ML022560046

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Comment of Michael P. Gallagher Concerning Draft Plant-Specific Supplement 10 to the Generic Environmental Impact Statement Regarding Peach Bottom Atomic Power Station
ML022560046
Person / Time
Site: Peach Bottom  Constellation icon.png
Issue date: 08/27/2002
From: Gallagher M
Exelon Nuclear
To:
NRC/ADM/DAS/RDB
References
67FR44245 00008, NUREG-1437
Download: ML022560046 (5)


Text

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Exelon Nuclear www exelonc c&Mn

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August 27, 2002 Chief Rules and Directives Branch Mailstop T-6D 59 U.S. Nuclear Regulatory Commission Washington, DC 20555-0001

Subject:

Comments Concerning Draft Plant-Specific Supplement 10 to the Generic Environmental Impact Statement Regarding Peach Bottom Atomic Power Station

Dear Sir:

This letter is being submitted in response to the NRC's request for comments concerning the draft plant-specific Supplement 10 to NUREG-1 437, "Generic Environmental Impact Statement for License Renewal of Nuclear Plants," regarding the renewal of operating licenses for Peach Bottom Atomic Power Station (PBAPS), Units 2 and 3, for an additional 20 years of operation.

Exelon Generation Company, LLC appreciates the opportunity to comment on this draft Supplement 10 to NUREG-1437. We agree that the adverse environmental impacts of license renewal for PBAPS are not so great that preserving the option of license renewal for energy planning decisionmakers would be unreasonable.

Specific comments on draft Supplement 10 to NUREG-1437 are provided in Attachment 1.

If you have any questions, please do not hesitate to contact us.

Very truly yours, Michael P. Gallagher Director, Licensing & Regulatory Affairs Mid-Atlantic Regional Operating Group

Enclosures:

Attachment 1 171 '4561

ArrACHMENT 1 Comments on Draft Supplement 10 to NUREG-1437 Attachment 1 Page 1 of 3 Number Location (pg/line) What is in DEIS What should be in DEIS Why the change 1 1-11 / 4,7 Excelon Exelon Spelling 2 2-7 / 18 The operation is infrequent This dredging operation is English 3 2-7 / 29, 32, 34 'rocket' This term should be The term 'rocket' is a deleted. colloquial term that does not come from product literature.

4 2-6 / 25 Conowongo Conowingo Spelling 5 2-11/17 ... water storage tank. ... water storage tank, and The fourth tank is not Torus dewatering tank. named properly.

6 2-19/12 ... uses an ammonium uses an Quaternary- Correction to what is used.

chloride-based molluscide amine-based molluscide 7 2-21 /38 ... a consortium of a consortium of utilities The consortium also Federal, regional, ... and Federal, regional, ... included utilities.

8 2-37/2, 8 emission stacks emission stack There is only one off-gas stack visible at Peach Bottom.

9 2-37 / 8 There is no visible plume There is no visible vapor Clarify that the plume that plume ... is being talked about is a water vapor plume.

10 2-43/24 and railroads) were and railroads, etc.) were These taxes were collected from more than just the utilities shown.

11 2-47/39 NRC is consulting with the NRC has consulted with Consultation has already FWS. the FWS. taken place.

12 4-15 / 13-15 The designed operation These sentences should The impingement criteria criteria are maintained in be deleted. are maintained at the part by removal of outer intake structure.

sediments that are The intake canal, and the deposited in the canal. sediment removal Maintenance of the described here, follow the designed depth for the intake structure and, as intake canal helps ensure such, have no bearing on that approach velocities at maintaining the intake the screens meet criteria. velocities necessary to reduce impingement.

13 4-15/19 NPDES Permit NPDES Permit PA Correction to the number PA00097733 0009733 on the permit.

14 4-17/9 Five mechanical draft Three mechanical draft While it is true that five cooling towers ... cooling towers are located towers were built, the on berms... permit now allows for three towers. Since three towers are allowed by permit, there are now three towers standing.

15 4-34 /33 Hisroric Historic Spelling.

Comments on Draft Supplement 10 to NUREG-1437 Attachment 1 Page 2 of 3 Number Location (pg/line) What is in DEIS What should be In DEIS Why the change 16 4-36 / 24-25 The applicant should While Exelon has stated reflect the aforementioned that it did not anticipate in its licensing basis any additional land commitments and, ... disturbances, or major structural modifications, or maintenance activities beyond previously disturbed areas as a result of license renewal, these were not licensing basis commitments. If it was determined that any of these areas needed to be addressed as a result of license renewal, then the proper Federal, State, and local agencies would be consulted prior to the I activity.

17 4-36 / 26 ... not have an effect ... not have an effect on Remove duplicate effect on any ... any ... wording.

18 4-36 / 35-36 Given the commitments of Given the commitments of Exelon has committed in the applicant to avoid the applicant to limit land letters to appropriate future disturbances and to disturbances in support of agencies, to limit control access to lands it license renewal, ... maintenance activities to manages, ... previously disturbed areas and it has stated that it did not anticipate any additional land disturbances in support of license renewal. No commitments were made to avoid all future land disturbances nor to control access to lands it manages.

19 4-38 1 6-10 The listing of counties is For counties entirely in the Correction to the proper not correct. 50 mile zone, delete Kent information.

County DE, and add New Castle County DE. For counties partially in the 50 mile zone: add Kent County DE.

20 4-38/22 ... criteria, Table 4-8 ... criteria, Figure 4-1 Correction to the proper indicates ... indicates ... graphic.

21 4-39 / Map Maryland Counties include Maryland Counties include Spelling and correction to Kent and Queen Annes. Queen Anne, but not Kent. the proper information.

22 4-45 / 30-31 ... and its independent ... and its independent Delete the pending analysis, and pending the analysis, it ... consultation with FWS outcome of consultation since that has already with the FWS, it ... occurred.

23 4-45 / 34-35 Therefore, it is the staff's Therefore, it is the staff's Consultatibn with FWS preliminary determination ... has been completed.

determination...

24 4-48/38 BEIR Biological Effects of Spelling of acronym at first Ionizing Radiation (BEIR) usage.

Comments on Draft Supplement 10 to NUREG-1 437 Attachment 1 Page 3 of 3 Number Location (pglline) What is In DEIS What should be in DEIS Why the change 25 4-51 /13 ... isptope ... ... isotope ... Spelling 26 4-51 / 35 Considerable of technical A considerable amount of English literature ... literature ...

27 4-58/12 Units w and E...DPR44 Units 2 and 3...DPR-44 Spelling and Dpr-56 and DPR-56 28 6-6 / 17-21 On February 15, 2002, On July 23, 2002, the Change in status of the 6-8 /29-30 subsequent to the ... This President signed into law Yucca Mountain project.

change in regulatory House Joint Resolution 87 status does not cause the designating Yucca staff to change its Mountain as the repository position.... for spent nuclear fuel.

29 8-38/37 ... construc-tion ... ... construction ... Spelling 30 8-55/7 Pennsylvania Power & Exelon Generation Spelling Light Company (Exelon) Company, LLC (Exelon) 31 F-2 / 24 A.1 F.1 Spelling