ML093290073

Environmental RAI Enclosure

ML093290073
Person / Time
Site:	Watts Bar
Issue date:	12/03/2009
From:	Division of Operating Reactor Licensing
To:	Tennessee Valley Authority
Wiebe, Joel NRR/DORL/WBSP, 415-6606
Shared Package
ML093030163	List: ML093290073
References
TAC MD8203
Download: ML093290073 (12)

Text

1 RAIs Watts Bar Unit 2 RAI Number Question (RAI)

Cultural Resources CR-1 As discussed and reviewed at the site audit, describe the process to identify Tribes and interested parties to consult with regarding the potential impacts to cultural resources as a result of the proposed project.

CR-2 During the site audit staff reviewed consultation letters related to cultural resources. Provide copies of all consultation letters with the State Historic Preservation Officer (SHPO), Tribes, and interested parties as well as response letters and comments received from the SHPO, Tribes, and interested parties as a result of the proposed project.

CR-3 As discussed at the site audit, describe the cultural background (prehistoric and historic) at Watts Bar Nuclear (WBN) and the vicinity to put the historical properties in context.

CR-4 As discussed at the site audit, provide a status of the 106 consultation process.

CR-5 As discussed at the site audit, describe the Area of Potential Effect (APE) and the cultural resources located within.

CR-6 As discussed and reviewed at the site audit, provide copies of relevant cultural resources reports and site forms for the Watts Bar property and the associated survey reports for the transmission line corridors. Provide copies of all relevant reports and site forms associated with the APE.

CR-7 As discussed at the site audit, provide copies of procedures that identify measures to be taken if cultural resources and/or human remains are inadvertently discovered during operation and maintenance activities.

CR-8 As discussed at the site audit, provide pre-and post-construction aerial photographs, if available.

CR-9 As discussed at the site audit, describe the cultural resources at Watts Bar and the impacts the proposed action may have on cultural resources at Watts Bar.

CR-10 As discussed at the site audit, provide copies of erosion control procedures for the reservoir shoreline.

CR-11 As discussed at the site audit, provide information on management around less-developed areas of the plant site, for instance, brush removal programs near known historic and archaeological resources or near unsurveyed areas.

Enclosure

2 RAI Number Question (RAI)

CR-12 During the site audit, staff reviewed a document titled Categorical Exclusion (CEC) for the Cleveland FY09 Mechanical Reclearing and Herbicide Application (tracking number 19300). Provide this document in a referenceable format. Provide vegetation management procedures for the site and associated transmission line(s) to avoid impacts to historic and archaeological resources and sensitive wildlife resources. Provide TVAs policy regarding seasonal access to transmission corridors that cross agricultural lands.

CR-13 As discussed at the site audit, provide a copy of the Environmental Compliance Manual and any other environmental review procedures for land-disturbing activities (e.g., trenching, clearing, digging).

CR-14 As discussed at the site audit, provide maps of ownership and land use of the applicants property and associated transmission lines. Copies of historic plat maps would be useful, if available.

Land Use L-1 Verify that current land use at the site and in the vicinity is the same as described in the 1978 FES-OL.

Provide a map of the Watts Bar site and vicinity with detail on current land-use coverage categories. This map should reproduce clearly in black and white for use in hardcopy and website versions of the Nuclear Regulatory Commission (NRC) EIS.

L-2 As discussed at the site audit, provide land acreage estimates of major coverage type categories (e.g.,

forested, built-up, etc.) within the site and boundary and within the vicinity of the site.

Transmission Lines TL-1 As discussed at the site audit, provide a map of the Watts Bar transmission system within the site and to the nearest substations. Include corresponding description of relevant dimensions (e.g., length and width of the corridors) and land-use coverage type in transmission corridor. This map should reproduce clearly in black and white for use in hardcopy and website versions of the NRC EIS.

Socioeconomics S-1 As discussed at the site audit, in order to determine the overall economic impact in the region (focusing primarily on Rhea and Meigs Counties), provide an estimate of the marginal in-lieu tax payment from Tennessee Valley Authority (TVA) that is attributable to the existence of an additional operational nuclear unit (Unit 2) on the Watts Bar site and provide a rough estimate of how much of this payment is distributed to Rhea and Meigs Counties.

S-2 Provide the list of counties that have been designated as impacted areas during the construction phase of Watts Bar Unit 2, and provide an estimate of the tax equivalency payments these impacted counties are (and/or will receive.

3 RAI Number Question (RAI)

S-3 Provide recent information on the total number of Watts Bar Unit 1 and 2 permanent operations-related employees and describe where these employees live (county-level residence is sufficient).

S-4 Briefly describe the outage process associated with Unit 1 and 2 on the Watts Bar site in terms of activities (at a summary level), staffing needs (i.e., number of workers), duration, and frequency. If known, roughly estimate the number of the workforce that are local residents and commute to site relative to the workforce that temporarily moves into the region during the outages.

S-5 Provide a copy of TVAs Commitment Tracking - EIS Project 16475.

S-6 Provide data on the capacity and average usage for regional (i.e., Rhea and Meigs Counties) water and sewer utilities (including Decatur Water Department, Dayton Water Department and Wastewater Treatment, Spring City Water System and Waste Treatment, and Watts Bar Utility District).

Benefit-Cost BC-1 At the site audit we were shown a publicly available presentation from an August 1, 2007 TVA board meeting (entitled Watts Bar Nuclear Plant Unit 2 Completion Studies), which included a capital cost estimate of $2.49 billion for the completion of Watts Bar Unit 2. Confirm that this capital cost estimate is still a reasonable overnight capital cost estimate associated with the completion of Unit 2 and indicate the appropriate dollar years (e.g., 2007, 2008) associated with this estimate. If this estimate is no longer valid, provide an updated overnight capital cost estimate for the completion of Unit 2.

BC-2 Provide an estimate of levelized operating (i.e., delivered cost) costs associated with power generation from Watts Bar Unit 2 and describe relevant assumptions, including assumed capacity factor. Indicate the amount (either as a percent or in cents/kWh) attributable to fuel costs, decommissioning expenses, and waste disposal costs.

BC-3 To assess the potential benefits of operating a plant in the TVA service area, please describe the following information related to power supply and demand (and net needs) in the service area as provided in the TVAs most recent Long-Term Capacity Expansion Plan:

1. At what rate did net system requirements grow from 1990 to 2008?

2. As part of the medium-load forecast, at what average rate are net system requirements projected to grow through 2011 to 2012 timeframe?

3. What is the forecasted need for capacity of any type (baseload, intermediate, or peaking) during the 2012 to 2014 timeframe (provide MW estimate)? Include estimates for the low-, medium-, and high-load forecasts.

4. What portion of this forecasted need for capacity during the 2012 to 2014 timeframe would be considered baseload need (provide MW estimate)? Include estimates for the low-, medium-, and high-load forecasts.

4 RAI Number Question (RAI)

Hydrology H-1 During the site audit, staff reviewed a document titled Groundwater Investigation Report prepared by ARCADIS G&M Inc. for TVA August 12, 2004. Provide this document in a referenceable format.

H-2 If the ARCADIS report cannot be provided, provide a current water-table map of the Watts Bar site including locations of monitoring wells.

H-3 If the ARCADIS report cannot be provided, provide an analysis of groundwater travel time from WBN Unit 2 facilities to nearby surface water bodies (accessible environment) taking into account the properties of the site following construction of Unit 2.

H-4 Provide a current summary of tritium distribution in groundwater at the WBN site.

H-5 In order to better understand the impact of plant operations on site groundwater, provide information on the stage fluctuation of the yard holding pond during a recent year of operations. How are those fluctuations expected to change when WBN Unit 2 begins operation?

H-6 The ARCADIS report reviewed at the site audit showed the impact on the water table of a French drain surrounding the power block. How much water is pumped from the French drain annually?

H-7 Provide a list of current and likely future downstream water users drawing from the Tennessee River including the estimated population served, average daily use, and approximate distance from the site. Also identify municipal water supplies drawing from surface water bodies within a 50-mile radius of the site.

H-8 Provide a current list of groundwater users in the vicinity of the WBN site including an estimate of annual withdrawal.

H-9 Provide a current table of dilution factors and travel times for downstream water users within an 80-kilometer (50-mile) radius of the WBN Plant.

Have any of the users listed in the 1995 EIS ceased water withdrawal? Are there new users to be considered?

Have any changes occurred that result in changes to the dilution factors reported.

H-10 Table 2.3 of the Final Environmental Statement related to the operation of Watts Bar Nuclear Plant Units Nos.

1 and 2 (1978) (NUREG 0498) summarized water quality in Chickamauga Reservoir adjacent to the Watts Bar site. Identify any changes to water quality since publication of that table.

H-11 Provide through screen velocities for water entering the Intake Pumping Station under normal operating conditions with WBN Units 1 and 2 operating. Provide a diagram of the intake pumping station that includes dimensions of intake openings, location, and characteristic of trash racks and traveling screens to allow staff to validate the velocity provided.

5 RAI Number Question (RAI)

H-12 Provide through screen velocities for water entering the Supplemental Condenser Cooling Water (SCCW) system under normal operating conditions with WBN Units 1 and 2 operating. Provide a diagram of the SCCW intake structure that includes the dimensions of intake openings, location, and characteristics of trash racks and traveling screens to allow staff to validate the velocity provided.

H-13 Provide a description of how the cooling system will be operated under normal winter and summer operations.

Provide a copy of the TVA procedure for operations of the cooling systems to make sure National Pollutant Discharge Elimination System (NPDES) permit conditions are not exceeded.

H-14 Provide a water balance and heat balance for the operation of WBN Units 1 and 2. Indicate where incremental increases in water use will occur as a result of initiating operation of Unit 2. Provide this information for normal summer and winter operation and for the operational mode which has the greatest impact on the receiving water body (effluent temperature, instream temperature, and instream temperature rate of change).

H-15 Thermal Description and Physical Impacts. Provide the calculation package for all runs that support the application (CORMIX or other models). Include electronic copies of all input and output files.

H-16 The figure included in Appendix B of the 2007 TVA EIS shows water flow rates for plant systems with one unit in operation. Provide an update of this figure showing the flow rates for the system with WNB Unit 1 and 2 in operation. Provide an update to the table on page 3-3 of 1978 EIS to include values that include the flow rates needed for both units in operation.

H-17 ESRP 5.3 directs the staff to describe the cooling system impacts of station operation. Temperature evaluations associated with the operation of Unit 1 provide insight into potential impacts of Unit 2 operations.

As such staff request the following document on the impact of WBN 1 operation on receiving water temperature:

TVA 2006b. Watts Bar Nuclear Plant (WBN) - Unit 1 - Technical Specification (TS) Change TS-06-09, Revision of Ultimate Heat Sink (UHS) Temperature, TVA letter to U.S. Nuclear Regulatory Commission, May 8, 2006.

H-18 What is the current expectation for blowdown discharge for operating WBN Units 1 and 2? The 2007 TVA EIS states For the original heat dissipation system, the maximum discharge from the plant diffusers due solely from blowdown from the cooling towers was expected to be about 50 cfs for the operation of one unit and 85 cfs for the operation of both units (TVA 1977b).

6 RAI Number Question (RAI)

H-19 ESRP 5.2.1 directs staff to consider hydrologic alterations such as maintenance dredging. Is periodic maintenance dredging of the intake canal required/planned? If so, how are intake operations conducted to supply the plants raw water demand while dredging of the intake channel. Would maintenance dredging of the barge unloading facility be required prior to future use? Are any other dredging actions associated with operation of WBN Unit 2 being considered? How would dredged material be disposed of?

H-20 From the past 5 years, provide any release notifications, violation information (NOVs), or remediation documentation associated with surface-water discharges, septic or sewage systems, groundwater or soil contamination (including spills, leaks, and other releases of fuel solvents, or other chemicals).

H-21 The ER states (p. 52) Operation of Unit 2 along with Unit 1 would result in an increase of raw water intake usage at the IPS by an estimated 33 percent compared to sole operation of Unit 1. Why does water withdrawn at the IPS only increase 33 percent for a doubling of the amount of cooling needed?

H-22 The ER states that potable water will be obtained from the Watts Bar Utility District. What is the volume of water provided by WBUD to support the operation of Unit 1 and what is the anticipated additional increment of water needed from the utility district to support the operation of Unit 2? What is the total anticipated water need from the district in the future? What are the environmental impacts associated with the WBUD obtaining and providing the additional water.

H-23 What is the anticipated normal and maximum volume of effluent to be pumped to the Spring City sewage treatment plant with WBN Units 1 and 2 in operation?

H-24 When did the tie in to the Spring City sewage treatment plant become effective?

H-25 What is the concentration of total dissolved solids in the water discharged from the cooling tower basins through the diffuser? How does this compare to the concentration in the intake wate H-26 On one of the tours during the site audit, we visited the onsite landfill and were told it is not currently being used. How will solid waste from operation of WNB Unit 2 be disposed of?

H-27 Provide a figure of the WBN site that identifies site drainage features. This figure should reproduce clearly in black and white for use in hardcopy and website versions of the NRC EIS.

H-28 Provide an update of Table 3-10 of the 2007 EIS that reflects changes in chemical use and site operations since closure of the sewage treatment plant and change in chemical use at the site documented in the April 2009 letter, Watts Bar Nuclear Plant (WBN) - National Pollutant Discharge Elimination System (NPDES)

Permit No. TN0020168-Request For Raw Water Treatment Modification. Letter from Darin Hutchison to Mr. Vojin Janjic.

7 RAI Number Question (RAI)

H-29 Provide a recent analysis of groundwater quality on the WBN site. ESRP 2.3.3 calls for staff to review water quality parameters including total dissolved solids, hardness, odor, conductivity, phosphorus forms (total and orthophosphate), nitrogen forms (ammonia, nitrate, nitrite, organic), alkalinity, chlorides, sulfate, sodium, potassium, calcium, magnesium, heavy metals (e.g., Hg, Pb), pH, silica, iron, carbon dioxide, and bicarbonate.

How will the operation of Unit 2 impact groundwater quality on the WBN site?

H-30 Identify the survey datum used to establish elevations reported for the WBN site and facilities (for example NAVD88 or NGVD29).

General G-1 Provide the requested figures that reproduce clearly in both black-and-white and color, and that can be modified as necessary, for use in hardcopy and website versions of the EIS. If GIS was used to create the figures, provide the shapefiles/metadata that accompanies the figure. For each figure, provide a high-resolution (300 dpi or higher) PDF made from a source file. Figures and supporting files for the following figures from the TVA 2007 EIS -

Figure 1-1 Figure 1-2 Figure 2-1 Figure 2-2 Figure 3-1 Figure 3-2 Figure 3-4 Figure 2.4-105 from the FSAR, Amendment 94 G-2 Provide all 2007 TVA EIS references, including documents that are referenced in the EIS appendices. The only references from the 2007 TVA EIS that the NRC is not requesting are those that have been published by the NRC and those that are publically available.

G-3 As discussed at the site audit, cumulative impacts will be included as part of the EIS. Provide current updated information on other nearby industrial facilities, other nuclear facilities, and other projects within a 50-mile radius of the site. This should include updated information on major water users within a 50-mile radius as well as facilities that discharge into the Tennessee River.

G-4 As discussed at the site audit, provide the procedure for reporting and keeping records of environmental data that will be used during operation of WBN Unit 2.

8 RAI Number Question (RAI)

G-5 Provide a list of all authorizations, consultations, and environmental permits and approvals needed for operation of Unit 2 and provide a status for each item.

Meteorology M-1 As discussed at the site audit, provide 50 percent X/Q values for use in the environmental review of DBAs.

The timeframes and distances for the environmental review X/Q values should be the same as those in the FSAR.

Design Basis Accidents DBA-1 As discussed at the site audit, provide analyses of the DBAs considered in the FSAR that use realistic (50 percent) X/Qs with sufficient information to permit staff to independently evaluate the doses.

Severe Accidents SA-1 As discussed at the site audit, provide MACCS input and output files for Watts Bar Unit 2 that include analyses for all severe accident release classes including the release class or classes in which radionuclides are released to reactor containment and containment remains intact.

SA-2 As discussed at the site audit, provide a discussion of the potential risks associated with external initiating events and accidents that might occur when the reactor is not at power and the relative frequency of such events and accidents.

Severe Accident Mitigation Alternatives SAMA-1 As discussed at the site audit, provide a discussion of the extent to which the January 2009 assessment considers the risks (core damage frequencies) associated externally initiated events and events that might occur when the reactor is shut down.

SAMA-2 As discussed at the site audit, provide a discussion of the bases for estimating the costs of implementing design alternatives for the January 2009 document.

Aquatic Ecology AE-1 Additional data has been collected since the publication of the FES-CP. The vast majority of the impingement in 2005 to 2006 was due to threadfin shad. The ESRPs state that cropping rates in relation to standing stock estimates for species populations should be considered. As discussed at the site audit, provide a population estimate of threadfin shad in the Watts Bar Reservoir to use as a metric for standing stock estimates.

9 RAI Number Question (RAI)

AE-2 Explain the apparent difference between the number of fish impinged during the August 1974 to July 1975 impingement sampling from the intake for the WBF as reported on pages 34 and 35 of the SCCW EA, and the discussion of impingement during the same timeframe on pages 3 and 4 and Table 4 for the 316(b) analysis, dated 2007 (Fish Impingement at Watts Bar Nuclear Plant Supplemental Cooling Water Intake Structure during 2005-2007).

AE-3 As discussed at the site audit, provide an updated Table C-7 from the 2007 TVA EIS that corrects the discrepancy in the heading of the sixth column, and appropriately describes the use of the word Total in the last column heading.

AE-4 TVA 1998 Figure 3-2 shows the location of the sampling stations at three native mussel beds surveyed during the preoperational and operational monitoring programs (TRM 520-521L; TRM 526-527R and TRM 528-529L).

Table C-7 of the FSEIS (pages 155 and 156) indicates that sampling was conducted in 1997 at TRM 529.2R.

Indicate whether this is an additional existing mussel bed and provide the extent of this mussel bed and/or the reference that discusses the sampling and its location. If additional mussel beds are known to occur in this reach beyond those specified above, provide the locations of the beds.

In addition, Table C-7 of the FSEIS shows that monitoring of mussels only occurred at 529.2R during the 1997 sampling period. However, Table 3-6 of TVA 1998 provides results of mussel surveys at TRM 528.2 to 528.9.

Provide an updated Table C-7 that provides the data for all of the surveys that were conducted in the mussel beds closest to the Watts Bar site from surveys in 1990, 1992, 1994, 1996 and 1997.

AE-5 As discussed at the audit, provide the most recent TVA annual biological monitoring reports or recent Reservoir Vital Signs measurements for the Watts Bar Reservoir.

AE-6 Provide a figure that shows the detailed features of the site, including major hydrological features and proposed or existing sampling stations and monitoring locations. Include the approximate locations for annual environmental monitoring of fish and invertebrates.

AE-7 Provide a statement regarding whether any operational monitoring programs of aquatic organisms including fish and mussels will be conducted after WBN 2 begins operation. If so, provide details related to the type of monitoring, location, and frequency of monitoring.

AE-8 As discussed at the site audit, provide an analysis that compares the preoperational and post-operational differences or similarities in fish species from Unit 1 operations in terms of occurrence and trends in the Chickamauga Reservoir.

AE-9 Provide a description of the mussel habitat formation project that was performed by TVA downstream of the Watts Bar dam. Describe any observed changes to the mussel population at that location and any plans for further studies or habitat improvements for the mussels.

10 RAI Number Question (RAI)

AE-10 Provide the following documents:

Kay L.K. and J.P. Buchanan. 1995. Effects of thermal effluent from Sequoyah Nuclear Plant on fish populations in the Chickamauga Reservoir. Tennessee Valley Authority. Water Resources, Environmental Compliance, Chattanooga, TN.

Hickman and J.P. Buchanan. 1996. Chickamauga Reservoir sauger investigation 1993-1995 final project report. Tennessee Valley Authority, Water Management, Chattanooga, TN.

TVA 1994a - Chapter 5. Letter from DE Nunn, TVA, to U.S. NRC. August 5, 1994.

Subject:

Watts Bar Nuclear Plant (WBN) Units 1 and 2 - Request for Additional Information Relating to Final Environmental Statement. (From SFEIS (1995); page 5-31)

TVA 1994g - Chapter 5. Letter from DE Nunn, TVA, to U.S. NRC. September 27, 1994.

Subject:

Watts Bar Nuclear Plant (WBN) - Response to NRC's Request for Additional Information Related to the Watts Bar Environmental Review. (From SFEIS (1995 page 5-31)

Terrestrial Ecology TE-1 As discussed at the site audit, provide a map of terrestrial habitats on the WBN site, including wetlands and streams.

TE-2 As discussed at the site audit, provide an updated list of federal-and state-listed species that may occur on or within 1/2 mile of the WBN site and transmission corridors.

TE-3 Provide updated distribution and abundance information describing known occurrences of federal-and state-listed species within 1/2 mile of the transmission corridors that service the WBN site from the site to the first substation.

TE-4 As discussed at the site audit, provide a list of and distribution information on exotic invasive species that may occur on the WBN site, within the transmission corridors, and within 1/2 mile of the WBN site and the transmission corridors.

TE-5 During the site audit, staff reviewed a document titled Categorical Exclusion Checklist for the WBN U-2 Powerline Upgrade (tracking number 18217). Provide this document in a referenceable format.

TE-6 Provide the WBN Environmental Compliance Manual chapter that addresses erosion/storm water pollution prevention controls.

11 RAI Number Question (RAI)

Radiological Protection RP-1 As discussed during the site audit, the analysis on dose to the population was updated in the 2007 FSEIS.

However, the data was not sufficient for staff to conduct independent validation of the conclusions. Based on the data needs found in the revised ESRP 5.4, Exposure Pathways, provide the following data (including references for where data were obtained).

a. Confirm that there are no milk goat or meat animals are present in the 5-mi radius.

b. Provide the direction and distance for the nearest residence, nearest garden, and nearest milk cow.

c. Confirm that releases are calculated as ground level releases

d. Provide nearest site boundary distances for the 16 cardinal compass directions

e. Confirm that FSAR Section 11 (11.3.10.1 worst case feeding factor identified during the 1994 land use census for any real cow location (i.e., 70% pasture feeding). Milk feeding factors are listed in FSAR Table 11.3-10 is the appropriate data for determining the grazing seasons and fraction of daily intake of milk cows derived from pasture or fresh forage during the grazing season.

f. Provide data on fraction of the year that leafy vegetables are grown (Note: FSAR Section 11 (11.3.10.1 TVA assumes that enough fresh vegetables are produced at each residence to supply annual consumption by all members of that household.) Confirm and provide basis for absolute humidity: Factor H Table 6.3 p. 85/195 of ODCM (9 g/m3).

g. For the locations from which an individual can obtain aquatic food and/or drinking water and the shoreline areas that an individual can use for recreational purposes, provide the transit time of each facility discharge stream containing liquid radwaste discharge from the point at which the stream enters an unrestricted area to the identified location, and the estimated stream dilution at that location.

h. For each liquid radwaste discharge, the transit time from input to a facility discharge stream to the point at which the stream enters an unrestricted area, and the stream discharge in m3/sec (Note: Reg Guide 1.109 P 1.109-12 lists 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> as a minimum transit time for potable water.)

i.

Provide the following distributional data for each of the 22.5-degree radial sectors centered on the 16 cardinal compass directions for radial distances of 2, 4, 6, 8, 10, 20, 40, 60, and 80 km (1.2, 2.5, 3.7, 5, 6.2, 12, 25, 27, and 50 mi) from the reactor: (1) projected population for five years from the time of the licensing action under consideration, (2) present annual meat production (kg/yr), (3) present annual milk production (L/yr), (4) present annual vegetable production (kg/yr), and (5) estimate of direct radiation doses from sources within the site.

j.

Provide the present commercial fish catch (in kg/yr from waters within 50 mi downstream of the facility radwaste discharge (Note: Fish harvest - 3.04 lb/acre/y (variable HVST P77/195 of ODCM. From reference 12 (1 TVA memorandum on fish harvest. Dated Dec 15, 1987.) Confirm that there is no invertebrate catch to be considered. Provide transit time from the point at which the discharge stream

12 RAI Number Question (RAI) enters an unrestricted area to each major catch location, the estimated dilution at each location, and the basis for calculating transit time and dilution.

k. Provide the transit time and estimated dilution at each major location for drinking water intake locations within 80 km (50 mi) of the facility radwaste discharge (downstream or radius), the basis for calculating transit time and dilution, and the populations served or the daily water consumption at each location.

l.

Confirm that irrigation is not used for crops in the vicinity.

m. Confirm that there are no unusual animals, plants, agricultural practices, game harvests, or food processing operations having the potential to contribute 10 percent or more to either individual or population doses in areas affected by liquid effluents, and food-processing operations involving large quantities of water.

n. Provide the reference(s) for the sources or radioactive liquid and gaseous waste released from Unit 2, as addressed in the TVA FSEIS, Section 3.14, pp. 91-94.

o. Identify (preferably on a diagram) and provide a reference for principal release points for gaseous and liquid radioactive materials to the environment.

Identify and provide a reference for direct radiation sources within or onsite out-of-plant as solid waste (e.g.,

independent fuel storage).

RP-2 As discussed at the site audit, dose to biota was calculated in the 1978 NUREG-0478. However, this analysis cannot be validated using the current guidance. The following information is needed to meet the intent of NUREG-1555, ESRP 5.4.4 (1) Identify the representative biota for the area (see ESRP 5.4.4).

(2) Identify the pathways of exposure to the biota (3) Based on the above, perform dose calculations to biota using the radioactive source term used for the human dose calculations Transportation TR-1 On the bottom of page 99 of the TVA 2007 EIS, the applicant states the 1972 FES analysis was based on annual shipment of about 100 tons of natural uranium. Clarify (and provide a reference) that Watts Bar Unit 2 will use low-enriched uranium fuel.

TR-2 In Section 3.16 of the TVA 2007 EIS, the applicant refers frequently to tons of new fuel. Confirm that the unit is MTU.