ML053640304
| ML053640304 | |
| Person / Time | |
|---|---|
| Site: | Nine Mile Point  |
| Issue date: | 12/15/2005 |
| From: | Spina J Constellation Energy Group |
| To: | Division of Administrative Services |
| References | |
| 70FR58489 00002, NMPE 0587, TAC MC3274, TAC MC3275 | |
| Download: ML053640304 (8) | |
Text
Constellation Energy Nine Mile Point Nuclear Station P.O. Box 63 Lycoming, NY 13093 December 15, 2005 NMPE 0587.T1 F]'T]Ca C_')3:: 49 Chief, Rules Review and Directives Branch U.S. Nuclear Regulatory Commission Division of Administrative Services Office of Administration Mail Stop T-6D59 Washington, DC 20555-0001 c Cr M CO r- u HI, C_'SC30
Subject:
Comments regarding the Draft Plant-Specific Supplement 24 to the Generic Environmental Impact Statement for License Renewal of Nuclear Plants regarding Nine Mile Point Nuclear Station, Units 1 and 2, Docket Nos. 50-220 and 50-410 (TAC Nos. MC3274 and MC3275)
Dear Sir:
Constellation Energy has reviewed the subject document and is providing the attached comments for your consideration when developing the Final Supplemental Environmental Impact Statement for the Nine Mile Point Nuclear Station, Units 1 and 2, License Renewal Application.
Our review focused on technical content, and the majority of our comments identify corrections.
Sincerely, es A Spina Vice President Nine Mile Point JAS/KES/sac Attachment cc: Ms. L.C. Fields, NRC Environmental Project Manager Mr. L.M. Cline, NRC Senior Resident Inspector Mr. J. Zappieri, Coastal Resources, NY Dept. of State Mr. J. Feltman, Regional Permit Administrator NYSDEC Region 7 Mr. J.A. Nasca, Environmental Permits, NYSDEC Mr. P.D. Eddy, Electric Division, NYS Dept. of Public Service ,ef:Ib! An-d-d =-3;- // -fl as/ (J1 ev
- v. -Review Comments on GEIS, Supplement 24 Regarding Nine Mile Point Nuclear Station, Units 1 & 2 DSEIS Comment Page #No. Line# Comment(s)
Page xxi, Acronym 'NMP' should refer to Nine Mile Point Units 1 and 2.1 Line 1 It is used once in Draft Supplement Environmental Impact Statement (DSEIS) on page 5-5, Line 31 and is in context of Nine Mile Point.2 Page 1-7, NMP Units 1 and 2 produce enough electricity to power 2 Line 23 million homes.3 Page 1-7, Change reference citation (NMPNS 2000) to (NMPNS 2004) to Line 25 reflect cited reference in DSEIS.Page 2- Value for particulates should be 2.71x1 0-2 Ci and 1003 MBq, 4 14, as documented in Attachment 2 of the following references:
Line 34 NMPNS 2001b and c, NMPNS 2002b and c, NMPNS 2003d and e, NMPNS 2004a and b, and NMPNS 2005a and b.Page 2- Unit 2 value for particulates should be 2.29x1O-3 and 84.7 MBq, z 5 15, as documented in Attachment 2 of the following references:
Line 5 NMPNS 2001b and c, NMPNS 2002b and c, NMPNS 2003d and e, NMPNS 2004a and b, and NMPNS 2005a and b.Page 2- Revise " ...which can handle up to 454m 3/d (120,000 gpd)" to 16, read "... which is permitted for 454m 3/d (120,000 gpd) as a 30-6 Line 39 day average. Daily flows range from 1 32-908m 3/d (35,000-Page 2- 240,000 gpd)." to be consistent with information in NMPNS 17, Line 1 2004e.Page 2- Reference NMPNS 2004e does not support the information 7 31, Lines presented and should be removed and/or replaced.13-23 Page 2- The text states the Oswego River is the spawning area for lake 33, Lines sturgeon.
While it has been identified in the past as a 2-3 spawning area based on 1982 observations as documented in NYSDEC 2004b, it is not certain if it is still a viable spawning area. More recently, NYSDEC has identified four areas where 8 distinct and reproducing populations remain (St. Lawrence River downstream of Massena, Niagara River above and downstream of the Falls and the Grasse River in St. Lawrence County as indicated in a NYSDEC 2003 press release[http:/h/ww.dec.state.ny.us/website/reg6/press/2003/6ro322.ht ml].Page 2- The date 1070 should be changed to 1970 as documented in 9 34, Line reference NMPNS 2004e. Also, Provence should be changed 23 to Province.Page 1 of 7 Review Comments on GEIS, Supplement 24 Regarding Nine Mile Point Nuclear Station, Units I & 2 DSEIS Comment Page #No. Line# Comment(s)
Page 2- Dreussena should be Dreissena as documented in reference 10 35, Line NMPNS 2004e.11 Page 2- Reference NMPNS 2004e does not support the information 11 38, Lines presented and should be removed and/or replaced.18-21 Page 2- The date of the survey should be changed from 1979 to 1976 12 40, Line as documented in NMPC 1985.20 13 Page 2- 'The FWS' should be changed to 'the FWS' where it occurs.41, Line 4 Page 2- Suggest adding the following:
'Occurrence at the Nine Mile 14 43, Line Point site or associated rights-of-way has not been 25 documented.'
as supported by reference NMPNS 2004e.Page 2- The maximum organ dose is incorrect.
Revise value to 1.5 47 Lines 0.0000073 mSv (0.00073 mrem) as documented in the 38-39 references NMPNS 2005a and 2005b.tA Page 2- The range for the maximum organ dose is incorrect.
Revise a~i 48, Line the values to 8.03x10-7 mSv and 4.0x10-5 mSv (8.03 x 10-5 1I6 20 mrem and 4.0 x 10-3 mrem) as documented in the references NMPNS 2001b and c, NMPNS 2002b and c, NMPNS 2003d and e, NMPNS 2004a and b, NMPNS 2005a and b.Page 2- The maximum organ dose presented (0.23 mrem) is the 48, Lines calculated average, not the maximum organ dose, for the 17 23-24 period 2000 to 2004 (References NMPNS 2001b and c, NMPNS 2002b and c, NMPNS 2003d and e, NMPNS 2004a and b, NMPNS 2005a and b). The text should be corrected to so note.Page 2- "Independence Station" should be capitalized as it is a proper 18 51, Line name.12 Page 2- Percent of total acres for Oswego County in the land use 53, Table categories of "Public" and "Commercial and Industrial" are not 9 2-10 documented in Reference NMPNS 2004e. An additional 1 and Page reference is needed.2-52, Line 25 Page 2 of 7 I Review Comments on GEIS, Supplement 24 Regarding Nine Mile Point Nuclear Station, Units 1 & 2 DSEIS Comment Page #No. Line# Comment(s)
Page 2- Height of the cooling tower is 541 feet as documented in 20 53 Line reference NMPNS 2004e.32 Page 2- Footnote should be added to Table 2-13 explaining conversion 58, Line of actual dollars as found in the cited reference to '2005 dollars'21 5-14 used in the text and table.Page 2-59, Table 2-13 Page 2- Data for the year 2001 is not in the cited reference, NMPNS 22 58, Line 2004e. If the 2001 data is available, add appropriate 12 reference.
Page 2- Fitzpatrick Nuclear Power Plant is no longer owned by the New 23 63, Line 9 York Power Authority.
The text should be corrected to reflect_ _ ownership by Entergy.X Page 2- Information is needed to complete NOM references 2004b 24 67, Lines and 2004c.7-8 Page 2- Reference NMPC 1975 appears to be a duplicate of NMPC 69, Lines 1976 and should be deleted or corrected.
Associated change 11-12 will be required on page 2-27, Line 15. Also, delete 'West'from 'West Syracuse.'
Page 2- Reference -RREDC 2004a appears to be incomplete.
26 72, Lines Additional information needed.10-11 Page 2- Reference EPA 2004 appears to be incomplete.
Additional 27 73, Line information needed.17 Page 4- Clarify that the Phase II performance standards are designed 12, Lines to significantly reduce entrainment losses due to plant 28 20-21 operation from a baseline condition.
This fact is important because NMP already has some "credits" against the baseline condition as defined in the Phase II rule.Page 4- The text states that there is a discharge canal. Given that 29 13, Line there is no discharge canal at Nine Mile Point, please revise.34 Page 3 of 7 or I Review Comments on GEIS, Supplement 24 Regarding Nine Mile Point Nuclear Station, Units I & 2 DSEIS Comment Page#No. Line# Comment(s)
Page 4- Clarify that the Phase II performance standards are designed 15, Lines to significantly reduce entrainment losses due to plant 30 29-30 operation from a baseline condition.
This fact is important because NMP already has "credits" against the baseline condition as defined in the Phase II rule.Page 4- Percent of Individuals Collected values appear to be averages 16, Lines of percent per year. Given the variation in total numbers 1-12 impinged each year, a better representation of the percentages 31 would be to divide the total number impinged of each species by the total impinged.
For example, the latter calculation results in 82% for alewife and 7% for smelt compared to 60%and 20% as stated on page 4-16.Page 4- "Proceeding" should be revised to "Following." 32 16, Line 13 Page 4- Over the period discussed (1 972-1983), rainbow smelt were 3 16, Line also the most abundant species impinged in 1982, in addition i 19 to 1979 as documented in reference NMPNS 2004b.d Page 4- As documented in reference NMPNS 2004b, the highest A 16, Line number of fish impinged was in 1973 rather than 1976.22 Greater than 5 million fish were estimated to be impinged during that year. Please revise.Page 4- As documented in reference 2004b, large die-offs of alewife 18, Line 6 typically occur during winter, not spring. Please revise.Page 4- Cited reference NMPNS 2004b does not support information 36 20, Line presented in Lines 27-32 regarding tree trimming, herbicide.34 use, mowing, and use of buffer strips. Please revise to clarify the source of this information.
Page 4- Cited reference NMPNS 2004b does not fully support 24, Lines statements on Lines 20-23 indicating that field measurements 18-24 demonstrated compliance with NESC and that Nine Mile Point transmission lines are below the size of concern for induced shock. Suggest revising to indicate that compliance with the NESC code was demonstrated by field measurements and computer analyses, and deleting sentence regarding size of transmission lines.Page 4 of 7 W .I- ': ' I r Review Comments on GEIS, Supplement 24 Regarding Nine Mile Point Nuclear Station, Units 1 & 2 DSEIS Comment Page# ; .No. Line# Comment(s)
Page 4- Text should be changed to reflect that tax payments to the City 32, Line have fallen from 56 percent to 43 percent over the period from 38 14 1995 to 2000. Data was not available for the year 2001 in the cited reference, NMPNS 2004b. Or, if data available, add appropriate reference.
Page 4- Shaded areas on Figure 4-1 do not appear to correspond to 37, Figure areas noted in text of page 4-38 as having minority 4-1 populations.
No minority populations were identified in Oswego or Seneca Counties in the text and there are some 39 depicted on the figure. Jefferson County is noted as having minority populations, yet none are apparent on the figure. The minority populations depicted on the figure in Cayuga County do not appear to correspond to those in the cited reference._ NMPNS 2004b.l ;Page 4- Shaded areas on Figure 4-2 do not appear to correspond to 39, Figure areas noted in text on page 4-38 as having low-income 4-2 populations.
The low-income populations depicted on the figure in Cayuga, Oswego, Oneida, and Jefferson Counties do not appear to correspond to those in the cited reference NMPNS 2004b.Page 8-8, Mention is made of the "Lakeview Subdivision immediately Line 8 west" of NMP (also shown on Figure 2-3). This area is now 41 occupied by the Ontario Bible Conference Camp, which is mentioned on page 2-1, Line 23 and shown on Figure 2-2 of the DSEIS. NRC may wish to revise this sentence to clarify this point.Page 8- The DSEIS states particulate emissions estimate data as 181-14, Lines tons PM 1 0.The correct data are 181 tons total (filterable) and 42 16-17 41 tons PM 1 0 (NMPNS 2004, page 7-35).Page 8-10, Line 13 Page 8- The assumption of a 40-year operating life as stated here is not 19, Line 1 supported by the applicant's ER (NMPNS 2004), which is cited as the source of assumptions and numerical values in Section 8.2.2 unless otherwise indicated (page 8-18, Lines 32-33).Consider resolving the inconsistency by using the ER assumption (25 years) or citing another appropriate source.Page 5 of 7
-I I --',-, V- ",.N. -c Review Comments on GEIS, Supplement 24 Regarding Nine Mile Point Nuclear Station, Units I & 2 DSEIS Comment Page # 31 No. Line# Comrmient(s)
Page 8- The estimated land requirement for the gas-fired alternative of 44 19, Line 1600 acres is inconsistent with the 110 acre estimate cited 20 elsewhere in this section (page 8-23, Line 12) and NMP ER (NMPNS 2004).Page 8- The statement that no groundwater is currently used for NMP 34, Line operation could be viewed as inconsistent with the fact that a 45 25 dewatering system is employed for NMP Unit 2 (see Section 4.5.1 of the DSEIS). Acknowledgement of the dewatering system here should be considered for clarity.Page 8- For clarity and consistency with the analysis presented in 46, Lines DSEIS Section 8.2.5.10 and in the NMP ER Section 7.2.3.2 46 6-8 (NMPNS 2004), the phrase "retirement of other Constellation Energy Group generating units" should be replaced with"retirement of other generating units directly controlled by owners of Nine Mile Point".Page 8- Adverse impacts for Nine Mile Point Site alternative in the 48, Ecology and Aesthetics impact category in this table are Line 7, greater than those presented in Table 8-3, yet the primary Page 8- contributor to impact is a comparable but smaller capacity gas-50, Line 1 fired combined-cycle plant. This apparent inconsistency in the DSEIS should be resolved.48 Page 8- The NMP ER (NMPNS 2004) is cited in Chapter 8 (e.g., page 52 8-7), but is not included in the list of references in Section 8.4.Page 9-8 Adverse impacts for Combination of Altematives Nine Mile Lines 8, Point Site alternative in the Ecology and Aesthetics impact 30 categories in this table are greater than those presented in 49 Table 8-3, yet the primary contributor to impact is a comparable but smaller capacity gas-fired combined-cycle plant. NRC may wish to consider revising to resolve this apparent inconsistency in the DSEIS.Page 9-8, Adverse impacts for New Nuclear Generation Alternate Site in 50 Line 29) the Aesthetics impact category in this table are different than those presented in Table 8-5, page 8-33. This inconsistency in the DSEIS should be resolved.Page G- Revise the initial number of potential SAMA candidates from 51 1, 223 to 220 to be consistent with Chapter 5 of the DSEIS.Line 16 Page G- Correct 7.5x1 0-5 to 7.5x104.52 5, Line 2 Page 6 of 7 Review Comments on GEIS, Supplement 24 Regarding Nine Mile Point Nuclear Station, Units 1 & 2 DSEIS Comment Page #No. Line# Comment(s)
Page G- Revise value of CDF from 23 to 2.3 (or 2 considering 53 17, significant digits) used in table to be consistent with the NMP Line 9 ER (NMPNS 2004).Page 7 of 7