ML21259A035

License Renewal Pre-Application Submittal Meeting Sept 2021 Environmental Report

ML21259A035
Person / Time
Site:	Comanche Peak
Issue date:	09/16/2021
From:	Luminant Generation Co
To:	NRC/NRR/DNRL
James L, NRR/DNRL/NRLP, 301-415-3306
References
EPID L-2020-RNW-0029
Download: ML21259A035 (19)

Text

Comanche Peak Nuclear Power Plant (CPNPP)

First License Renewal (60 years) Application:

Environmental Pre-Application Submittal Meeting

September 2021 Opening Remarks and Introductions

Speakers Steven Sewell (Luminant)

Todd Evans (Luminant)

Participants Randy Harding (Luminant)

Stacy Burgess (Enercon)

Rachel Turney-Work (Enercon)

2 Agenda

General Information Introduction to CPNPP Key Discussion Topics Methodology & Permits / Authorizations / Alternatives Agency and Tribal Consultations Groundwater Monitoring Program & ISFSI Ecology SAMA Update Lessons Learned Additional Topics Closing Remarks

3 General Information Project Team Luminant LR project team Luminant line organization subject matter experts Luminant corporate (Vistra) environmental ENERCON environmental team Project Team Experience Luminant engaged in NEI License Renewal Environmental Task Force Luminant conducted extensive LR Feasibility Study in 2019 Luminant attends LR related public meetings Experienced Luminant technical personnel Engaged resources with extensive LR experience - ENERCON

4 General Information (cont.)

Building a high-quality Environmental Report Review and address recent applicant RCIs, RAIs and Supplements (River Bend, Waterford, Turkey Point, Peach Bottom, Surry)

Monitoring on-going applicants (North Anna, Point Beach, Oconee, St Lucie)

Use of proven technical and administrative procedures informed by current regulatory guidance Periodic process related check-ins Industry Peer Review to be conducted prior to submittal Lessons Learned Submittal Plan On track for application submittal Oct-Dec 2022

5 General Information (cont.)

CPNPP Units 1 and 2 Four Loop Westinghouse PWRs that are nearly identical Located in north Texas, southwest of Dallas-Fort Worth

CPNPP Upgrade History Unit 1 Unit 2

Initial License, 3411 MWt 1990 1993

Leading Edge Flow Meter Technology, 3458 MWt 2001 1999 / 2001

Stretch Power Uprate, 3612 MWt 2008 2008

SG & RVCH Replacements 2008 N/A

Current License Expiration Date 2/8/2030 2/2/2033

6 Introduction to CPNPP: Site

12

1 11 2 3 4 5 8 9

6 7

10

7 Introduction to CPNPP: Site

CPNPP Site is about 7,700 acres and includes the Squaw Creek Reservoir Located in southern Hood and northern Somervell Counties, TX No ground disturbances or refurbishment activities planned as a result of License Renewal No planned changes in operations for the Period of Extended Operations

8 Introduction to CPNPP: 6-Mile Vicinity

9 Introduction to CPNPP: 50- Mile Region

10 Key Discussion Topics: Methodology & Permits /

Authorizations / Alternatives

Methodology Regulatory Standard Practices Incorporate by Reference Permits / Authorizations Coastal Zone Management Act Texas Pollutant Discharge Elimination System Permit Clean Water Act 401 Certification Alternatives Analysis Advanced Light Water Reactor Nuclear Alternative Small Modular Reactor Nuclear Alternative Natural Gas Combined Cycle Alternative Combination Alternative (Natural Gas, Solar, and Wind)

11 Key Topic Discussions: Agency and Tribal Consultations

Initiated agency consultations early in the ER development Agencies Texas Commission on Environmental Quality Texas General Land Office Texas Historical Commission Texas Parks and Wildlife Department US Fish and Wildlife Service Texas Department of State Health Services Letters sent to 20 different Tribes Letters sent to other agencies and stakeholders to inform them about the License Extension

12 Key Discussion Topics: Groundwater Monitoring Program and ISFSI

Groundwater Protection Program CPNPP implemented a groundwater protection program in 2008 Well water samples below lower limit of discrimination (2,000 pCi/L)

ISFSI Current onsite ISFSI pad can accommodate 40 years of operation Potential ISFSI expansion cannot be determined at this time and Luminant is not considering expansion

13 Key Discussion Topics: Ecology

Threatened and Endangered Species No federally listed species known to exist at CPNPP site nor along in-scope transmission line ROWs Five species federally protected under Endangered Species Act (ESA) that have probability of occurring within the 6-mile radius Nine state-listed species listed as potentially occurring in Hood and Somervell counties Essential Fish Habitat (EFH)

No EFH is located within the vicinity of CPNPP, nor were any EFH areas protected from fishing No habitat areas of particular concern (HAPCs) are located within the 6-mile vicinity of CPNPP

14 Key Discussion Topics: SAMA Update

SAMDA analysis performed in 1989 as part of the initial licensing of the plant SAMA analysis for CPNPP will be performed using the methodology documented in NEI 17-04, Revision 1 The results of this analysis will be detailed in the SAMA Basis Document and summarized in the ER

15 Lessons Learned

Incorporate lessons learned from previously submitted ER & SAMA analyses into the CPNPP ER and basis documents SAMA Evaluations Agency Consultations Review and incorporate applicable information into CPNPP LR ER based on previously submitted LR and SLR ER RAIs (e.g. River Bend, Waterford, Turkey Point, Surry, Point Beach)

Engagement in NEI License Renewal Environmental Task Force Industry peer review provides useful feedback to refine the ER Allocate sufficient time to test IT resources and resolve issues (e.g.,

access to e-Portal)

Receiving and responding to environmental audit information needs prior to audit to allow time for NRC review prior to audit sessions The most recent 5 years of data, available at the time of development, is included in the environmental report

16 Additional Topics

Any foreseeable future aspect the staff sees that may need to be addressed by Luminant Other issues or updates

17 Closing Remarks

CPNPP application will be consistent with industry practices and lessons learned from recent LRs/SLRs and meet NRC requirements

Luminant will submit a high-quality application that can support an 18 month staff review

CPNPP application is on track to be submitted to the NRC in October to December 2022

18 LR Environmental Report Pre-Submittal Meeting

References

1. NUREG/BR- 0184, Regulatory Analysis Technical Evaluation Handbook, U.S. Nuclear Regulatory Commission, 1997 (ML111290858).

2. NUREG-1555, Standard Review Plan for Environmental Reviews for Nuclear Power Plants, Supplement 1, Operating License Renewal, Final Report, Revision 1 - June 2013, Sections 5.1 and 5.2 (ML13106A246).

3. Comanche Peak Steam Electric Plant Letter No. TXX -89720, Severe Accident Mitigation Design Alternatives (SAMDAs), September 22, 1989 (ML20248D047).

4. NEI 17-04, Revision 1, Model SLR New and Significant Assessment Approach for SAMA, August 2019 (ML19316C718).

5. U.S. NRC, Interim Endorsement of NEI 17- 04, Model SLR [Subsequent or Second License Renewal]

New and Significant Assessment Approach For SAMA, Revision 1, Letter from Anna Bradford, Director Division of New and Renewed Licenses Office of NRR to Chris Earls, Senior Director Regulatory Affairs, NEI, December 11, 2019 (ML19323E740).

6. RG 4.2, Supplement 1, Revision 1, Preparation of Environmental Reports For Nuclear Power Plant License Renewal Applications June 2013 (ML13067A354).

7. Environmental Review for Renewal of Nuclear Power Plant Operating Licenses, 61 Fed. Reg. 28,467, 28,481 (June 5, 1996).

19