ML070260528

JAFNPP - Shooting Range Additional References; Questions & Responses from 1/23/07 E-mail from Jessie Muir (NRC) to Mike Rodgers (Entergy)

ML070260528
Person / Time
Site:	FitzPatrick
Issue date:	01/26/2007
From:	Rodgers M FitzPatrick
To:	Muir J NRC/NRR/ADRO/DLR
jmm7
References
Download: ML070260528 (13)

Text

Questions & Reponses from the 1/23/07 email from Jessie Muir (NRC) to Mike Rodgers (Entergy):

BIRDS:

1. Do you know if the Oswego County Health Dept would have identified and recorded the name and/or species of the birds found?

Entergy Response:

Upon notification, the Oswego County Health Department did not request that the birds be brought to them for identification. The Health Department advised Entergy to simply dispose of the dead birds (because they were non-crow species?). No further action was taken.

2. On the 2006 report, the suggested action item states, "If this is an item that requires monitoring and tracking, personnel at the facility should be made aware of it." Is there a procedure in place to identify birds to determine what species they are, to determine if they are migratory or T&E species? Or is there one being developed as a result of these incidences?

Entergy Response:

Entergy is not aware of any federal or state requirement to monitor and/or track bird deaths related to the operation of the facility. The CR originator was simply stating that if there is a requirement then plant personnel need to be made aware of it. The CR originator assumed there was a requirement to track these incidents because the NRC had asked a question about it relative to License Renewal.

Entergy does not believe these birds were a T&E species and it is unknown if they were migratory or not.

These are two isolated incidents and Entergy will continue to track these in our site Condition Reporting system. If an adverse trend develops then appropriate corrective actions will be enacted. No procedure is being developed at this time.

Based on our previous conversation this morning, our staff has a couple more questions related to the outdoor rifle range.

RANGE:

1. When was the outdoor firing range built? You mentioned the range was built on a 'previously disturbed' site. Do you know what activities had been conducted at that site prior to the construction of the current rifle range? The archaeological study from 1987 states there was a shooting range at JAFNPP but did not indicate a location.

Do you know the location of that firing range?

Entergy Response:

The outdoor firing range was constructed in late 2004/early 2005.

The site where the outdoor firing range was built was an open field that had previously supported farming activities. The site had also been used as an artillery range prior to the plant being built.

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Regarding the reference to a shooting range in the 1987 archaeological report, there is an indoor shooting (pistols) range east of the JAF plant between the plant and the outdoor range. The indoor range is located along the access road leading to the outdoor range. See attached picture (Indoor-Outdoor Ranges.JPG) which shows the relationship of the indoor range and the outdoor range to the JAF Protected Area.

2. Was the outdoor range built with the SACON blocks? If not, what (if any) mitigative measure were used to reduce soil contamination from lead before the SACON blocks were installed?

Entergy Response:

SACON blocks have been used as the backstop for all firing activities since the original construction of the outdoor range. The SACON blocks are stacked in front of the 30 foot high soil backstop and are used to absorb the arms fired into them. The spent SACON blocks and associated debris have been tested (TCLP) and the results showed that they can be disposed of as non-hazardous waste. See attached memos to file (SACON block-debris memos.PDF) for more information on these waste determinations and for additional information on SACON.

See attached memo to Chuck Barlow (Entergy Environmental Counsel) from Michael D. Rodgers (JAF Sr. Environmental Engineer) (Rifle Range memo with pictures.PDF) with accompanying pictures for a better description of the rifle range.

3. How often is the outdoor range used? Several weeks a quarter, correct?

Entergy Response:

The outdoor range is used by JAF Security personnel for training purposes. It is used approximately 3-4 weeks per trimester or 12-14 weeks per year.

4. Has any testing been done for noise levels? If so, what are the results?

Entergy Response:

JAF Security personnel wear hearing protection while training at the range. No surrounding area noise level testing has been conducted during firing operations because the range is located entirely on Entergy property, well away from the property lines. In addition, there have been no reports of noise related issues off site as a result of firing range operations.

5. What type of information did the zoning committee require?

Entergy Response:

The Town of Scriba Planning Committee asked about three items:

Direction of fire: The 30 foot high end berm, in combination with the fact that the range, as built, is over 2 miles away from the Entergy property line essentially eliminated concerns over this issue. During the design phase of the range, it was determined to be more desirable 2

to fire away from the lake than towards it to avoid any incidental discharge into the water.

Noise concerns: Based on the location of the range (well within our property boundary) this has not been an issue.

Additionally, because the range has a 30 foot high end berm and 10-15 foot high side berms the noise generated from range activities is well contained to the immediate area.

Lead control: The range was constructed and is managed in accordance with USEPA guidance EPA-902-B-01-1, Best Management Practices for Lead at Outdoor Shooting Ranges, January 2001.

The Town of Scriba required construction drawings for the range and they performed a code compliance inspection during construction.

All items/issues were successfully resolved with the Town leading to the construction of the range. Since construction, there have been no issues raised by the Town or any local citizens related to the operation of the range.

6. You stated no permit is required from local or state authorities, correct?

Entergy Response:

There are no local or state requirements to have an operating permit for the range.

7. It is stated in the Environmental Review checklist that the shooting range was built according to EPA BMPs. Is the shooting range managed according to the EPA BMPs? On Page 4 of 7, its mentions attachment 9.1, can you provide that attachment?

Entergy Response:

For Best Management Practices (BMPs) implemented at the outdoor firing range during construction and operation, see memo to Chuck Barlow (Entergy Environmental Counsel) from Michael D. Rodgers (JAF Sr.

Environmental Engineer). As a note, a Stormwater Pollution Prevention Plan (SWPPP) was developed and implemented prior to construction of the range to ensure compliance with stormwater regulations. A Notice of Intent (NOI) was not required because the pond did not discharge to waters of the state. This interpretation was confirmed with Mr. Scott Cook (NYSDEC-Region 7).

The attachment requested On page 4 of 7 was submitted as Item #85 in the FitzPatrick License Renewal Environmental Site Audit Information Requests submitted to NRC on December 19, 2006. The document referenced consists of 3 pages from former site procedure CHSO-09 (Environmental Impact Review, Attachment 1 and 2), entitled Firing Range Expansion, dated 6/14/04.

8. Does anyone else use the shooting range (local law enforcement, etc)?

Entergy Response:

No, only JAF personnel use the range.

9. Was the soil tested for anything before it was paved and graded?

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Entergy Response:

Prior to range construction some soil borings were collected in this area to determine soil composition only. No other soil testing was conducted.

SETTLING POND:

1. What did you test for lead (water, sediment?) and where (at the paved areas, at the pond)? Did you test for any other metals or constituents besides lead?

Entergy Response:

The water in the second pond compartment of the settling pond was tested in 2005 (0.0068 ppm) and 2006 (ND, detection limit of 0.0050 ppm). Based on knowledge of the process, the only constituent tested for was lead.

There has been no accumulation of sediment in either compartment of the settling pond since operation of the range began. Therefore, no sediment samples have been collected or analyzed. In the future, if sediment deposition allows, a soil sample will be obtained and analyzed for lead content.

2. Is the state aware of your settling pond and where the water comes from and goes? Do you have any communication with the state about the discharge of water from the settling pond into a nearby field and their buy off that it does not need to be included in the SPDES permit?

Entergy Response:

See attached memo to Chuck Barlow (Entergy Environmental Counsel) from Michael D. Rodgers (JAF Sr. Environmental Engineer). This issue was evaluated at the corporate and site level and it was determined that there was no discharge to waters of the state (i.e. the water basically trickles out into a field). Based on input from Chuck Barlow, Legals review confirmed our interpretation. Therefore, no communication occurred with NYSDEC about the pond.

3. Do you dredge the settling pond? If so, what do you do with the spoils? How often do you dredge the pond?

Entergy Response:

There has been no need to dredge the pond as the range has been in use for less than two years. If a need arises at a later date, all spoils will be properly characterized (hazardous or non-hazardous) in accordance with Entergy Nuclear fleet procedure EN-EV-106 (Waste Management Program) to ensure that the dredge material is disposed of properly.

4. Did the earth excavation for the settling pond and/or range require approval from anyone since wetlands were disturbed?

Entergy Response:

The area of disturbance was confined to non-wetland areas (it was an open field). Therefore, no approval was required.

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