ML25177A046
| ML25177A046 | |
| Person / Time | |
|---|---|
| Site: | Robinson  |
| Issue date: | 06/30/2025 |
| From: | Loomis K NRC/NMSS/DREFS/EPMB1 |
| To: | Basta L Duke Energy Progress |
| References | |
| Download: ML25177A046 (1) | |
Text
Laura Basta Site Vice President H. B. Robinson Steam Electric Plant Duke Energy Progress, LLC 3581 West Entrance Road, RNPA11 Hartsville, SC 29550
SUBJECT:
H. B. ROBINSON STEAM ELECTRIC PLANT, UNIT 2 - LICENSE RENEWAL REGULATORY AUDIT REGARDING THE ENVIRONMENTAL REVIEW OF THE LICENSE RENEWAL APPLICATION (EPID NUMBER: L-2025-SLE-0000)
(DOCKET NUMBER: 50-261)
Dear Laura Basta:
By letter dated April 1, 2025, (Agencywide Documents Access and Management System Accession No. ML25091A291), Duke Energy Progress, LLC, submitted to the U.S. Nuclear Regulatory Commission (NRC) an application for license renewal of Facility Operating License No.
DPR-32 for H. B. Robinson Steam Electric Plant, Unit 2 (RNP) pursuant to Section 103 of the Atomic Energy Act of 1954, as amended, and Part 54 of Title 10 of the Code of Federal Regulations, Requirements for renewal of operating licenses for nuclear power plants. The NRC staff has initiated the environmental review for the application. A virtual environment audit will be conducted the week of July 14, 2025 by NRC staff see Enclosure 1.
To the extent possible, the NRC staff requests the information identified in the Environmental Audit Needs List Enclosure 2 be made available on the RNP online reference portal prior to the audit. A draft schedule is provided in Enclosure 3.
If you have any questions, please contact me via email at Karen.Loomis@nrc.gov.
Sincerely, Karen L. Loomis Environmental Project Manager Environmental Project Management Branch 1 Division of Rulemaking, Environmental, and Financial Support Office of Nuclear Material Safety and Safeguards Docket No. 50-261
Enclosures:
As stated June 30, 2025 Signed by Karen Loomis on 06/30/25
ML#########
OFFICE NE/PM:EPMB1 LA:REFS BC:EPMB1 NE/PM:EPMB1 NAME KLoomis AWalker-Smith SKoenick KLoomis DATE 6/26/2025 6/26/2025 6/30/2025 6/30/2025 Audit Plan License Renewal Environmental Review H. B. Robinson Steam Electric Plant, Unit 2 July 2025
2 License Renewal Environmental Review H. B. Robinson Steam Electric Plant, Unit 2
1. Background
By letter dated April 1, 2025 Agencywide Documents Access and Management System Accession No. ML25091A291, Duke Energy Progress, LLC (Duke, the applicant), submitted to the U.S.
Nuclear Regulatory Commission (NRC) an application for license renewal of Facility Operating License No. DPR-32 for H. B. Robinson Steam Electric Plant, Unit 2 (RNP) pursuant to Section 103 of the Atomic Energy Act of 1954, as amended. A Federal Register (FR) Notice (90 FR 19535) dated May 8, 2025, noted the receipt and availability of the application, including the environmental report (ER).
The NRC staff is conducting an environmental audit of the RNP site to improve understanding, to verify information, and to identify information for docketing to support the preparation of an environmental impact statement. Specifically, the NRC staff will be identifying pertinent environmental data, reviewing the facility, and seeking clarifications regarding information provided in the ER.
2.
Environmental Audit Bases License renewal requirements for environmental reports are specified in Title 10 of the Code of Federal Regulations (10 CFR) Part 51, Postconstruction environmental reports. As specified by 10 CFR 51.53(c): Operating license renewal stage, (1) Each applicant for renewal of a license to operate a nuclear power plant under Part 54 of this chapter shall submit with its application a separate document entitled "Applicant's Environmental ReportOperating License Renewal Stage." Review guidance for the staff is provided in NUREG-1555, Supplement 1, Revision 1, Standard Review Plans for Environmental Reviews for Nuclear Power Plants: Supplement 1 -
Operating License Renewal.
The NRC staff is required to prepare a site-specific supplement to NUREG-1437, Generic Environmental Impact Statement for License Renewal of Nuclear Plants. During the scoping process required in 10 CFR 51, the NRC staff is required to define the proposed action, identify significant issues which must be studied in depth, and to identify those issues that can be eliminated from further study.
3.
Environmental Audit Scope The scope of this environmental audit is to identify new and significant issues and issues which can be eliminated from further study. The NRC staff will also identify environmental resources that must be described and evaluated in the Supplemental Environmental Impact Statement.
Audit team members will review the documents and other requested information made available on the RNP online reference portal identified on the environmental audit needs list (Enclosure 2) and discuss any questions and additional information needs with the applicants subject matter experts.
4.
Information and Other Material Necessary for the Environmental Audit As identified on the environmental audit needs list (Enclosure 2).
3 5.
Environmental Audit Team Members and Resource Assignments The environmental audit team members and their assignments are shown in the table below.
Discipline Team Members Environmental Review Supervisor Steve Koenick Environmental Project Manager Karen Loomis Backup Environmental Project Manager Kim Conway Air Quality Nancy Martinez Aquatic Resources Mitchell Dehmer Federally Protected Ecological Resources Shannon Healy (Duke as NFR)
Geologic Environment Gerry Stirewalt Greenhouse Gases/Climate Change Brian Glowacki Groundwater (Hydrology and Hydrogeology)
Gerry Stirewalt Historic and Cultural Resources Beau Goldstein Human Health Rao Tammara Land Use and Visual Resources Caroline Hsu Meteorology and Climatology Nancy Martinez Noise Nancy Martinez Postulated Accidents Bill Rautzen/Elijah Dickson Replacement Power Alternatives Peyton Doub Severe Accident Mitigation Alternatives Bill Rautzen/Elijah Dickson Socioeconomics Caroline Hsu Spent Nuclear Fuel Rao Tammara Surface Water Lloyd Desotell Termination of Operations and Decommissioning Rao Tammara Terrestrial (Land Cover and Habitat)
Shannon Healy Uranium Fuel Cycle Rao Tammara Waste Management (Rad and Non-Rad)
Rao Tammara 6.
Logistics An environmental audit will be conducted by NRC staff virtually the week of July 14, 2025. An entrance meeting will be held with plant management at the beginning of the environmental audit and an exit meeting will be held following the conclusion of the virtual audit.
7.
Special Requests Duke staff and contractors who are subject matter experts in the disciplines identified on the environmental audit needs list should be available for interviews and tours.
8.
Deliverables An audit summary report will be issued by the NRC staff within 90 days from the end of the environmental audit.
4 Audit Tours and Information Needs H. B. Robinson Steam Electric Plant, Unit 2 Described below in three categories (i.e., virtual tours, meetings, and information needs) are the information needs of the U.S. Nuclear Regulatory Commission (NRC) staff, supported by Pacific Northwest National Laboratory (PNNL), for Robinson Nuclear Plant, Unit 2. Please arrange for the tours and meetings specified below to occur during the virtual environmental audit. Additionally, we ask that you provide responses to the information needs on the electronic portal and make subject matter experts (SMEs) available to discuss these items with the NRC staff.
Virtual Tours Please arrange for, and provide appropriate subject matter experts to contribute to, the following virtual tours. For the virtual tours, please provide photographs, diagrams, location maps, and/or callouts for specific components that would be of interest for the features noted.
Number and Title Features Observed NRC Participants PNNL Participants
- 1. General site Virtual walk-through of the following via photographs and/or diagrams:
Exterior grounds Transmission lines Historic and cultural sites Possible alternative power generation locations Independent Spent Fuel Storage Installation (ISFSI)
Plant views from publicly accessible areas All All Available
- 2. Plant intake and discharge Virtual walk-through of the following via photographs and/or diagrams:
Intake surrounding area views View from vicinity of the dam spillway back toward the intake Intake bays Intake traveling screens and trash baskets Cooling Water Intake System system pathway from intake to discharge Discharge flume (beginning overview of flume, and ending at lake)
Discharge terminus (grates, gating, mesh, weir)
Discharge surrounding area view Settling ponds Robinson Dam and spillway structure. Discussion of how Lake Mitchell Dehmer Philip Meyer
5 Number and Title Features Observed NRC Participants PNNL Participants Robinson water levels are maintained under normal and high flow conditions.
Fish return, from debris troughs to entry point 400 ft downstream Lake Robinson Dam
- 4. Groundwater Resources Virtual walk-through of the following via photographs and/or diagrams:
Ash basin associated with former Unit 1 coal-fired energy production and groundwater monitoring wells for the ash basin and/or the Class 3 landfill site constructed for coal combustion residuals disposal.
Surrounding view from west edge of plant parking area looking from the north to the west to the south.
View of the settling ponds and surrounding area.
Locations of groundwater monitoring wells, including wells where tritium was detected (e.g., MW-106 where maximum of 7,090 pCi/L was detected in the second quarter of 2022).
Location of sheet piling installed to stabilize the shoreline around the intake structure that may locally block the hydraulic connection between the lake and the shallow groundwater.
Gerry Stirewalt Philip Meyer Meetings Please be prepared to schedule breakout meetings with the appropriate SMEs and/or contractor(s) concerning the following topics. Those in attendance should be prepared to discuss the corresponding questions as described in the Information Needs and Document Requests section below. The staff intends to use these breakout meetings, as needed, to resolve or clarify any outstanding data needs or questions arising from the environmental audit. The NRC intends to leverage virtual breakouts to the extent possible. No in-person breakouts are needed at this time.
General Topics Noise Water Resources (Surface and Groundwater)
Ecological Resources (Terrestrial and Aquatic)
Historic and Cultural Resources Socioeconomics
6 Human Health Waste Management Spent Nuclear Fuel Greenhouse Gas and Climate Change Information Needs and Document Requests Information needs and document requests are identified below by topic.
General (All)
The following requests are generic to more than one environmental resource area. Issues applicable to these questions are provided below along with the responsible NRC and PNNL subject matter expert, as appropriate.
GEN-1 Please provide any relevant updates to table 9.1-1 in the Environmental Report. If any authorizations have expired since Duke Energy Progress, LLC (Dukes) Application for Subsequent Renewed Operating License, dated April 1, 2025 (Agencywide Documents Access and Management System Accession No. ML25091A290), please provide the status of those permits and/or renewals.
GEN-2 Please provide documentation of Duke Energys new and significant information review and results identified in Section 5 of the environmental report (ER) that supports the finding that no new and significant information was identified for Category 1 issues regarding the environmental impacts of the Subsequent License Renewal (SLR) associated with Robinson.
Topic-specific The following requests are specific to a single environmental review area. If a topic is not provided below, the discussions held in response to the generic requests above are expected to fully cover that topic.
Replacement Power Alternatives (Peyton Doub, NRC)
Audit Needs None Anticipated.
Document Needs None Anticipated.
Land Use and Visual Resources (Caroline Hsu, NRC)
Audit Needs None Anticipated Document Needs None Anticipated
7 Air Quality (Bradley Werling, NRC)
Audit Needs None Anticipated.
Document Needs None Anticipated.
Noise (Nancy Martinez, NRC)
Audit Needs NOI-1 Section 3.4 of the ER identifies that intermittent noise is produced at H. B. Robinson Steam Electric Plant, Unit 2 (RNP) from the security training facility range. Provide the distance between the security training facility and 1) the nearest noise sensitive receptor and 2) the nearest site boundary.
NOI-2 If Duke Energy conducted offsite noise surveys in the vicinity of Robinson, please provide a copy.
NOI-3 Has Duke Energy received any notices of violation or non-compliance with respect to the noise ordinance from Darlington County.
NOI-4 Section 3.4 of the ER states that noise complaints were received from the public from 2019 through 2023. Please provide the following information:
1.
has Duke Energy received any noise complaints since 2023?
2.
with respect to complaints of unexplained noise from the plant for which the source of the noise was never determined: clarify if the complaint was from one or multiple complainants and/or instances; describe the unexplained noise from the plant as provided by the complainant(s); and what specific actions were taken to identify the noise source.
3.
with respect to complaints of noise emitted from siren testing, clarify if the complaint was from one or multiple complainants and/or instances. Does Duke Energy inform the public of siren testing prior to the testing being conducted?
NOI-5 Does Duke Energy have procedures in place for the handling of noise complaints? If so, please provide a copy.
Document Needs None Anticipated.
Geologic Environment (Gerry Stirewalt, NRC)
Audit Needs None anticipated.
Document Needs None anticipated.
8 Water Resources - Surface Water (Lloyd Desotell, NRC)
Audit Needs SW-1 ER Section 4.1.1.4 discusses surface water consumption stating: As a once-through cooling system, water consumption at RNP for cooling purposes is estimated at approximately 2 percent of surface water withdrawals. This section also discusses calculated forced evaporation rates of 3.6 - 7.5 million gallons per day due to once-through thermal discharge. Please discuss how these values relate to each other.
SW-2 Since the ER was written, has RNP received any notices of violation or non-compliances associated with wastewater discharges to receiving surface waters? If so, please provide a description of the violation and associated corrective actions.
SW-3 Over the last 5 years, has RNP reduced power to meet thermal discharge limits? If so, please briefly summarize these instances.
SW-4 Please provide a knowledgeable person to provide an overview of the Operational and Contingency Plan (OCP) for surface water withdrawals referenced in ER Section 3.6.3.1. The overview should include origins of the plan, conditions that trigger the plan, mitigation/conservation measures employed, applicable reporting requirements and a summary of past plan implementation, if any.
Document Needs SW-5 National Pollution Discharge Elimination System (NPDES) General Stormwater Permit Number-SCR000000 SW-6 Any correspondence between Duke and South Carolina Department of Environmental Services (SCDES) regarding NPDES violations and exceedances over the last 5 years SW-7 Impact of Tritium Release from Lake Robinson at the Robinson Nuclear Plant for 2023 cited in the 2023 Annual Radioactive Effluent Release Report.
SW-8 Discharge Monitoring Reports for the last 5 years SW-9 RNP Stormwater Pollution Prevention Plan SW-10 RNP Spill Prevention, Control, and Countermeasure plan Water Resources - Groundwater Resources (Gerry Stirewalt, NRC; Phil Meyer, PNNL)
Audit Needs GW-1 Provide an SME at the audit to describe the evidence for a lack of hydraulic connection between surface water bodies and shallow wells as stated in ER 3.6.2.1 and 3.6.2.3.
Campbell (2014), referenced in the ER, has a conceptual model of groundwater flow in which precipitation recharges the Crouch Branch aquifer at the land surface and the Crouch Branch aquifer discharges water to springs, streams, river, and wells. Is this hydraulic connection believed to be lacking at the RNP site?
GW-2 ER 3.6.2.3 describes sheet piling installed to stabilize the shoreline around the intake structure and states that this may locally block the hydraulic connection between the lake and the shallow groundwater. Show the location of the sheet piling and provide the depth of the sheet piling, as installed.
GW-3 ER figure 3.6-7 shows a groundwater elevation of 230.28 ft main sea level (MSL) at two different wells each designated as MW-7. These wells are distinguished in ER table
9 3.6-3 as MW-7 monitoring the ash pond and MW-07, presumably located near the discharge. ER table 3.6-3 states that well MW-07 is screened from 211.4 to 221.4 ft MSL with the top of casing at 224.4 ft MSL. What is the ground surface elevation at the location of MW-07 and what was the measured groundwater elevation in this well during July 27-29, 2020?
GW-4 Provide a list of the groundwater pollution index monitoring wells with the purpose of each well indicated (e.g., background, sentinel, perimeter, etc.).
GW-5 ER 3.6.2.3 states that when Wells A, B, or C are individually pumped at 90 gpm, the potentiometric surface within the Middendorf Formation (McQueen Branch aquifer) drops below 200 ft MSL around each well, which is below the water table elevation in the recent alluvium (surficial aquifer). The ER states that this relationship results in pumping-induced downward flow gradients and groundwater migration between the aquifers. What percentage of time does this pumping condition occur (e.g., during the last five years)?
GW-6 Are the groundwater withdrawal values shown in ER table 3.6-6a available for 2024? If so, please provide them.
GW-7 ER figure. 2.2-1, Water Balance Flow Diagram, shows a groundwater source to the Units 1 and 2 Retention Ponds. Is this groundwater inflow to unlined ponds? Are these Retention Ponds the same as the Settling Ponds shown in ER figure. 3.1-1?
GW-8 Provide information on tritium activities over time as observed in on-site monitoring wells.
GW-9 Provide information on tritium levels in the lake, including how the level has changed over time.
GW-10 Confirm that there have been no nonradiological releases impacting soil or groundwater from 2024 to the present.
GW-11 Confirm that there have been no leaks or spills at RNP that have resulted in the detection of tritium in groundwater at 20,000 pCi/L or higher during Unit 2 operations.
GW-12 Confirm that there have been no unplanned radionuclide releases impacting soil or groundwater from 2024 to present.
Document Needs GW-13 Provide for inspection the site procedures implementing the Groundwater Protection Program at RNP, including the two most recent reports updating the Site Conceptual Model.
Terrestrial Resources (Shannon Healy, NRC)
Audit Needs TER-1 ER Section 4.2.2 states that water levels of Lake Robinson fluctuate minimally and typically are maintained between 220.7 and 221.5 feet above MSL with a minimum water level of 218 feet above MSL. Please provide more information regarding the management of the water levels in Lake Robinson, including:
a.
a description of how the discharge rate through the dam is controlled; b.
a description of whether the fluctuations in lake level reflects the natural seasonality of water levels within Black Creek;
10 c.
a description of the potential effects water level fluctuation may have on riparian wetlands upstream and downstream of the impoundment; and d.
how the dam discharge is managed during low flows and whether there is a minimum required discharge over the Lake Robinson dam.
TER-2 ER Section 9.4.22 states that the meteorological (MET) tower on site is the tallest structure on site and is appropriately marked/lighted. Please describe the lighting regime (color of light, steady or blinking) for the MET tower and any other structures onsite that are greater than 100 feet tall. Additionally, please specify whether the MET tower is freestanding or guyed.
TER-3 Please provide details regarding where herbicides and pesticides are used on site as well as the method, location, purpose, and frequency of application.
TER-4 Please provide details regarding the location, frequency, and purpose of land management practices on side including mowing, planting, hand-cutting, tree clearing, prescribed fire, and pine straw harvesting. Please specify whether these activities are connected to the proposed SLR and describe the connection, if applicable.
TER-5 Please provide information regarding the anticipated location and acreage of the clearing associated with the Robinson Solar Farm as well as the expected timeframe for this project.
TER-6 Section 3.7.1.2.4. of the ER states that there have been no reported avian incidents at RNP from 2019 through 2024. Please specify whether there have been any reported avian incidents from 2015 through 2019 and whether there have been any reported avian incidents since time the ER was prepared. If so, provide the following, if available: (1) a summary of bird mortalities or injuries (species, date, cause if known, associated structures or buildings, if any) in chronological order; and (2) detailed reports for each incident, if any.
Document Needs TER-7 Federal Migratory Bird Special Purpose Utility Permit (no. MB000257)
TER-8 South Carolina Department of Natural Resources Migratory Bird Permit (No. MB-4-24)
TER-9 Report from the 2015 Natural Resources Investigation TER-10 Report from the 2023 Duke Robinson Solar Project Wetland Delineation TER-11 Provide Procedures:
(1) avian protection procedure; (2) vegetation management program; (3) pesticide discharge management plan; (4) pesticide compliance procedure; (5) integrated vegetation management program; (6) natural resource management program; (7) wetlands - dredge and fill procedure; (8) Duke procedures for land-disturbing activities; and (9) storm water pollution prevention plan (see SW-9).
11 Aquatic Resources (Mitchell Dehmer, NRC)
Audit Needs AQU-1 ER Section 3.7.2.2.2 states that there have been no fish kills at RNP in the last 10 years. Please clarify if there has or has not been fish kills within the last license renewal term.
AQU-2 ER Section 3.7.2.2.1 discusses thermal stratification in Lake Robinson. Please quantify the amount of stratification occurring near the intake, discharge, and at the mid-lake sites.
AQU-3 ER Section 4.2.4.4 states that thermal effluent restricts growth of aquatic plants along eastern shores opposite of the discharge canal and in the cove north of the discharge canal. Additionally, the ER states that these areas have habitat characteristics that normally support aquatic plant growth. Please specify these habitat characteristics and how continued operation effects the ability of aquatic plants to grow in these suitable areas.
AQU-4 ER Section 4.2.4.4. discusses that apparent seasonal movements and distribution of fish has occurred as a result of increased water temperatures. Please further explain this finding to include the species of fish affected, time of year, and any other ecologically relevant information.
AQU-5 ER Section 4.2.4.4 discusses that historical studies have indicated that minor fish species were temporarily reduced in numbers near the discharge during summer months. Please elaborate and include the species affected.
AQU-6 ER Section 4.2.3.4 discusses impingement and entrainment impacts on centrarchids. It is also stated that centrarchid spawning habitat is impacted. Please describe how the spawning habitat is impacted.
AQU-7 NPDES Permit No. SC0002925 states that Lake Robinson drawdown shall be limited to a maximum of 2 feet below the normal pool elevation (220 feet). Has this scenario ever occurred? If so, did Duke notify SCDES regarding the drawdown?
AQU-8 At the Lake Robinson Dam, managed by Duke, are fish able to pass downstream, or are they confined to the Lake? Please explain the purpose of the fish return being located downstream rather than back into Lake Robinson.
Document Needs AQU-9 Provide a copy for the NRC staff review of the following documents and studies:
a.
2006 Impingement Monitoring Study as described in ER Section 3.7.2.3.3.
b.
2016-2017 Entrainment Characterization Study as described in ER Section 3.7.2.3.4.
c.
2016-2019 Environmental Aquatic Monitoring Program Studies as described in ER Section 3.7.2.2.3.
d.
2022 Clean Water Act (CWA) 316(b) submittal for NPDES Permit No. SC0002925.
e.
Most recent CWA 316(a) demonstration report.
f.
Last three years of annual monitoring studies performed by Duke Energy Environmental Services Water Resource Team for Lake Robinson, if applicable.
g.
Current Surface Water Withdrawal Permit No. 16PN001.
12 h.
OCP for surface water withdrawals as described in ER Section 3.6.3.1.
Federally Protected Ecological (FPE) Resources (Shannon Healy, NRC; Duke, Non-Federal Representative(NFR))
Audit Needs N/A; Duke as the designated NFR is responsible for any FPE information needs.
Document Needs N/A; Duke as the designated NFR is responsible for any FPE document needs.
Historic and Cultural Resources (Beau Goldstein, NRC)
Audit Needs HCR-1 Provide a map, associated with table 3.8-1, which shows what areas of the RNP have been previously subject to archaeological or cultural resources survey (ER Section 3.8.6).
HCR-2 Provide additional historical and contextual information on the historic farmstead and cemetery (ER Section 3.8.3). In addition, indicate whether physical remains of these properties have been identified during construction or operation of the facility. And if so, describe how such discoveries were handled.
HCR-3 Provide any historic and cultural resources related correspondence with State Historic Preservation Office (SHPO), Tribes, or other parties, that has been sent or received since the date of ER submittal to NRC.
Document Needs HCR-4 Provide procedures 9.2 and 9.6 (ER Section 3.8.6).
HCR-5 Provide the architectural survey submitted to SHPO in March 2025 and any related correspondence (ER Section 3.8.5).
HCR-6 Provide copies of any archaeological or cultural resources surveys conducted within the boundaries of the RNP, such as for the solar project (ER Section 4.7.4.6).
Socioeconomics (Caroline Hsu, NRC)
Audit Needs SOC-1 Table 3.9-2 in the ER shows Duke Energy Property Tax Payments from 2019-2023.
Please provide a column for the table showing Duke Energy Property Tax Payments in 2024 and 2025 (if 2025 information is available). Included information should be the same as in table 3.9-2 as follows:
Tax Jurisdictions 2024 2025 Total Property Tax Paid by Duke Energy Darlington County Total Revenue Property Tax as a % of Darlington County Total Revenues
13 Portion of Duke Energy Total Property Tax Appropriated to D1SD Total D1SD Revenue Property Tax as a % of D1SD Total Revenues SOC-2 Table 3.9-3 in the ER shows emergency preparedness payments on behalf of RNP from 2019-2023. Please provide the same information for 2024 and 2025 (if available).
Document Needs None Anticipated.
Human Health (Rao Tammara, NRC)
Audit Needs HH-1 Please provide any updates concerning waterborne diseases in the vicinity of the plant since the submission of the subsequent license renewal environmental report, including any updates from Centers for Disease Controls National Outbreak Reporting System Dashboard. In ER Section 4.4.1.4 it is stated that SCDES is consulted (correspondence enclosed in Attachment D) with regards to concerns about any waterborne disease associated with RNPs thermal discharge. Please provide any response received from SCDES.
HH-2 In ER Sections 3.10.2 and 4.4.2.4 it is stated that in-scope transmission lines are within area that meet (NESC) definition of an electrical supply station, but not clear about meeting the NESC clearance standard and milliamperes threshold criteria. Please clarify and confirm. Also, it is stated that work is conducted under electrical safety procedures and safety guidance. Please confirm.
Document Needs HH-3 Please provide room copies of the fleet electrical safety procedures, pertaining to Electric Shock Hazards.
Waste Management (Rao Tammara, NRC)
Audit Needs WM-1 As part of the effluent control systems, plan to discuss how the plant processes radioactive effluents to maintain radiation doses to the public to levels that are as low as reasonably achievable. Are there any proposed changes or upgrades to the program being considered during the license renewal term?
WM-2 Section 2.2.5 did not address any mixed waste. Any mixed waste stored in this location? What are the plans and procedures associated with the storage of mixed waste?
WM-3 Section 2.2.5.3 discusses the Solid Waste Management Systems. Are there any proposed changes or upgrades to the program being considered during the license renewal term?
14 WM-4 In Section 9.3 of the ER, it is stated that for the period of 2020-2024, there were two reportable releases of which one Notice of Violation was issued on May 29, 2004, and SCDES received communication from Duke Energy about the event and corrective actions, have there been any other reportable releases since the ER was written that triggered the notification requirement.
WM-5 If there have been any reportable unplanned releases of radioactive materials (unplanned/inadvertent radioactive liquid or gaseous releases) which would trigger a notification requirement since the ER was written, please provide a description of the releases. Please be prepared to discuss your plan to handle unplanned releases of radioactive materials.
WM-6 If there have been any reportable inadvertent releases or spills of nonradioactive contaminants which would trigger a notification requirement since the ER was written, please provide a description of spills/releases. Please be prepared to discuss your plan to handle inadvertent nonradioactive releases.
Document Needs:
WM-7 Provide procedures:
(1) Radioactive and Nonradioactive Waste Management Program (2) Waste Minimization Program (3) Stormwater Pollution Prevention Plan (see SW-9).
Spent Nuclear Fuel (Rao Tammara, NRC)
Audit Needs The ER Section 2.2.5.3 states that there are two separate ISFSIs, one designated as 7P-ISFSI having each canister containing seven fuel assemblies, and the second designated as 24P-ISFSI having each canister containing 24 fuel assemblies. Please discuss the storage plans for the spent fuel produced during the license renewal term, including any plans for expansion or additional storage locations necessary for capacity for license renewal term. Please clarify whether the present ISFSI will provide sufficient capacity to store all the spent fuel that is expected to be generated for the lifetime of the plant through the period of extended operation once all the fuel has been removed from the spent fuel pools. If the dry storage capacity should need to be expanded, please indicate whether there is already disturbed land that could be used for the expansion.
Document Needs None Anticipated.
Uranium Fuel Cycle (Rao Tammara, NRC)
Audit Needs None Anticipated.
Document Needs None Anticipated.
15 Termination of Operations and Decommissioning (Rao Tammara, NRC)
Audit Needs None Anticipated.
Document Needs None Anticipated.
Greenhouse Gas and Climate Change (Brian Glowacki, NRC)
Audit Needs GHG-CC-1 ER Section 3.13.2.1 states that intake water temperature data is available from May 2014 through May 2024. This data is presented in plots of annual average monthly intake temperature and average monthly seasonal intake temperature as ER figures 3.13-1 and 3.13-2, respectively. However, ER figures 3.13-1 and 3.13-2 appear to be the same, please resolve this apparent discrepancy.
GHG-CC-2 Has Duke Energy conducted any thermal discharge studies that account for potential increases in water temperature in Lake Robinson due to climate change? If so, please provide a copy for review.
Document Needs None Anticipated.
Postulated Accidents/SAMA (Bill Rautzen and Elijah Dickson, NRC)
Audit Needs None Anticipated.
Document Needs None Anticipated.
16 H. B. Robinson Steam Electric Plant, Unit 2 Environmental Audit Schedule Virtual Audit Tuesday, July 15, 2025 START END ACTIVITY 9:00 am ET 9:30 am ET Entrance meeting between U.S. Nuclear Regulatory Commission (NRC), Duke, and contractors 9:30 am ET 3:00 pm ET Virtual tours/virtual meetings between NRC, Duke, and contractor subject matter experts (SMEs)
Wednesday, July 16, 2025 START END ACTIVITY 9:00 am ET 3:00 pm ET Virtual meetings between NRC, Duke, and contractor SMEs