished SFI Data from 1997 through 2008 ObservedValley-wide Average 1997 44 35 1998 26 33 1999 36 32 2000 43 33 2001 39 36 2002 36 34 2003 34 33 2004 40 31 2005 42 34 2006 42 33 2007 48 33 2008 40 35 Response to NRC Request for Additional Information Regarding Environmental Review E1-9TVA Unpublished SFI Scores for Largemouth Bass Watts Bar Reservoir (1997-2008) AE-2 NRC RequestExplain the apparent difference between the number of fish impinged during the August 1974 to July 1975 impingement sampling from the intake for the WBF as reported on pages 34 and 35 of the SCCW EA, and the discussion of impingement during the same timeframe on pages 3 and 4 and Table 4 for the 316(b) analysis, dated 2007 ("Fish Impingement at Watts Bar Nuclear Plant Supplemental Cooling Water Intake Structure during 2005-2007).

TVA ResponseThe differences in the impingement estimates provided in the Supplemental Condenser Cooling Water (SCCW) Environmental Assessment (EA) and the 2007 impingement report Fish Impingement at Watts Bar Nuclear Plant Supplemental Cooling Water Intake Structure during 2005-2007 are due to differences in the number of samples relied on in extrapolating the estimates and the manner in which the estimates were derived.

0 10 20 30 40 50 60199719981999200020012002200320042005200620072008 S F I S c o r e Year SportFishingIndexScoresforLargemouthBassWattsBarReservoir(1997 2008)Observed ValleywideAverage Range20 60 Response to NRC Request for Additional Information Regarding Environmental Review E1-10The SCCW EA used sample data from 42 samples taken between August 1974 and July 1975 and estimated impingement by month to reach a total annual impingement estimate of 21,787. The estimates are broken down by month in Table 3.3.6 of the EA. The 2007 impingement report references two distinct but related data sets. Pages 3 and 4 of the 2007 report recites data included in a 1976 TVA report, Impingement at Watts Bar Steam Plant. The 1976 report used 33 samples collected from August 1974 to May 1975, resulting in 2,130 fish collected; and then estimated an annual impingement at 16,421 based on the assumption that

Watts Bar Steam Plant was operating 69.7 percent of the time. Table 4 of the 2007 report provides a slightly higher annual impingement estimate, which was calculated using the original sample records from 43 samples taken between August 1974 and July 1975, including the 33 samples cited in the 1976 report. A total of 2,525 fish were counted in the 43 samples, and this total was extrapolated on a weekly basis to determine the estimated annual impingement of 17,675 cited in Table 4. The 1976 report is included in this report as Attachment 16. AE-3 NRC RequestAs discussed at the site audit, provide an updated Table C-7 from the 2007 TVA EIS that corrects the discrepancy in the heading of the sixth column, and appropriately describes the use of the word "Total" in the last column heading.

TVA ResponseTable C-7 of the Final Supplemental Environmental Impact Statement (FSEIS) is a condensed form of data contained and tabulated in Appendix A-2 and Table 3-7 of Aquatic Environmental Conditions in the Vicinity of Watts Bar

Nuclear Plant During Two Years of Operation, 1996-1997. Appendix A-2 provides the results of 14 native mussel surveys at 12 sites in the vicinity of WBN, 1983-1997. The species lists are arranged in order of abundance within each table of Appendix A-2. The data are then summarized in Table 3-7 of the report. This table, and the supporting data from Appendix A-2, may be used in lieu of FSEIS Table C-7. Table 3-7 and Appendix A-2 are included in this submittal as Attachments 17 and 18. As explained in TVAs response to AE-4, the final data column in FSEIS C-7, 529.2R (1997), was not contained in the report cited here, but came from Table 3.3.4 of the 1998 SCCW EA. Response to NRC Request for Additional Information Regarding Environmental Review E1-11AE-4 NRC RequestTVA 1998 Figure 3-2 shows the location of the sampling stations at three native mussel beds surveyed during the preoperational and operational monitoring programs (Tennessee River Mile [TRM] 520-521L; TRM 526-527R and TRM 528-529L). Table C-7 of the FSEIS (pages 155 and 156) indicates that sampling was conducted in 1997 at TRM 529.2R. Indicate whether this is an additional existing mussel bed and provide the extent of this mussel bed and/or the reference that discusses the sampling and its location. If additional mussel beds are known to occur in this reach beyond those specified above, provide the locations of the beds. In addition, Table C-7 of the FSEIS shows that monitoring of mussels only occurred at 529.2R during the 1997 sampling period. However, Table 3-6 of TVA 1998 provides results of mussel surveys at TRM 528.2 to 528.9. Provide an updated Table C-7 that provides the data for all of the surveys that were conducted in the mussel beds closest to the Watts Bar site from surveys in 1990, 1992, 1994, 1996 and 1997.

TVA ResponseThe final data column in Table C-7 in the FSEIS, titled 529.2R (1997), relies on data contained in the August 1998 EA for the WBN SCCW. Table 3.3.4 of the SCCW EA provides data on freshwater mussels encountered during diver-conducted searches of transects located just off shore from the Watts Bar Fossil Plant discharge at TRM 529.2. This survey was a special study done as part of the SCCW analysis and does not represent an additional mussel bed. As discussed in TVAs response to AE-3, the rest of FSEIS Table C-7 comes from Table 3-7 and Appendix A-2 of Aquatic Environmental Conditions in the Vicinity of Watts Bar Nuclear Plant During Two Years of Operation, 1996-1997. This report includes data from all surveys conducted in 1990, 1992, 1994, 1996 and 1997, with the exception of the diver-conducted transect searches at TRM 529.2 described above. A summary of the data is presented in Table 3-7 of this report. Table 3-7 and Appendix A-2 should be used in lieu of FSEIS Table C-7. Table 3-7 and Appendix A-2 are included in this submittal as Attachments 17 and 18. AE-7 NRC RequestProvide a statement regarding whether any operational monitoring programs of aquatic organisms including fish and mussels will be conducted after WBN 2 begins operation. If so, provide details related to the type of monitoring, location, and frequency of monitoring. Response to NRC Request for Additional Information Regarding Environmental Review E1-12 TVA ResponseTVA will conduct preoperational and operational monitoring to characterize the aquatic communities in the vicinity of the plant in Watts Bar and Chickamauga Reservoirs due to the proposed operation of an additional nuclear reactor at the WBN site. This monitoring will serve to update and verify historical monitoring data on entrainment and impingement of fish and freshwater mussel community assemblages. The data collected prior to operation of Unit 2 (2010-2011) and after Unit 2 is in operation will provide additional information to assess the potential for any direct, indirect and cumulative effects to the fish and shellfish communities of

Chickamauga Reservoir from operating two units at WBN. Entrainment (fish eggs and larvae) Ichthyoplankton sampling to estimate temporal densities and species composition of fish eggs and larvae began in March 2010 and will continue at least two years after Unit 2 is in operation. Samples will be collected weekly on a diel schedule (day and night) during March through August and monthly September through February at TRM 528.0 to 528.3 and TRM 529.9 to 530.3 for the IPS and SCCW IPS, respectively. This sampling will estimate temporal abundance of fish eggs and larvae at five stations at each site within a transect perpendicular to river flow just upstream of the plant intake channel and SCCW (upstream of Watts Bar Dam). Samples will consist of one ten-minute tow filtering approximately 150 m3 of water at each sampling location. Additional samples will be collected at each of the plant cooling water intake to estimate entrainment of fish eggs and larvae (Baxter et al. 1998). Impingement Mortality Impingement mortality of fish and shellfish at the IPS (TRM 528) traveling screens will be sampled to update the historical database. Weekly counts of fish and shellfish impinged during a 24-hour period on the IPS traveling screens at WBN will be collected beginning March 2010 and continue for at least one year for preoperational and one year for operational monitoring (Baxter et al. 1998).

Freshwater Mussels To characterize the current freshwater mussel fauna in the vicinity of WBN, qualitative and quantitative mussel surveys will be conducted during June 2010 at three known mussel beds in the vicinity of WBN and in the mid-channel approximately 1 mile below Watts Bar Dam to evaluate four experimental plots within the boulder field to characterize species composition and relative abundance of juvenile and adult freshwater mussel fauna. Response to NRC Request for Additional Information Regarding Environmental Review E1-13Study Area Descriptions In 1983, mussel monitoring sites were established in three known concentrations of mussels (mussel beds) downstream from Watts Bar Dam near WBN: TRM 520-521L (left descending bank), TRM 526-527R (right descending bank),

and TRM 528-529L. The most upstream of these beds (TRM 528-529L) is located on the opposite side of the river from WBN and upstream from its diffuser discharge. The middle bed (TRM 526-527R) is on the same side of the river as WBN and is just downstream from the confluence of Yellow Creek and the WBN diffuser discharge. The downstream bed (TRM 520-521L) is 6 river miles downstream from WBN and is located on the opposite side of the river. All three beds exist on submerged gravel and cobble bars in water approximately 9 to 21

feet deep (Baxter et al. 1998). In 2002, four experimental plots within a boulder field were conducted in the Tennessee River approximately 1 mile (~1.6 km) downstream from Watts Bar Dam approximately 164 feet from the right (descending) shore in water approximately 12 to 14 feet deep (TRM 528.3 - 528.8). This location was chosen along the right (descending) margin of the navigation channel, between the loading facility at Watts Bar Fossil Plant and the intake channel for WBN (Fraley et al. 2002). The purpose of these additional mussel surveys is to determine whether the mussel populations have changed and whether operation of WBN has had any obvious effect on the mussel resources in this part of the Tennessee River.

References Baxter, D.S., J.P. Buchanan, G.D. Hickman, J.J. Jenkinson, J.D. Milligan, and C.J. OBara (1998). Aquatic environmental conditions in the vicinity of Watts Bar Nuclear Plant during two years of operation, 1996-1997. Norris, TN: Tennessee Valley Authority. G. D. Hickman. 2000. Sport Fishing Index (SFI): A Method to Quality Sport Fishing Quality. Environmental Science & Policy 3 (2000), S117-S125. S. J. Fraley, Jenkinson, J. J., and Smith, B.T. (2002). Preliminary Evaluation of an Artificial Boulder Field for Enhancing Native Mussel Habitat in the Watts Bar Tailwater, Tennessee River Mile 528.5. Norris, TN: Tennessee Valley

Authority.TVA 2010. http://www.tva.com/environment/water/sportfish.htm#29 Response to NRC Request for Additional Information Regarding Environmental Review E1-14 Radiological ProtectionRP-1 As discussed during the site audit, the analysis on dose to the population was updated in the 2007 FSEIS. However, the data was not sufficient for staff to conduct independent validation of the conclusions. Based on the data needs found in the revised ESRP 5.4, Exposure Pathways, provide the following data (including references for where data were obtained). a NRC RequestConfirm that there are no milk goat or meat animals are present in the 5-mi radius. TVA Response The annual land use survey process includes the search for milk cow and milk goat locations. No milk goat locations were identified within the five mile radius. The identification of meat animals is not required for Radiological Environmental Monitoring Program (REMP) Land Use Survey process covered in NUREG 1301 and is not performed for WBN. b NRC RequestProvide the direction and distance for the nearest residence, nearest garden, and nearest milk cow. TVA Response This information is reported in Appendix G of the WBN AREOR. c NRC RequestConfirm that releases are calculated as ground level releases.

TVA ResponseFSAR Section 11.3.9, Atmospheric Dilution, states Releases from the Shield Building, Turbine Building (TB), and Auxiliary Building (AB) vents are treated as ground level. d NRC RequestProvide nearest site boundary distances for the 16 cardinal compass directions. Response to NRC Request for Additional Information Regarding Environmental Review E1-15 TVA Response Sector Distance (Meters) Unrestricted Area Boundary N 1550 Unrestricted Area Boundary NNE 1980 Unrestricted Area Boundary NE 1580 Unrestricted Area Boundary ENE 1370 Unrestricted Area Boundary E 1280 Unrestricted Area Boundary ESE 1250 Unrestricted Area Boundary SE 1250 Unrestricted Area Boundary SSE 1250 Unrestricted Area Boundary S 1340 Unrestricted Area Boundary SSW 1550 Unrestricted Area Boundary SW 1670 Unrestricted Area Boundary WSW 1430 Unrestricted Area Boundary W 1460 Unrestricted Area Boundary WNW 1400 Unrestricted Area Boundary NW 1400 Unrestricted Area Boundary NNW 1460 e NRC RequestConfirm that FSAR Section 11 (11.3.10.1 "worst case feeding factor identified during the 1994 land use census for any real cow location (i.e., 70% pasture feeding)." Milk feeding factors are listed in FSAR Table 11.3-10 is the appropriate data for determining the grazing seasons and fraction of daily intake of milk cows derived from pasture or fresh forage during the grazing season. TVA ResponseThe FSAR table containing the milk feeding factors is Table 11.3-9 (currently Unit 1 FSAR) versus Table 11.3-10 (currently Unit 2 FSAR). The following table shows the feeding factors for 1993, 1994, and 1995. During this period, the annual feeding factors were determined and supplied to WBN. WBN now determines the annual feeding factors based on the monthly fraction that each milk farmer is using substitutional feed. Response to NRC Request for Additional Information Regarding Environmental Review E1-16Location Sector / Distance (meters)Feeding Factor 1993 1994 1995 ESE / 5791 0.17 0.60 0.38 ESE / 6553 0.21 0.70 0.33 ESE / 7620 0.13 0.50 0.38 SSW / 2073 0.02 0.65 0.06 WNW / 7925 0.17 0.60 0.41 WSW / 7010 (goat) 0.17 0.67 none f NRC RequestProvide data on fraction of the year that leafy vegetables are grown (Note: FSAR Section 11 (11.3.10.1 "TVA assumes that enough fresh vegetables are produced at each residence to supply annual consumption by all members of that household.") Confirm and provide basis for absolute humidity: Factor H Table 6.3 p. 85/195 of ODCM (9 g/m 3).TVA ResponseDuring the Annual Land Use Survey, it was determined that the fraction of the year that the leafy vegetables are grown ranges between 4 to 6 months. The basis for absolute humidity: Factor H Table 6.3 p. 85/195 of the Offsite Dose Calculation Manual (ODCM) (9 grams per cubic meter [g/m 3]) is based on the following calculations, which were performed for Sequoyah and

Browns Ferry Nuclear Plants. WBN assumed the (9 g/m

3) due to plant region and the over-estimation that is inherent in the calculation. TVAs ODCMs include absolute humidity in the denominators of equations for ingestion dose factors. An estimated value of 9 g/m 3 is used based on the calculations performed for Browns Ferry and Sequoyah. The methodology used to determine the absolute humidity is examined as follows: Absolute humidity (H) is the ratio of the mass of water vapor present to the volume occupied by the mixture; that is, the density of the water vapor

component. (Glossary of Meteorology) Absolute humidity is not directly measured, but must be calculated from those variables which are measured by TVA. TVA measures the temperature (T) and dewpoint (Td) at 10m at each nuclear plant. In the 1970s and early 1980s TVA also measured the barometric pressure. These three values can be used to Response to NRC Request for Additional Information Regarding Environmental Review E1-17calculate other measures of moisture which then yield the absolute humidity by the following steps: 1. T and Td must be converted to Kelvin. Since they are measured in Fahrenheit the conversion is (T or Td) in (Kelvin) = 5 * (T-32)

+ 273.16

92. Barometric pressure (p) must be converted to millibars. The conversion is P (mb) = 33.8639
  • p (in Hg) 3. The saturation vapor pressure (e) in millibars must be calculated from an approximation given in the Smithsonian Meteorological Tables, page 350. It is dependent only on the dewpoint. log 10 (e) = -7.90298(373.16/Td-1) + 5.02808
  • log 10 (373.16/Td) -1.3816*10

-7 (1011.344 (1-Td/373.16)-1) +8.1328

  • 10

-3 (10 -3.49149 (373.16/Td-1)

-1) + log 10 (1012.25) (This approximation is sufficiently accurate to apply it to the normal range of temperatures below 273.16K in the TVA region even though

it is specifically derived for temperature above 273.16K.) 4. The saturation mixing ratio (w) can then be calculated from: w = 0.622 (e)

  • 10 3 (g/kg) p - e (from Hess, p59). 5. The density of dry air (d) is calculated from:

d = p* 10 6 (kg/m 3)R

  • T Where R is the gas constant for dry air (2.8704*10 6 m 2 g-2 K-1)(from Hess, p16., equation 2.8) 6. Absolute Humidity can then be calculated from: H = w
  • d (g/m
3) Response to NRC Request for Additional Information Regarding Environmental Review E1-18 This methodology was used in the computer code RELABSHMREV to generate annual and seasonal average values of absolute humidity for Browns Ferry and Sequoyah using meteorological data collected for the period January 1, 1978, through December 31, 1979. These values and the extreme maximum and minimum values are given in the table below. Browns Ferry Sequoyah Absolute Humidity (g/m
3) Absolute Humidity (g/m 3)Average Extreme Max ExtremeMin Average Extreme Max Extreme MinWinter 4.6 16.6 1.3 Winter 4.2 16 0.8 Spring 9.6 20.1 2.1 Spring 8.9 20.2 1.8 Summer 17.7 24.1 7.5 Summer 16.7 23.6 8 Fall 11.0 22.1 2.1 Fall 10.5 20.8 1.9 Average 10.7 24.1 1.3 Average 10.1 23.6 0.8 These data indicate that use of 9 g/m 3 on an annual basis would result in an overestimate of the associated dose factors by a factor of about 1.1 to 1.2 for the average. On average, overestimation in the summer would be by a factor of 1.9 to 2.0. Underestimation in the winter would be by a factor of about 2.0 to 2.1. The largest overestimation would occur in the summer and the largest underestimation in the winter. The extreme differences would be overestimation by a factor as large as 2.7 or an underestimation by a factor as large as 11.3.

ReferencesHess, S. L., 1959: Introduction to Theoretical Meteorology, Holt, Rinehart and Winston, Inc., NY. Huschke, R. E., 1959: Glossary of Meteorology, R. E. Huschke, ed., American Meteorological Society, Boston, MA. List, R. J., 1949: Smithsonian Meteorological Tables, Smithsonian Institution Press, Washington, DC. g NRC RequestFor the locations from which an individual can obtain aquatic food and/or drinking water and the shoreline areas that an individual can use for recreational purposes, provide the transit time of each facility discharge stream containing liquid radwaste discharge from the point at which the Response to NRC Request for Additional Information Regarding Environmental Review E1-19stream enters an unrestricted area to the identified location, and the estimated stream dilution at that location.

TVA ResponseFor conservatism, a transit time of zero was assumed for releases to reach aquatic recreation areas; therefore, we do not assume any stream dilution. h NRC RequestFor each liquid radwaste discharge, the transit time from input to a facility discharge stream to the point at which the stream enters an unrestricted area, and the stream discharge in m 3/sec (Note: Reg Guide 1.109 P 1.109-12 lists 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> as a minimum transit time for potable water.)

TVA ResponseDecay time for water ingestion is equal to the travel time from the plant to the water supply plus one day to account for the time of processing at the water supply per Regulatory Guide 1.109. i NRC RequestProvide the following distributional data for each of the 22.5-degree radial sectors centered on the 16 cardinal compass directions for radial distances of 2, 4, 6, 8, 10, 20, 40, 60, and 80 km (1.2, 2.5, 3.7, 5, 6.2, 12, 25, 27, and 50 mi) from the reactor: (1) projected population for five years from the time of the licensing action under consideration, (2) present annual meat production (kg/yr), (3) present annual milk production (L/yr), (4) present annual vegetable production (kg/yr), and (5) estimate of direct radiation doses from sources within the site.

TVA ResponseFor item RP-1i, NRC Staff will use information previously submitted by TVA to complete this analysis. Response to NRC Request for Additional Information Regarding Environmental Review E1-20j NRC RequestProvide the present commercial fish catch (in kg/yr from waters within 50 mi downstream of the facility radwaste discharge (Note: Fish harvest -3.04 Ib/acre/y (variable HVST P77/195 of ODCM. From reference 12 (1 TVA memorandum on fish harvest. Dated Dec 15, 1987.) Confirm that there is no invertebrate catch to be considered. Provide transit time from the point at which the discharge stream enters an unrestricted area to each major catch location, the estimated dilution at each location, and the basis for calculating transit time and dilution.

TVA ResponseTVAs information relating to commercial fish catch downstream of the facility is contained in the annual WBN REMP report which samples fish representative of the commercial and recreational species in the areas downstream of the WBN radwaste discharge. k NRC RequestProvide the transit time and estimated dilution at each major location for drinking water intake locations within 80 km (50 mi) of the facility radwaste discharge (downstream or radius), the basis for calculating transit time and dilution, and the populations served or the daily water consumption at each location.

TVA ResponseWBN is located on the Tennessee River at TRM 528. FSAR Section 11.2.8 states The Dosimetry calculations for drinking water are based on the assumption that the liquid effluent will be mixed with 10% of the river flow between the point of discharge and Tennessee River Mile 510.0, where 100% dilution is assumed to occur. The transit times are based on the average quarterly river flow of 25,657 cubic feet per second (cfs) recorded from 1985 to 1994. Annual drinking water quantities for the average and maximally exposed individual were referenced from NRC Regulatory

Guide 1.109. Response to NRC Request for Additional Information Regarding Environmental Review E1-21Public Water Supplies Within 50-Mile Radius Downstream of WBN Name TRM Transit Time Days 1990 Population Dayton, TN 504 1.9 13,500 Soddy-Daisy/Falling Water Utility District 487 5.2 10,000 East Side Utility, TN 473 8.3 35,000 Chattanooga, TN 465 9.9 167,500 Note: Tennessee River mile locations are rounded to the nearest mile for dose calculation purposes. l NRC RequestConfirm that irrigation is not used for crops in the vicinity.

TVA Response

The potential use of irrigation from the Tennessee River is reviewed for home garden locations identified by the REMP annual land use survey. No locations using irrigation from the Tennessee River were identified in the most recent land use survey. m NRC RequestConfirm that there are no unusual animals, plants, agricultural practices, game harvests, or food processing operations having the potential to contribute 10 percent or more to either individual or population doses in areas affected by liquid effluents, and food-processing operations involving large quantities of water. TVA Response Not required for REMP land use survey. n NRC RequestProvide the reference(s) for the sources or radioactive liquid and gaseous waste released from Unit 2, as addressed in the TVA FSEIS, Section 3.14, pp. 91-94. Response to NRC Request for Additional Information Regarding Environmental Review E1-22 TVA Response TVAN WBNTSR-093, Liquid Radioactive Waste Release, which is based on NUREG-017 and ANSI/ANS-18.1-1984. TVAN TI-534, Annual Routine Radioactive Airborne Releases from Operation of One Unit, which is also based on NUREG-017. o NRC RequestIdentify (preferably on a diagram) and provide a reference for principal release points for gaseous and liquid radioactive materials to the environment. Identify and provide a reference for direct radiation sources within or onsite out-of-plant as solid waste (e.g., independent fuel storage).

TVA ResponsePrincipal release points to the environment for liquid and gases were provided in Figures 3-7, 3-8, and 3-9 in the TVA FSEIS. Radiation fields are produced in nuclear plant environments as a result of radioactivity contained within the reactor and its associated components.

Doses from sources within the plant are primarily due to nitrogen-16, a radionuclide produced in the reactor core. Since primary coolant of pressurized water reactors is contained in a heavily shielded area of the plant, dose rates in the vicinity of pressurized water reactors are generally undetectable (less than 5 millirem per year) (FEIS for the Production of Tritium in a CLWR March 1999). This can be contrasted with the annual background dose (NCRP 1987) estimated to be 300 millirems. Low-level direct radiation sources located outside at WBN are the Old Steam Generator Storage Facility (OSGSF), Radwaste Pad, and Decon Building. See WBN Unit 1 FSAR, Chapters 11.5.5.2; 12.3. (The first two buildings are in the Unit 1 FSAR; all three will be included in one of the next updates to the Unit 2 FSAR.) These storage locations are estimated to contribute less than 0.01 millirem per year at the site boundary. (FEIS for the Production of Tritium in a CLWR March 1999.) List of Regulatory Commitments E2-1Tennessee Valley Authority Watts Bar Nuclear Plant - Unit 2, Docket No. 50-391 TVA will provide a response to the following Request for Additional Information on or before April 23, 2010: H-16 The figure included in Appendix B of the 2007 TVA EIS shows water flow rates for plant systems with one unit in operation. Provide an update of this figure showing the flow rates for the system with WNB Unit 1 and 2 in operation. Provide an update to the table on page 3-3 of 1978 EIS to include values that include the flow rates needed for both units in operation. The first two buildings are in the Unit 1 FSAR; TVA will include all three buildings (the Old Steam Generator Storage Facility, Radwaste Pad, and Decon Building) in one of the next updates to the Unit 2 FSAR. RP-1o Identify (preferably on a diagram) and provide a reference for principal release points for gaseous and liquid radioactive materials to the environment. Identify and provide a reference for direct radiation sources within or onsite out-of-plant as solid waste (e.g., independent fuel storage)..

TABLE G-5 FEDERAL, STATE, AND LOCAL AUTHORIZATIONS Sheet 1 of 4 Agency Authority Phase/Requirement/Status Activity Covered U.S. Nuclear Regulatory Commission (NRC) 10 CFR Part 50 Preconstruction. Construction Permit CPPR-92 EXP: 31DEC2013 Permit for construction of a utilization facility. NRC 10 CFR Part 50 OL Submittal. Updated license application filed 04MAR2009 Operation of a utilization facility for commercial purposes U.S. Fish and Wildlife Service (FWS) 16 U.S.C. §§ 1531 et seq.FSEIS. Concurrence. 1995 consultation with FWS, cited in FSEIS Appendix D, applied to WBN1 and WBN2. 2007 FSEIS also found no impacts. Consultation concerning potential impacts to Federal threatened & endangered (T&E) species. U.S. Department of the Interior (DOI) 42 U.S.C. § 1996; 25 U.S.C. § 3001 et seq.FSEIS. Consultation. Consultation not required as FSEIS did not identify any items of cultural significance to Native American tribes. Identification, protection, and repatriation of items of cultural significance to Native American tribes. Federal Aviation Administration (FAA)14 CFR Part 77 Preconstruction. Notification not required as no activities affect structures over 200ft. Preconstruction letter of notification to FAA results in a written response certifying that no hazards exist or recommending project modification. U.S Coast Guard 14 U.S.C.

§§81,83, 85, 633; 49 U.S.C. § 1655(b).Preconstruction. Authorization not required as no activities affect navigation. Navigation markers authorization to protect river navigation from hazards connected with temporary construction activities in a river. Tennessee Department of Environment and Conservation (TDEC) Water Quality Control Act, TCA §§ 69-3-101 et seq.Preoperation. Certification. TVA will seek any required certification from TDEC prior to issuance of the OL. Aquatic resource alteration permit (ARAP) for any alteration of the properties of state waters. This permit also serves as a section 401 water quality certification, which is required prior to seeking a Federal permit or license, including an operating license from the NRC.

TABLE G-5 FEDERAL, STATE, AND LOCAL AUTHORIZATIONS Sheet 2 of 4 Agency Authority Phase/Requirement/Status Activity Covered U.S. Army Corps of Engineers (USACE) 33 U.S.C. § 1344; 33 U.S.C. §§ 1341 Preconstruction.

Permit.USACE stated, as listed in FSEIS Appendix D, that Section 404 permit not required as no work requires discharge of dredged or fill material. Section 404 permit required for discharge of dredged and fill material. A section 401 certification that the action does not violate state water quality standards is required prior to obtaining a section 404 permit. TDEC Air Division Tennessee Air Quality Act, TCA §§ 68-201-101 et seq. 42 U.S.C. §§ 7401 et seq.Preconstruction. Construction permit.

Permit 957606P held by TVA.

EXP: 01JAN2007 Renewal pending. Requested update and consolidation with operating permit 448529 on 23JAN2007. Construction permit for prevention of significant deterioration of air quality required to construct an air contaminant source. TDEC Air Division TCA §§ 68-201-101 42 U.S.C. §§ 7401 et seq.Preoperation. Operating permit. Permit 448529 held by TVA. EXP: 01SEP2010. This permit covers emissions from the Watts Bar site for both Unit 1 and Unit 2 equipment. TVA - WBN opted out of major source - Not a Title V Permit.

TDECWater Division 42 U.S.C.

§ 1342; TCA§§ 69-3-101 et seq.Continuing permit requirement. NPDES Permit TN0020168 held by TVA.

EXP: 04NOV2006 Permit administratively continued. Renewal filed 03MAY2006. Facility permit for point source discharges of wastewater to surface waters and in-stream monitoring Unit 1 only - Permit modification request to include Unit 2 will be filed in June 2010.

TABLE G-5 FEDERAL, STATE, AND LOCAL AUTHORIZATIONS Sheet 3 of 4 Agency Authority Phase/Requirement/Status Activity Covered TDECWater Division 33 U.S.C. §1342; TCA §§ 69-3-101 et seq.Continuing permit requirement. Industrial Storm water Multi-Sector General Permit TNR050000 held by TVA.

EXP: 14MAY2014 Permit for discharge of storm water associated with land disturbance and industrial activity.

TDECWater Division 33 U.S.C. §1342; TCA §§ 69-3-101 et seq.Preconstruction. Permit. Not required, as no construction activities planned that would result in storm water discharge. Permit for discharge of storm water associated with construction involving clearing, grading or excavation that result in an area of disturbance of one or more acres, and activities that result in the disturbance of less than one acre if it is part of a larger common plan of development TDEC Division of Solid and Hazardous Waste Management (SHW) Tennessee Solid Waste Disposal Act, TCA §§ 68-211-101et seq.Preoperation. Permit. Permit number DML72-103-0025 held by TVA.EXP: N/A Site Permit for operation of a Class IV disposal facility (onsite construction & demolition landfill)TDEC Division of SHW TCA§§68-212 EPA Facility ID TN2640030035 Construction Demolition Landfill Permit Number DML 721030025 EXP: N/A Transportation of waste Alabama Department of Environmental Management (ADEM) ADEM Admin. Code R. 335-14 Ongoing. Permit. Operation Permit AL2-640-090-005 held by TVA. EXP: 06MAY2011 Storage of hazardous waste at the hazardous waste storage facility in Muscle Shoals, AL.

TABLE G-5 FEDERAL, STATE, AND LOCAL AUTHORIZATIONS Sheet 4 of 4 Agency Authority Phase/Requirement/Status Activity Covered TDEC Division UST or Solid and Hazardous Waste TCA§§68-212 Preconstruction/operation. Permit. Not required as no underground storage tanks as defined by TDEC. Installation/operation of underground storage tanks that store regulated substances. Tennessee Historical Commission (THC) (State Historic PreservationOfficer) 16 U.S.C. §§ 470 et seq. 36 CFR Part 800 Preoperation. Consultation. Consultation with THC completed and documented in FSEIS Appendix D. Review and analysis of cultural and historic resources, including completion of NHPA Section 106 consultation. Tennessee Public Service Commission Operation. Certification not required. Certificate of public convenience and necessity.

TVAExecutive Order 11514 (Protection and Enhancement of Environmental Quality) 40 CFR Parts 1500-1508 FSEIS. Completed. Protect and enhance the quality of the environment; develop procedures to ensure the fullest practicable provision of timely public information and understanding of Federal plans and programs that may have potential environmental impacts that the views of interested parties can be obtained.

TVAExecutive Order 11988 (Floodplain Management) TVA Procedure for Compliance With NEPA, Section 5.7 FSEIS. Completed. Floodplain impacts to be avoided to the extent practicable.

TVAExecutive Order 11990 (Protection of Wetlands) TVA Procedure for Compliance With NEPA, Section 5.7 FSEIS. Completed. Requires federal agencies to avoid any short- and long-term adverse impacts on wetlands wherever there is a practicable alternative.

DB1/64684625.1UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD ) In the Matter of )

) Docket No. 50-391-OL TENNESSEE VALLEY AUTHORITY )

) April 19, 2010 (Watts Bar Nuclear Plant Unit 2) )

)CERTIFICATE OF SERVICE I hereby certify that, on April 19, 2010, copies of Tennessee Valley Authoritys Motion to Dismiss Southern Alliance for Clean Energys Contention 1 as Moot and supporting attachments were served by the Electronic Information Exchange on the following recipients:

U.S. Nuclear Regulatory Commission Atomic Safety and Licensing Board Panel Mail Stop: T-3F23

Washington, DC 20555-0001 Lawrence G. McDade, Chair Administrative Judge E-mail: lgm1@nrc.govPaul B. Abramson Administrative Judge E-mail: pba@nrc.gov Gary S. Arnold Administrative Judge E-mail: gxa1@nrc.gov U.S. Nuclear Regulatory Commission Office of the General Counsel

Mail Stop: O-15D21

Washington, DC 20555-0001 Edward Williamson, Esq. E-mail: elw2@nrc.gov David Roth, Esq. E-mail: david.roth@nrc.gov Andrea Jones, Esq. E-mail: andrea.jones@nrc.gov 2 U.S. Nuclear Regulatory Commission Office of Commission Appellate Adjudication

Mail Stop: O-16C1

Washington, DC 20555-0001 OCAA Mail Center E-mail: ocaamail@nrc.gov U.S. Nuclear Regulatory Commission Office of the Secretary of the Commission

Mail Stop: O-16C1

Washington, DC 20555-0001 Hearing Docket E-mail: hearingdocket@nrc.gov Diane Curran, Esq.

Matthew D. Fraser, Esq.

Representative of Southern Alliance for Clean Energy (SACE) Matthew Harmon, Curran, Spielberg & Eisenberg, L.L.P. 1726 M Street N.W., Suite 600

Washington, D.C. 20036 E-mail: dcurran@harmoncurran.commfraser@harmoncurran.comSigned (electronically) by Paul M. Bessette Paul M. Bessette, Esq.

Morgan, Lewis & Bockius LLP 1111 Pennsylvania Avenue, N.W.

Washington, D.C. 20004

Phone: 202-739-3000

Fax: 202-739-3001 E-mail: pbessette@morganlewis.com

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