ML13079A334
| ML13079A334 | |
| Person / Time | |
|---|---|
| Site: | South Texas  |
| Issue date: | 03/06/2013 |
| From: | Rencurrel D W South Texas |
| To: | Document Control Desk, Office of Nuclear Reactor Regulation |
| References | |
| NOC-AE-13002969, TAC ME5122, TAC ME5123 | |
| Download: ML13079A334 (7) | |
Text
Nuclear Operating CompanySouth Texas Project Electric Generating Station P.. Box 289 Wadsworth, Texas 77483March 6, 2013NOC-AE-1300296910 CFR 54STI: 33659164U. S. Nuclear Regulatory CommissionAttention: Document Control DeskWashington, DC 20555-0001South Texas ProjectUnits 1 and 2Docket Nos. STN 50-498, STN 50-499Response to Requests for Additional Informationfor the Review of the South Texas Project License Renewal ApplicationConcernina Wildlife Manaciement (TAC Nos. ME5122 and ME5123)
References:
1. STPNOC letter dated October 25, 2010, from G. T. Powell to NRC DocumentControl Desk, "License Renewal Application" (NOC-AE-10002607)(ML103010257)2. NRC letter dated February 15, 2013, "Requests for Additional Information forthe Review of the South Texas Project License Renewal Application(ML13037A678)By Reference 1, STP Nuclear Operating Company (STPNOC) submitted a License RenewalApplication (LRA) for South Texas Project (STP) Units 1 and 2. By Reference 2, the NRC staffrequests additional information for review of the STP LRA. STPNOC's response to therequests for additional information is provided in Enclosure 1 to this letter.There are no regulatory commitments in this letter.Should you have any questions regarding the information included in this response, pleasecontact either Peggy Travis, STP Environmental Group Supervisor, at (361) 972-8573 or KenTaplett, STP License Renewal Project regulatory point-of-contact, at (361) 972-8416.I declare under penalty of perjury that the foregoing is true and correct.Executed onKJT
Enclosure:
' " Date- Rec nSenior Vice PnSTPNOC Response to Requests for Additional InformationiLt7 NOC-AE-13002969Page 2cc:(paper copy)(electronic copy)Regional Administrator, Region IVU. S. Nuclear Regulatory Commission1600 East Lamar BoulevardArlington, Texas 76011-4511Balwant K. SingalSenior Project ManagerU.S. Nuclear Regulatory CommissionOne.White Flint North (MS 8B1)11555 Rockville PikeRockville, MD 20852Senior Resident InspectorU. S. Nuclear Regulatory CommissionP. O. Box 289, Mail Code: MN116Wadsworth, TX 77483C. M. CanadyCity of AustinElectric Utility Department721 Barton Springs RoadAustin, TX 78704John W. DailyLicense Renewal Project Manager (Safety)U.S. Nuclear Regulatory CommissionOne White Flint North (MS 011-Fl)Washington, DC 20555-0001Tam TranLicense Renewal Project Manager(Environmental)U. S. Nuclear Regulatory CommissionOne White Flint North (MS O11F01)Washington, DC 20555-0001A. H. Gutterman, EsquireKathryn M. Sutton, EsquireMorgan, Lewis & Bockius, LLPJohn RaganChris O'HaraJim von SuskilNRG South Texas LPKevin PolioRichard PenaCity Public ServicePeter NemethCrain Caton & James, P.C.C. MeleCity of AustinRichard A. RatliffAlice RogersTexas Department of State Health ServicesBalwant K. SingalJohn W. DailyTam TranU. S. Nuclear Regulatory Commission EnclosureNOC-AE-1 3002969Page 1 of 5STPNOC Response to Requests for Additional InformationSOUTH TEXAS PROJECT, UNITS 1 AND 2REQUEST FOR ADDITIONAL INFORMATION(TAC NOS. ME4936 AND ME4937)
Background:
On January 15, 2013, the U.S. Nuclear Regulatory Commission (NRC or the staff) held twopublic meeting sessions on the NRC's Supplement 48 to NUREG-1437, "GenericEnvironmental Impact Statement for License Renewal of Nuclear Plants" (SEIS), regarding thelicense renewal of South Texas Project (STP). During the evening session, a member of thepublic had a comment concerning wildlife management on the STP site. Consistent with 10CFR 51.91 (a)(1) and the staff's review criteria in the Standard Review Plan, the staff requestsadditional information to complete its review.Issue:The staff does not have sufficient information to verify the accuracy of the commentsconcerning wildlife management at STP. The comments are reproduced below from thetranscript:I want to thank the NRC staff for traveling all this way and giving us an opportunity toparticipate in this process.I'm a Matagorda County native and a business person here locally and a state-licensedwildlife rehabilitator. I live on a 65-acre ranch in Blessing, about eight miles from STP, andI run an animal sanctuary there as well.I really appreciate the opportunity to come and be heard during this scoping process. Ibelieve that accountability, transparency, and the right to challenge industry are veryimportant and that to question is every citizen's duty. I have several areas of this EIS that Iwould like to fundamentally disagree with and respectfully ask you to reconsider.I continually see and hear that STP is lauded as beneficial to local wildlife and habitat, andthat angle is accepted and incorporated into the EIS. This is not what I see as a localcitizen and one of only three licensed wildlife rehabilitators here in our county.I see a large corporation doing a great job of showing you and the public the good andbeneficial-to-them part of the picture.In reality, the contract granted by STP to deal with wildlife issues goes to the lowest bidder,currently GCA. GCA, as well as previous environmental contractors, requires itsemployees to destroy bird nests, eggs, and infant birds that nest on the site as part ofstandard housekeeping.
EnclosureNOC-AE-1 3002969Page 2 of 5These employees receive no training in applicable laws such as the Migratory Bird TreatyAct, no training on species identification, and don't even know what kind of avian lifethey're destroying.One year ago this week STP initiated a nuisance-bird eradication program, whereby seedwas set out for several days in a row to establish feeding stations on site, and then theseed was replaced with poison.This project was aimed primarily at several protected species of grackles that congregatein large numbers to overwinter on the Texas Gulf Coast. The poisons that are used areneurotoxic, and the animals that ingest them die a horrible death, often beating themselvesto death on the ground.Predator species such as hawks, eagles, and owls are drawn to the activity and, byingesting the tainted birds, they ingest the poisons as well. These are biocumulative in thefood chain.I got calls about several raptors on and around the STP site that week that were actingabnormally. One red-tail hawk was brought to my facility but could not be saved.I emailed S TP authorities before this poisoning took place and asked them to considerother options. They did not reply to my email, which is attached; I'll leave my commentshere.There are much more humane ways to keep the site free of unwanted birds, short of killingthem, though maybe none so inexpensive. These kinds of activities must be considered inthe scoping process, and we must acknowledge that fact, that profit supersedesenvironmental concerns.STP also regularly deals with mammals on site with lethal solutions, and when problemanimals are relocated, employees lack the training to recognize disease which may beinfectious, and they are not trained on the laws that pertain especially to our fur-bearingspecies.Our wildlife rehabilitation group has offered training to STP personnel at no expense butwere told and I quote "We are not ready to take it to that level." Additionally, STPregularly kills entire bee colonies that swarm on site. Honeybee numbers are in seriousdecline, and most of our food crops depend on their pollination.NRC Request:The staff requests information that addresses the validity of the comments reproduced abovein their entirety, and to include the following information:Provide information on how STP Nuclear Operating Company (STPNOC) ensuresgroundskeepers and wildlife management workers or contractors receive adequate trainingin applicable laws such as the Endangered Species Act, the Migratory Bird Treaty Act, andthe Bald and Golden Eagle Protection Act. Include information on how STPNOC ensures EnclosureNOC-AE-1 3002969Page 3 of 5that workers or contractors are trained and knowledgeable in identification of protectedspecies that are likely to occur on the South Texas site.STPNOC Response:STPNOC does not provide employees or contractors specific training on the EndangeredSpecies Act, the Migratory Bird Treaty Act or the Bald and Golden Eagle Protection Act.STPNOC does not provide employees training on identification of protected species thatare likely to occupy on the South Texas site.STPNOC uses the services of personnel that are licensed in their field of expertise asneeded. Examples include:* Janak Alligators LLC for relocating nuisance alligators and nest stamps,* United States Department of Agriculture (USDA) for wildlife damage managementunder a Non-Commercial Political Pesticide Applicators License,* Orkin Services for bee eradication under TPCL 71 OGG), and* Gulf Coast Wildlife Rescue -a permitted wildlife rehabilitator.NRC Request:If State-or Federally protected species are identified on the site during groundsmaintenance, what procedures do workers or contractors follow to ensure compliance withapplicable statutes?STPNOC Response:Site procedure OPGP03-ZO-0025, "Site Environmental Compliance," provides instructionsfor site workers on wildlife protection and control. The purpose of this procedure is toprovide guidelines necessary for site compliance with applicable non-radiologicalenvironmental laws, regulations, procedures, and commitments at the South Texas site.This procedure prohibits site personnel other than the licensed animal controller availableto the site or those individuals designated by the site Facilities Management Group fromengaging in wildlife protection and control measures or taking any action that may causeharm to any wildlife found on site. STPNOC uses the services of personnel that arelicensed in their field of expertise as needed. Examples of these service organizations areprovided in the preceding response.NRC Request:Does STPNOC or its contractors remove or destroy any bird nests, eggs, or infant birds aspart of site maintenance? Provide a description of the procedure that STPNOC or itscontractors follow for such activities. Include a description of any coordination with State orFederal agencies that would take place.
EnclosureNOC-AE-1 3002969Page 4 of 5STPNOC Response:Site procedure 0PGP03-ZO-0025, Site Environmental Compliance, provides instructionsfor site workers regarding bird's nests, eggs or infant birds. The procedure states "No sitepersonnel shall disturb, move or destroy an active bird nest, eggs, or young." Theprocedure also states "If young are inadvertently dislodged from a nest or found separatedfrom their nest, Facilities Management should be contacted and the young protected ifpossible until arrival of Facilities personnel." A permitted wildlife rehabilitator may beconsulted on specific instances. Local permitted wildlife rehabilitators are used for the careof injured or wounded birds.NRC Request:Clarify whether or not STPNOC has a "nuisance-bird eradication program." If such aprogram exists, please provide a description of the program and any informationaddressing the issues raised in the comments above, concerning the use of neurotoxins,targeting of protected grackle species, and indirect impacts to raptor species.STPNOC Response:STPNOC does not have a site nuisance-bird eradication program but has requestedassistance from the USDA Wildlife Services for wildlife damage management activitieswhen necessary. This includes bird depredation for the safety and protection of plantpersonnel and equipment. The bird depredation activities are performed on an as-neededbasis by the USDA at STPNOC's request to control the overpopulation of Blackbirdspecies, which could include the Common Grackle, that pose a health or safety hazard tosite employees and equipment. The services were performed from 2001-2005 and thendiscontinued until 2010. The services were performed again in 2010, 2011 and February2013. When services are requested, the USDA Animal and Plant Health Service monitorthe bird activity using a pre-bait to determine the number of target and non-target speciespresent. Once an acceptable location is determined, the USDA replaces the pre-bait withCompound DRC-1339; a slow-acting avicide registered for controlling certain species ofbirds that damage agricultural crops, personal property or prey upon federally-designatedthreatened or endangered species. DRC-1 339 rapidly degrades and has no documentedTMmortalities in raptors or scavenger mammals. STPNOC also uses Fog Force , which is abird repellent, during refueling outages when the personnel population onsite is at itsmaximum. STPNOC has used various bird deterrent measures in the past, includingfalcons, avian laser dispersal agents, butane cannons, deterrent bird spikes, plastic owls,bird screen netting and prey calls.NRC Request:* Provide a description of any wildlife management procedures or protocol related tomammals on site. Provide information addressing the issues raised in the commentsconcerning killing and relocating mammals and lack of employee training.
EnclosureNOC-AE-13002969Page 5 of 5STPNOC Response:Site procedure OPGP03-ZO-0025, "Site Environmental Compliance," contains a sectionrelating to wildlife protection and control. The procedure restricts handling of wildlife onsiteto the licensed animal controller or individuals designated by Facilities Management.Mammals found in areas that potentially pose a health or safety threat to employees orequipment are trapped and relocated.NRC Request:Provide information addressing the issue raised in the comments concerning killing beecolonies on the South Texas site. If this activity occurs, please provide details on thespecies targeted, the method of targeting, and any associated monitoring.STPNOC Response:The site eradicates bee colonies (swarms) when they are in populated areas that maypose a health and safety threat to employees or plant equipment. These bees areeradicated by a contracted Pest Controller or individuals designated by FacilitiesManagement. Bee colonies and swarms that do not pose a health or safety concern, suchas those in non-populated areas, are left undisturbed. Specific species are not targeted.NRC Request:* Provide any available information on STPNOC's past or current coordination or contact withState and Federal wildlife agencies for any on-site wildlife management activities.STPNOC Response:STPNOC uses State or Federal licensed personnel as needed for on-site wildlifemanagement activities. Examples include:* Janak Alligators LLC for alligator relocation and nest stamping and egg collection,* Orkin Services for bee eradication that pose a potential health or risk to personnelor equipment,* USDA for bird damage control activities if needed, and* Gulf Coast Wildlife Rescue for wildlife rehabilitation services.The USDA Natural Resources Conservation Service and the United States Fish andWildlife Service often participate in annual colonial water bird surveys onsite at STP.STPNOC also hosted the Texas Parks and Wildlife Department efforts in December 2010to capture, band, and identify various bird species onsite. There are no activities ongoingcurrently with State and Federal agencies regarding wildlife management.