ML14097A499
| ML14097A499 | |
| Person / Time | |
|---|---|
| Site: | Callaway  |
| Issue date: | 04/07/2014 |
| From: | Kovaleski S Ameren Missouri |
| To: | Document Control Desk, Office of Nuclear Reactor Regulation |
| References | |
| NUREG-1437, ULNRC-06112 | |
| Download: ML14097A499 (10) | |
Text
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WAmeren MISSOURI April 7, 2014 U.S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555-0001 Ladies and Gentlemen:
DOCKET NUMBER 50-483 CALLAWAY PLANT UNIT 1 UNION ELECTRIC CO.
ULNRC-06112 10 CFR 2.101 10 CFR 2.109(b) 10 CFR 50.4 10 CFR 50.30 10 CFR 51.53(c) 10 CFR 54 FACILITY OPERATING LICENSE NPF-30 REVIEW OF THE DRAFT SUPPLEMENT 51 FOR NUREG-1437
References:
- 1) ULNRC-05830 dated December 15, 2011 Callaway Plant
- 2) Notice of Availability ofthe Draft Plant-Specific Supplement 51 to the Generic Environmental Impact Statement for License Renewal of Nuclear Plants Regarding Callaway Plant, Unit 1, dated February 12, 2014 By the Reference 1letter, Union Electric Company (Ameren Missouri) submitted a license renewal application (LRA) for Callaway Plant Unit 1. Reference 2 dated February 12, 2014 transmitted the Notice of Availability of the Draft Plant-Specific Supplement 51 to the Generic Environmental Impact Statement (GElS) for License Renewal of Nuclear Plants Regarding Callaway Plant, Unit 1. The Accession Number for draft Supplement 51 to the GElS is ML14041A373.
PO Box 620 Fulton, MO 65251 AmerenMissouri.com
ULNRC-06112 April 7, 2014 Page 2 We have reviewed the Draft Supplemental Environmental Impact Statement (SEIS) for accuracy and are providing comments (refer to Enclosure 1-Comments on Draft Supplement 51 to NUREG-143 7) for your consideration.
It should be noted that there are no changes to commitments contained within this response.
If you have any questions with regard to this submission, please contact me at (573) 489-9435 or Roger Wink at (314) 225-1561.
Sincerely, J~r~*
Sarah Kovaleski Director, Engineering Design DS/adl
Enclosure:
- 1) Comments on Draft Supplement 51 to NUREG-143 7
ULNRC-06112 April 7, 2014 Page 3 cc:
Mr. Marc L. Dapas Regional Administrator U.S. Nuclear Regulatory Commission Region IV 1600 East Lamar Boulevard Arlington, TX 7 6011-4511 Senior Resident Inspector Callaway Resident Office U.S. Nuclear Regulatory Commission 8201 NRC Road Steedman, MO 65077 Ms. Carmen G. Fells Project Branch I Division of License Renewal Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission Mail Stop 0-IIFI Washington, DC 20555 Mr. John Daily, Senior Project Manager Project Branch 1 Division of License Renewal Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission Mail Stop 0-11F1 Washington, DC 20555 Mr. Fred Lyon Project Manager, Callaway Plant Office of Nuclear Reactor Regulation U. S. Nuclear Regulatory Commission Mail Stop 0-8B 1 Washington, DC 20555-2738 Mr. Gregory A. Pick U.S. Nuclear Regulatory Commission Region IV 1600 East Lamar Boulevard Arlington, TX 76011-4511
ULNRC-06112 April 7, 2014 Page 4 Index and send hardcopy to QA File A160.0761 Hardcopy:
Certrec Corporation 4150 International Plaza Suite 820 Fort Worth, TX 76109 (Certrec receives ALL attachments as long as they are non-safeguards and may be publicly disclosed.)
Electronic distribution for the following can be made via Tech Spec ULNRC Distribution:
F. M. Diya C. 0. Reasoner III D. W. Neterer L. H. Graessle B.L.Cox J. S. Geyer S.M. Maglio T. B. Elwood Corporate Communications NSRB Secretary B. C. Daniels M. A. McLachlan G. S. Kremer S. G. Kovaleski R. C. Wink STARS Regulatory Affairs Mr. John O'Neill (Pillsbury Winthrop Shaw Pittman LLP)
Missouri Public Service Commission Ms. Leanne Tippett-Mosby (DNR)
A. J. Burgess G. P. Gary
ULNRC-06112 April 7, 2014 CALLAWAY PLANT UNIT 1 LICENSE RENEWAL APPLICATION COMMENTS ON DRAFT SUPPLEMENT 51 TO NUREG-1437 Page 1 of 6
ULNRC-06112 April 7, 2014 No.
DSEIS Location Page Line 1
2 3
2-1 30-32 Comment Section General Ameren is in the process of Comment constructing an ISFSI with completion expected in 2015. The water filled excavation that was made for Callaway Unit 2 is being filled in, in preparation of ISFSI construction.
General The Chamois Power Plant ceased Comment operation in September 2013.
2.1 The prior excavation referred to in this section was from initial site construction in the early 1980s.
Page 2 of&
Suggested Resolution There are numerous locations in the report indicating that the existing spent fuel pool will reach capacity by 2020.
Prior to the spent fuel pool reaching capacity the ISFSI facility will be available to store spent fuel assemblies.
Also, there are several locations in the report indicating that the excavation previously completed for Callaway Unit 2 is water filled. This excavation has been drained of standing water and is in process of being filled to facilitate construction of the ISFSI project.
There are numerous references in the report describing the operation of the Chamois power plant.
Since it has ceased operation consider whether the report needs to reflect this change.
Consider revising this sentence to clarify that the prior excavation was from initial construction.
ULNRC-06112 April 7, 2014 4
2-8 5
2-9 28 1-4 6
2-18 30 7
2-18 42-46 2.1.2.1 2.1.2.2 2.1.6.1 2.1.6.1 Callaway does not use reverse osmosis as a treatment method for liquid radioactive waste.
Line 1-4 states "Offgases from the main condenser are the major source of gaseous radioactive waste. Other radioactive gas sources collected by the system include leakage from steam piping and equipment in the reactor building, turbine generator building, and radioactive waste building." This is not correct. In fact, the major source of gaseous radioactive waste is purging of the volume control tank and discharge of tank vents and other equipment in the containment, radioactive waste, and auxiliary buildings.
A statement is made that most of the water in the circulating system is lost to the atmosphere, this is misleading as only about 1% is lost through evaporation.
Should state the water flowing down the discharge pipeline and discharged to the Missouri River has a maximum temperature near 90°F. Cooling tower blowdown temperatures (Outfall 002} vary with season and range from about 60-90°F. The current NPDES Permit does not contain an upper temperature limit or stipulate that the discharge must not cause the temperature of the mixing zone (or the area where the discharge water meets and mixes with the river} to increase by more than 5°F (2.8°C}.
Page 3 of6 Remove reference to reverse osmosis.
Revise paragraph to state "The major source of gaseous radioactive waste is purging of the volume control tank and discharge of tank vents and other equipment in the containment, radioactive waste, and auxiliary buildings."
Consider deletion or revising as follows:
"Although small in comparison to the total volume of water in the circulating water system, the largest loss is to the atmosphere."
Revise the paragraph as follows: "The temperature of the water flowing down the blowdown pipeline and discharged to the Missouri River l:JSl:Jally has a maximum temperature of approximately 90 oF (32 oc} (Ameren 2011d}. +t:te NPQES peFmit feF (;allatlfay estat31ist:tes tt:le l:IJJJJeF limit ef alle~¥at31e tempeFatl:JFe impaets t3tt (;allatl*'ay eR tt:le Missel:JFi RitfeF. It
ULNRC-06112 April 7, 2014 8
2-19 32,33 9
2-21 10,11 10 2-33 14 11 2-68 Table 2-16 12 4-44 18-29 2.1.7.1 2.1.7.2 4.12.3.1 Incorrectly estimates the volume of water returned to the river. Over the past three years the volume of water returned to the river has averaged near 4400 gpm with the losses to evaporation near 11,000 gpm.
Therefore, approximately 25% of the water withdrawn is returned to the river.
The unit 2 prior excavation hole is in the process of being filled in and will be completely filled in by 2015. The GWS pump is used to dewater the structural fill area underlying the power block.
Concerning the 401 Water Quality Certification, Ameren did receive a response letter from the Missouri DNR (dated October 8, 2013} stating that the department considers the permit to provide appropriate environmental protection under the Missouri Clean Water Law and compliance with the Clean Water Act.
Number of Callaway employees does not match what is listed on page 2-57 The Chamois Power Plant ceased operation in September 2013 and is no longer a cumulative effect on the aquatic resources.
Page 4 of 6 stif:)l:llates tt=lat tt:te diset:taFge ml:lst Ret eal:lse tt:te temf:)eFatl:IFe of Ute mi)(iAg zeAe (oF tt:te aFea wt:teFe Ute diset:taFged *JJateF meets a Ad mhEes witt:.
tt:te FiYeF} to iAeFease lJ*; moFe tt:taA §oF (~.8 0 G} (MQNR ~Q1Qa}."
Suggest revising paragraph to state that approximately 25% of the water withdrawn is returned to the river.
Consider revising this text to match page 2-37 lines 17 & 18.
Consider revising.
Consider reconciling the two numbers.
Recommend removing reference to the Chamois Power plant or revising to state that it no longer impacts the aquatic resources.
ULNRC-06112 April 7, 2014 13 4-45 14 5-4 15 8-26 16 F-10 17 F-18 29 4.12.3.5 17 5.3.2 33 8.2.9 8
11 The sentence appears to be misleading. Sentence inappropriately implies that the "license renewal" contributes to the "LARGE" cumulative impact when in fact other major factors outside of existing or future operation of Callaway result in this impact.
The fire PRA CDF number has been reduced from 2.0E-5 to 1.68E-5 since the original LAR was submitted.
The Missouri-Kansas-Texas Railroad in central Missouri is now a state hiking trail (Katy Trail State Park),
with no rails remaining. The Callaway rail spur could not be reconstructed to provide rail access.
The stated CDF of 7.6x10E-6 has an incorrect exponent Safety related water system is incorrectly listed as emergency service water Page 5 of&
Consider revising the text as follows:
"Because of the noticeable destabilization of aquatic resources within the Lower Missouri River as a result of USACE intervention with reservoir construction and channel stabilization, independent of Callaway's existing or future operation, the NRC staff concludes that the cumulative effects have the potential to be LARGE."
The current fire CDF is 1.68x10-5* Given that the fire CDF has been reduced since the original LAR, no SAMAs have become more cost-beneficial and therefore changes to the SAMA analysis performed for this application are not needed.
Consider removing the discussion of the rail spur to the Callaway site.
Correct to state a CDF of 7.6x10E-5.
Change to essential service water.
ULNRC-06112 April 7, 2014 18 H-6 19 H-6 20 H-6 21 H-9 4
Appendix H 13,14 Appendix H 15 Appendix H H.4.3.2 Page 6 of&
Two additional sedimentation ponds are currently being designed with installation planned during 2015 as the existing treatment lagoons are approaching capacity.
The current NPDES Permit does not Consider removing contain a temperature limitation for this sentence.
discharge such that the discharge must not cause the temperature of the mixing zone (or the area where the discharged water meets and mixes with the river} to increase by more than 5°F (3°C}. Temperature is required to be monitored.
The statement in the Draft SEIS that Consider revising the 11AII plant outfalls except one connect section to state:
into a single pipeline... " is not 11NPDES outfalls 001, completely accurate.
002,003,007,009, and 016 all connect to a single discharge pipeline that discharges to the Missouri River. Storm water outfalls 010, 011, 012, 014, and 015 each flow to separate area creeks. Note that outfall 009 has never been used...
This section fails to acknowledge the Consider revising.
buoyancy and strong photopositive response of pallid larval as mentioned in Section H.4.1 in contrast to the water intake opening of the Callaway intake that may preclude larval impingement and/or entrainment. Emphasis should also be added to note relative small component of river water extracted due to minimal amount of water required by a cooling tower verses a once through cooling water system, i.e., mitigating factor/impacts.