ML21134A061
| ML21134A061 | |
| Person / Time | |
|---|---|
| Site: | Point Beach  |
| Issue date: | 05/14/2021 |
| From: | NRC/NMSS/DREFS/ELRB |
| To: | Point Beach |
| Clark, P.M, NMSS/REFS/ELRB, 301-415-6447 | |
| Shared Package | |
| ML21134A048 | List: |
| References | |
| EPID L-2020-SLE-0002 | |
| Download: ML21134A061 (13) | |
Text
POINT BEACH NUCLEAR PLANT, UNITS 1 AND 2 SUBSEQUENT LICENSE RENEWAL APPLICATION REQUESTS FOR CONFIRMATION OF INFORMATION (RCI)
ENVIRONMENTAL REVIEW Regulatory Basis:
License renewal requirements are specified in Title 10 of the Code of Federal Regulations (10CFR) Part54, Requirements for Renewal of Operating Licenses for Nuclear Power Plants. Licensees are required by 10CFR 54.23 to submit an Environmental Report (ER) that complies with the applicable requirements in 10CFR Part51, Environmental Protection Regulations for Domestic Licensing and Related Regulatory Functions, as part of the License Renewal Application. The Nuclear Regulatory Commissions (NRC) regulations at 10 CFR Part 51, which implement Section 102(2) of the National Environmental Policy Act of 1969, as amended (NEPA), include requirements for applicants to provide information as may be useful in aiding the NRC staff in complying with NEPA. As part of its review, theNRC staff is required to prepare a site-specific Supplemental Environmental Impact Statement (SEIS) to NUREG-1437, Generic Environmental Impact Statement for License Renewal of Nuclear Plants. 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.
Request for Confirmation of Information:
During the environmental audit, the NRC staff reviewed documents that were made available on the applicants electronic information portal in response to the staff audit needs (Agencywide Documents Access and Management System (ADAMS) Accession No. ML21005A058). The staff also participated in breakout sessions for each resource area with applicant personnel to gather information that will likely be used in the SEIS. To the best of the staffs knowledge, this information on the applicants electronic information portal and discussed in breakout sessions is not currently on the docket or publicly accessible. The NRC staff requests that the applicant submits confirmation that the information gathered from the audit and listed below is correct or provides the associated corrected information.
Alternatives (Info Need ALT-1):
Based on the NRC staffs review of Section 7.2.2.2.1 and 7.3 of the ER and information discussed during the environmental audit session pertaining to alternatives for providing replacement power and alternatives for mitigating impacts, please confirm:
- 1) NextEras reason for ultimately eliminating onshore wind power as a reasonable component of a combination alternative, as determined by an intensive review involving FPL generation experts, is based on the relatively greater acreage requirements associated with wind power, coupled with NextEras anticipated difficulty in acquiring sufficient land for build-out and setback requirements to support such an alternative.
- 2) NextEras renewal application for Wisconsin Pollutant Discharge Elimination System (WPDES) individual permit #WI-0000957-08-0 provides the best available information regarding the feasibility of deploying closed-cycle cooling at Point Beach.
Land Use and Visual Resources (Info Need LU-1):
Based on the NRC staffs review of Section 3.2.1 of the ER and information received during the environmental audit pertaining to Point Beach onsite agricultural leases, please confirm:
NextEra has leased out 356.5 acres of land within Point Beach site boundaries in four agricultural leases.
(Info Need LU-3):
Based on the NRC staffs review of Section 3.1.4 and Section 4.1.1.3 of the ER and information received during the environmental audit pertaining to the ISFSI-defined area, please confirm:
That should ISFSI expansion be necessary during the SLR term, there will be adequate Point Beach onsite land for expansion.
Further, please confirm as stated in the Audit Follow Up Actions table that the land use/land cover of the ISFSI-defined area is Developed, Low Intensity; Developed, Medium Intensity; Developed, High Intensity; Cultivated Crops; Pasture/Hay.
Lastly, please confirm as stated in the Audit Follow Up Actions table that the existing ISFSI-defined area is 12.4 acres.
(Info Need LU-8):
Based on the NRC staffs review of Section 3.2.1 of the ER and information received during the environmental audit pertaining to the solar array fence line, please confirm:
215 acres on the Point Beach site will be enclosed within the solar array fence line.
Air Quality and Noise (Info Need AQN-2a):
Table 3.3-11 of the ER presents Point Beach annual greenhouse gas (GHG) emissions for the 2014-2018 period of record. During the environmental audit, the NRC staff reviewed Point Beachs annual summary reports submitted to the Wisconsin Department of Natural Resources.
Based on annual fuel usage from these reports, the NRC staff identified and discussed with NextEra staff that the GHG emissions presented in Table 3.3-11 were transposed. During the audit, NextEra stated that the values in Table 3.3-11 between 2014 and 2018 and between
2015 and 2017 are transposed, but the values presented in the Table for 2016 are correct.
Confirm that the following values in Table 3.3-11 of the ER are transposed: 2014 and 2018 and 2015 and 2017.
(Info Need AQN-4):
Section 3.4 of the ER states that NextEra has not received noise complaints related to Point Beach plant operations between 2014-2018. During the environmental audit, Air Quality and Noise breakout session, and in response to information need AQN-4, NextEra stated that there have been no noise complaints related to Point Beach plant operations since 2019. Confirm that Point Beach has not received noise complaints as a result of Point Beach plant operations since 2014-2018.
Water Resources - Groundwater (Info Need GW-3b):
During the audit, the NRC staff discussed with NextEra the statement in ER Section 4.12.4.5 that It is not anticipated that groundwater withdrawal increases above the reported quantities will be required during the proposed SLR operating term. Please confirm:
There are no foreseeable conditions or situations under which total onsite groundwater withdrawal increases above 100 gpm during the SLR term.
(Info Need GW-5):
During the audit, the NRC staff discussed with NextEra the statement in ER Section 3.6.3.2 that There are currently no discharges to groundwater from PBN requiring permits by regulatory agencies. Please confirm:
Discharges to groundwater from Point Beach requiring permits by regulatory agencies are not expected to occur during the SLR term.
Water Resources - Surface Water (Info Need SW-1):
Based on the NRC staffs review of Table 9.1-1 of the ER and information reviewed during the environmental audit pertaining to stormwater discharges, please confirm:
NextEra will be renewing Point Beachs General WPDES industrial stormwater discharge permit when it expires on 5/31/2021 and that NextEra has received written correspondence from the Wisconsin Department of Natural Resources (WDNR) (dated 8/27/2020) that WDNR will automatically renew the permit.
(Info Need SW-3):
Based on the NRC staffs review of Section 2.2.3 et seq. of the ER and information reviewed during the environmental audit regarding the capacities of water supply pumps composing Point Beachs cooling and auxiliary water systems, please confirm:
4 circulating water pumps (2 servicing each nuclear unit) are each rated at 178,000 gallons per minute (gpm) 6 service water pumps, each rated at 5,320 gpm, supply water to the dual, common loop piped system for both units (with 3 service water pumps normally providing maximum demand for both units and the remaining 3 pumps in standby status) 2 screen wash pumps, each rated at 1,100 gpm, supply water to remove debris from the traveling screens.
(Info Need SW-4):
Based on the NRC staffs review of Sections 3.6.1.2.5 and 9.3 of the ER and information reviewed during the environmental audit regarding Point Beachs status of compliance, confirm the following:
A. NextEra has received no Notices of Violation, nonconformance notifications, or related infractions from regulatory agencies associated with effluent discharges; sanitary sewage systems; groundwater or soil contamination; as well as any involving spills, leaks, and other inadvertent releases (e.g., petroleum products, chemicals, or radionuclides) since the ER was written (2019).
B. NextEra self-reported four (4) WPDES permit non-compliances to the WDNR via phone and Discharge Monitoring Report submittal in 2020 including: (1) total residual halogen (TRH) concentration of 0.06 ppm in the Unit 2 cooling outfall (dated 03/11/2020); (2) TRH concentration of 0.15 ppm in the Unit 2 cooling outfall (dated 03/21/2020); (3) daily maximum total suspended solids (TSS) concentration of 114.9 mg/L in the Wastewater Effluent at internal sampling point 105 (dated 12/22/2020); and (4) monthly average TSS concentration in the Wastewater Effluent of 34 mg/L at sampling point 105 (dated December 2020).
Terrestrial Resources (Info Need TER-4):
Based on the NRC staffs review of Section 3.7.7.1.3 in the ER and information received during the environmental audit pertaining to eagles in the vicinity of Point Beach, please confirm:
The eagles referred to in the ER as nesting within the vicinity of Point Beach are bald eagles. Also, as stated during the environmental audit, please confirm that NextEra has no record of bald or golden eagle individuals, nests, or eggs found on the Point Beach site.
(Info Need TER-5):
Based on the NRC staffs review of Section 3.0 and Section 3.1.4 of the ER and information received during the environmental audit pertaining to terrestrial ecology management of Point Beach land leased to solar power facilities, please confirm:
For the Point Beach onsite land leased to the two solar facilities, the terrestrial ecology management functions (e.g., herbicide application, wildlife management, compliance with laws such as Migratory Bird Treaty Act and Bald and Golden Eagle Protection Act) will be undertaken by the operators of each solar site.
(Info Need TER-9):
Based on the NRC staffs review of Section 3.2.1 of the ER and information received during the environmental audit on the solar array fence line, please confirm:
The Two Creeks Solar and Point Beach Solar facilities are fenced off in sections, rather than one contiguous area, allowing for corridors throughout the area to allow movement of wildlife. As such, the solar array fence is not anticipated to interrupt possible species travel corridors.
Aquatic Resources NONE Special Species and Habitats (Info Need SSH-1):
During the initial license renewal review, NextEra developed a piping plover monitoring framework in coordination with the NRC and the U.S. Fish and Wildlife Service (FWS). The framework is memorialized in an April 21, 2005, letter from the NRC to the FWS (ADAMS Accession No. ML051110687). Since that time, NextEra has also incorporated this framework into site procedure NP 3.4.0, Environmental Programs. In connection with fulfillment of this framework, please confirm the following information.
Since 2005, NextEra has conducted annual piping plover breeding censuses in June of each year. NextEra has observed no piping plovers or nests during these censuses.
NextEra has not otherwise observed piping plovers on the Point Beach site during any other time of the year.
Based on the past sixteen years of census data (2005-2020), the suitable piping plover nesting habitat on the Point Beach site may be characterized as follows:
Shoreline habitat consists of sand beach, dunes, and gravel shore. Tides, erosion, and deposition affect the quantity of exposed shoreline that would be available for piping plover nesting, foraging, and other uses. Over the period 2015-2020, exposed shoreline habitat has varied from approximately 0.4-2.4 mi (0.6-3.9 km) in length and 20-82 ft (6-25 m) in width.
In 2005, NextEra committed to implementing the piping plover monitoring framework during the term of the initial license renewal (i.e., through 2033). However, NextEra currently has no plans to continue implementing this framework beyond 2033.
Historic and Cultural Resources NONE Human Health NONE Microbiological Hazards NONE Postulated Accidents NONE Waste Management (Info Need WM-1):
Based on the NRC staffs review of Section 3.6.4.2.1 of the ER, between 2015 and 2019, there have been no inadvertent radioactive liquid or gaseous releases. Please confirm: There have not been any reportable unplanned releases of radioactive materials that would trigger a notification requirement since the ER was written.
(Info Need WM-2):
Based on the NRC staffs review of Section 3.6.4.2.2 of the ER and information discussed during the environmental audit session, there was one reportable inadvertent nonradioactive release that would be classified as an incidental spill occurring between 2015 and 2019. As such, there has been one reportable spill since the ER was written. On January 19, 2021, WDNR was notified of a fuel release that occurred on January 18, 2021 (incident number 04 587180 BLATTNER ENERGY SPILL). Approximately eight gallons of diesel fuel was released as a result of a hose failure on a pickup truck. The area affected was approximately 50-ft by 15-ft and located within the portion of the Point Beach Solar facility that is located on the PBN property. The ground was frozen at the time, limiting the penetration of fuel into the affected soil to a depth of no more than a few inches. The contaminated soil, including soil that was stained or visually impacted, was immediately excavated to the extent practicable and temporarily stored in a containment for disposal. Approximately five tons of soil was hauled by Waste Management to their Ridgeview landfill facility for disposal. The incident was closed by WDNR on February 11, 2021. The record of this incident, including the disposal manifest, is available at WDNR Bureau for Remediation and Redevelopment Tracking System (BRRTS) on the Web (BOTW) at: <https://dnr.wi.gov/botw/GetActivityDetail.do?adn=0436587180&crumb=0>. Please confirm the January 19, 2021 spill is the only reportable spill that has occurred since the ER was written.
(Info Need WM-3):
Based on the NRC staffs review of Section 9.5.3.6 of the ER, between 2015 and 2019, there have been no reportable oil spills. Point Beach is subject to the reporting provision of 40 CFR Part 110 as it relates to the discharge of oil in such quantities as may be harmful pursuant to Section 311(b)(4) of the Federal Water Pollution Control Act. This reporting provision requires that any discharges of oil in such quantities that may be harmful to the public health or welfare or the environment must be reported to the U.S. Environmental Protection Agencys National Response Center. Therefore, please confirm: There have not been any reportable discharges that would trigger this notification requirement since the ER was written.
(Info Need WM-4):
Based on the NRC staffs review of Section 9.5.13.5 of the ER, between 2015 and 2019, there have been no reportable releases of a regulated substance from an underground storage tank containing a hazardous substance. Point Beach is subject to the reporting provisions of Wisconsin Administrative Code NR 706.11 as it relates to discovering the release of a regulated substance from an underground storage tank containing a hazardous substance. Any such events must be reported to the WDNR. Please confirm: There have not been any reportable releases at Point Beach that have triggered this notification requirement since the ER was written.
Cumulative Impacts (Info Need CI-1):
Based on the NRC staffs review of Section 4.12 of the ER and information discussed during the environmental audit session pertaining to cumulative impacts, please confirm that no additional
past, present, or reasonably foreseeable future projects or actions have been identified since the ER was prepared.
(Info Need CI-2):
Based on the NRC staffs review of Sections 4.12 and 7.2.2.2.2 of the ER and information discussed during the environmental audit session pertaining to cumulative impacts, the staff noted that several different acreage values have been used to characterize the Point Beach Solar Facility:
ER Section 7.2.2.2.2 states that The Point Beach solar PV facility, a facility without energy storage, is approximately 565 acres.
Information on the portal (Audit Question & Response for CI-2) indicates that Approximately 920 acres of the [Point Beach Solar] facility are located within the PBN site boundary.
Other information on the portal (Audit Question & Responses for LU-8 and LU-8a) indicates that the area within the Point Beach Solar Array Fence Line is approximately 215 acres.
Please confirm which of these values best characterizes the general acreage requirement associated with the Point Beach Solar Facility.
POINT BEACH NUCLEAR PLANT, UNITS 1 AND 2 SUBSEQUENT LICENSE RENEWAL APPLICATION REQUESTS FOR ADDITIONAL INFORMATION (RAI)
ENVIRONMENTAL REVIEW Alternatives Requirement:
10 CFR 51.53(c)(2) requires that applicants discuss in the ER the environmental impacts of alternatives and any other matters described in 10 CFR 51.45; 10 CFR 51.45 requires that the discussion of alternatives be sufficiently complete to aid the Commission in developing and exploring, pursuant to Section 102(2)(E) of NEPA, appropriate alternatives to recommended courses of action in any proposal which involves unresolved conflicts concerning alternative uses of available resources.
Issue:
To support the audit, NextEra posted a new figure to the portal showing existing and planned solar arrays, as well as the candidate areas for siting facilities associated with the replacement power alternatives considered in the ER. The figure depicts the areal extent and acreages associated with four color-coded expanses within the Point Beach site boundary (the Point Beach Solar Array Fence Line, the Potential Solar Area Combination Alternative, the Power Plant Alternative, and the Point Beach Solar Alternate Arrays). As discussed with NextEra during the Alternatives/Cumulative Impacts breakout session, it is not fully clear how the terminology, locations, and acreages presented for these color-coded areas correlate with the information presented in the ER.
Request:
Provide a summary of the environmental audit discussion held on 4/6/2021 addressing the narrative response to Information Need ALT-1 and the supporting information posted by NextEra to the Point Beach portal. Specifically, provide the figure posted to the Point Beach portal showing alternative replacement power locations (Viewing 01_Photo Overview_Alternatives with Solar_v2_29March2021.pdf) and provide a crosswalk discussion addressing how the different color-coded areas shown on the figure agree with or differ from the replacement power alternatives discussions presented in ER Sections 7.2.3.1.1, 7.2.3.2, 7.2.3.2.1, and 7.2.2.2.2, as well as the Point Beach Solar and Two Creeks Solar project areas depicted in ER Figure 3.1-3.
Water Resources - Surface Water Requirement:
10 CFR 51.53(c)(2) requires, in part, that an applicants ER contain the applicants plans to modify the facility, describe in detail the affected environment around the plant, as well as modifications directly affecting the environment.
Issue:
Section 3.5.3.2 of the ER presents NextEras assessment of erosion along Point Beachs shoreline including bank stabilization efforts. Further, Section 3.6.1.2.4 of the ER states that bank stabilization activities are conducted in accordance with a U.S. Army Corps of Engineers permit.
During the environmental audit, a breakout session was held on 4/7/2021 to discuss the NRC staffs information need #SW-5, which requested that NextEra provided a brief description of the nature and frequency of bank stabilization activities and when such activities were most recently performed. In its response, NextEra stated that a breakwater consisting of large stones was installed in Lake Michigan, in the area north and south of Point Beachs discharge flumes along with a section installed directly between the two discharge flumes. NextEra reported that the project was begun in November 2019 and was completed in the Fall of 2020.
Request:
Provide a description of the purposes of the completed bank stabilization project and the benefits it provides and discuss the relationship of the project to the Point Beach subsequent license renewal, if any.
Identify the acreage and linear feet of shoreline affected. Summarize any ecological, cultural, or other environmental surveys performed and consultations conducted with State or Federal agencies and list any environmental permits obtained to authorize the work.
In addition, confirm the NRC staffs understanding that no further bank stabilization projects are planned beyond routine maintenance of the existing stone armoring during the proposed SLR term.
Finally, provide for docketing a copy of the following reference as cited in Section 3.6.1.2.4 of the ER as relevant to the aforementioned bank stabilization project:
USACE. 2020b. Permit for Bank Stabilization, Regulatory File No. MVP-2014-01045-SJW, U.S.
Army Corps of Engineers, October 22, 2019.
Aquatic Resources AR-1 Requirement:
10 CFR 51.53(c)(3)(ii)(B) requires, in part, that for plants with once-through cooling systems, the applicant assess the impact of the proposed action on fish and shellfish resources resulting from thermal changes.
Issue:
Section 4.6.2 of the ER assesses the thermal impacts of the proposed license renewal on aquatic organisms. NextEras analysis relies on a thermal evaluation conducted by EA Engineering in connection with the 2009 extended power uprate. Although NextEra submitted EA Engineerings evaluation to the NRC during the staffs Extended Power Uprate review, the ADAMS record is incomplete (see ADAMS No. ML101340103). The document is missing many pages, including all figures and tables. The NRC staff requires the complete document to perform its NEPA analysis.
Request:
Submit the following ER reference for docketing:
EA Engineering. 2008. Point Beach Nuclear Plant Evaluation of the Thermal Effects Due to a Planned Extended Power Uprate. August 2008.
Historic and Cultural Resources HCR-1 Requirement:
10 CFR 51.53(c)(3)(ii)(K) requires that all applicants identify any potentially historic or archaeological properties and assess whether any of these properties will be affected by future plant operations and any planned refurbishment activities in accordance with the National Historic Preservation Act of 1966 (NHPA). Section 106 of the NHPA directs Federal Agencies to take into account the effects of their undertakings on historic properties. Section 106 of the NHPA requires that Federal Agencies consult with the State Historic Preservation Officer (SHPO) and in accordance with 36 CFR 800.1(c), the NRC must complete the Section 106 process prior to making a decision on the licensing action. In accordance with 36 CFR 800.4(b),
in consultation with the SHPO, the NRC shall take the steps necessary to identify historic properties within the area of potential effect.
Issue:
On March 5, 2021 (ADAMS Accession No. ML21069A220), the Wisconsin SHPO requested that NextEra conduct an architectural/structural survey of Units 1 and 2, including all ancillary buildings and structures, that may now fall within the 50-year threshold for inclusion on the National Register of Historic Places (NRHP) and that NextEras equivalent Historic Properties Management Plan (Archaeological, Cultural, and Historic Resources procedure manual) be updated to include architectural resources as part of Section 106 consultation for the Point Beach subsequent license renewal application. During the environmental audit, NextEra staff stated that they would conduct an architectural survey of Point Beach structures to determine NRHP eligibility and discussed the estimated completion timeframe of the survey.
Request:
A. Provide a copy of the architectural survey and any correspondence or communication with the Wisconsin SHPO regarding concurrence or nonconcurrence with the recommendations in the survey. If the architectural survey has not been completed or is not yet available, provide a discussion of the status of the survey, its expected completion date, and a date for when NextEra plans to submit the survey to the Wisconsin SHPO. When the architectural survey is finalized, the NRC staff requests that NextEra provide a supplement to this response to this RAI that includes a copy of the survey.
B. Provide a status of the update to NextEras Archaeological, Cultural, and Historic Resources procedure manual to include architectural cultural resources. As part of the response, provide a summary description of the changes made to the manual and the status of the Wisconsin SHPOs review and concurrence. If the requested information is not available, the NRC staff requests that NextEra provide a supplement to this response to this RAI when the information is available.
HCR-2 Requirement:
10 CFR 51.53(c)(3)(ii)(K) requires that all applicants identify any potentially affected historic or archaeological properties and assess whether any of these properties will be affected by future plant operations and any planned refurbishment activities in accordance with the NHPA.
Issue:
Section 3.8 and Table 3.8-1 of the ER identify onsite cultural resource surveys that have been conducted within the 1,260-acre Point Beach property, describe onsite cultural resources, and discuss NextEras Archaeological, Cultural, and Historic Resources procedure manual. During the environmental audit, the NRC staff reviewed NextEras Archaeological, Cultural, and Historic Resources procedure manual and the five cultural resource surveys identified in Table 3.8-1 of the ER. The NRC staff identified:
updated information in a 2018 Phase 1 Cultural Resource Survey that was not discussed in the ER related to site 47-MN-0267 (listed in Table 3.8-2 of the ER);
site 47-MN-0452 (listed in Table 3.8-2 of the ER) provides the incorrect name, site type, and cultural affiliation; and additional information related to identified sites that NextEra has committed to avoiding.
This information was discussed with NextEra during the Historic and Cultural Resources breakout session during the audit.
Request:
A. For site 47-MN-0267 listed in Table 3.8-2 of the ER, provide a summary of the findings discussed in the November 2018 Commonwealth Heritage Group, Inc. Phase 1 Cultural Resource Survey (listed in Table 3.8-1 of the ER). Include in your discussion recommendations regarding the eligibility of this site for listing on the NRHP.
B. For site 47-MN-0452 listed in Table 3.8-2 of the ER, provide the correct name, site type, and cultural affiliation.
C. Identify the sites listed in Table 3.8-2 of the ER that NextEra has fenced off within the 1,260-acre Point Beach property.