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Safety

Evaluation

Report for an

Early Site

Permit (ESP'

at' the Exel on

Generation

Company, LILC

(EGC) ESP Sihe

U.S. Nuclear Regulatory Commission

Office of Nuclear Reactor Regulation

Washington, DC 20555-0001

May 2006

- I
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NUREG-1844

MSafety Evaluation Report for an

Early Site Permit (ESP)

at the Exelon Generation Company, LLC

(EGC) ESP Site

Manuscript Completed: February 2006

Date Published: May 2006

Division of New Reactor Licensing

Office of Nuclear Reactor Regulations

U.S. Nuclear Regulatory Commission

Washington, DC 20555-0001
IiI
ABSTRACT

This safety evaluation report (SER) documents the U.S. Nuclear Regulatory Commission (14RC)

staff's technical review of the site safety analysis report (SSAR) and emergency planning

information in the early site permit (ESP) application submitted by Exelon Generation Company,

LLC (E.GC or the applicant), for the EGC ESP site. By letter dated September 25, 2003, EXelon

submitted the ESP application for the EGC ESP site in accordance with Subpart A, "Early site

Permits," of Title 10 of the Code of Federal Regulations (10 CFR) Part 52, "Early Site Permits;

Standard Design Certifications; and Combined Licenses for Nuclear Power Plants." The EGC

ESP site is located approximately 6 miles east of the city of Clinton in central Illinois, and is

adjacent to an existing nuclear power reactor operated by AmerGen, which is a subsidiary of

Exelon Generation Company. In its application, EGC seeks an ESP that could support a future

application to construct and operate additional nuclear power reactors at the ESP site with a

total nuclear generating capacity of up to 6800 megawatts (thermal).

This SER presents the results of the staff's review of information submitted in conjunction with

the ESP application. The staff has identified, in Appendix A to this SER, certain site-related

items that will need to be addressed at the combined license or construction permit stage, il an

applicant desires to construct one or more new nuclear reactors on the EGC ESP site. The

staff determined that these items do not affect the staff's regulatory findings at the ESP stage

and ari, for reasons specified in Section 1.7, more appropriately addressed at later stages in

the licensing process. Appendix A to this SER also identifies the permit conditions that the staff

recommends the Commission impose, if an ESP is issued to the applicant.

iii
ii
CONTENTS

In accordance with U.S. Nuclear Regulatory Commission Review Standard (RS)-002,

"Processing Applications for Early Site Permits," the chapter and section layout of this safety

evaluation report is consistent with the format of (1) NUREG-0800, "Standard Review Plan bor

the Review of Safety Analysis Reports for Nuclear Power Plants," (2) Regulatory Guide 1.710,

"Standard Format and Content of Safety Analysis Reports for Nuclear Power Plants," and

(3) the applicant's site safety analysis report. Numerous sections and chapters in the

NUREG-0800 are not within the scope of or addressed in an early site permit (ESP)

proceeding. The reader will therefore note 'missing' chapter and section numbers in this

document. The subjects of chapters and sections in NUREG-0800 not addressed herein wl be

addressed, as appropriate and applicable, in other regulatory actions (design certification,

construction permit, operating license, and/or combined license) for a reactor or reactors that

might be constructed on the EGC ESP site.

ABSTRACT............................................................... iii

CONTENTS ............................................................... v

EXECUTIVE SUMMARY .................................................... xiv

ABBREVIATIONS ......................................................... xvii

1. INTRODUCTION AND GENERAL DESCRIPTION ............................. 1-1

1.1 Introduction ..................................................... 1-1

1.2 General Site Description ........................................... 1-4

1.3 Plant Parameter Envelope ......................................... 1-5

1.4 Identification of Agents and Contractors ............ ................... 1-7

1.5 Summary of Principal Review Matters ............. ................... 1-7

1.6 Summary of Open and Confirmatory Items ............................ 1-8

1.7 Summary of Combined License Action Items ......... .................. 1-9

1.8 Summary of Permit Conditions ....................................... 1-9

2. SITE CHARACTERISTICS ........................................... 2-1

2.1 Geography and Demography ....................................... 2-1

2.1.1 Site Location and Description . ................................ 2-1

2.1.2 Exclusion Area Authority and Control ......... ................. 2-4

2.1.3 Population Distribution . .................................... 2-7

2.2 Nearby Industrial, Transportation, and Military Facilities ............... ... 2-1 1

2.2.1-2.2.2 Identification of Potential Hazards in Site Vicinity ..... ........ 2-11

2.2.3 Evaluation of Potential Accidents ....... ...................... 2-15

v
2.3 Meteorology ............................................... 2-18

2.3.1 Regional Climatology ..................................... 2-18

2.3.2 Local Meteorology . ...................................... 2-34

2.3.3 Onsite Meteorological Measurements Program ..... ............ 2-40

2.3.4 Short-Term Diffusion Estimates ......... .................... 2-43

2.3.5 Long-Term Diffusion Estimates ......... .................... 2-49

2.4 Hydrologic Engineering ........................................... 2-56

2.4.1 Hydrologic Description ......................

2.4.2 Floods ..................................

2.4.3 Probable Maximum Flood on Streams and Rivers .

2.4.4 Potential Dam Failures ......................

2.4.5 Probable Maximum Surge and Seiche Flooding . . .

2.4.6 Probable Maximum Tsunami Flooding ..........

2.4.7 Ice Effects ...............................

2.4.8 Cooling Water Canals and Reservoirs ..........

2.4.9 Channel Diversions ........................

2.4.10 Flooding Protection Requirements ............ 2.4.11 Low-Water Considerations ..................

2.4.12 Ground Water ...........................

2.4.13 Accidental Releases of Liquid Effluents to Ground

Waters .................................

.............. .2-56

.............. .2-70

.............. .2-80

.............. .2-94

.............. 2-99

............. .2-104

............. .2-107

............. 2-127

............. 2-143

............. 2-146 ............. 2-149

............. 2-156

and Surface

............. 2-164

2.4.15 Thermal Discharges .......... 2-169

2.4.16 Site Characteristics Related to Hydrology .... ...... 2-175

2.5 Geology, Seismology, and Geotechnical Engineering ..... ..... 2-177

2.5.1 Site and Regional Geology .......... 2-177

2.5.2 Vibratory Ground Motions .......... 2-200

2.5.3 Surface Faulting .......... 2-273

2.5.4 Stability of Subsurface Materials and Foundations .......... 2-277

2.5.5 Stability of Slopes .......... 2-307

2.5.6 Embankments and Dams .......... 2-308

3. SITE SAFETY ASSESSMENT .......... 3-1

3.5.1.6 Aircraft Hazards .......... 3-1

11. RADIOLOGICAL EFFLUENT RELEASE DOSE CONSEQUENCES FROM NORMAL

OPERATIONS .......... 11-1

11.1 Source Terms .......... 11-1

vi
11.1.1 Technical Information in the Application ....... ............... 11-1

11.1.2 Regulatory Evaluation . ................................... 11-1

11.1.3 Technical Evaluation ................. ................... 11-1

11.1.4 Conclusion ............................................ 11-3

13. CONDUCT OF OPERATIONS ........................................... 13-1

13.3 Emergency Planning ........................................... 13-1

13.3.1 Significant Impediments to the Development of Emergency Plans . . 13-2

13.3.2 Contacts and Arrangements with Federal, State, and Local

Agencies ........................... 13-14

13.3.3 Major Features of the Emergency Plans .................... 13-17 I. 

13.6 Industrial Security . .............................................. 13-80

13.6.1 Technical Information in the Application ..................... 13-80

13.6.2 Regulatory Evaluation .................................. 13-81

13.6.3 Technical Evaluation ......... .......................... 13-81

13.6.4 Conclusions ............. ............................. 13-82

15. ACCIDENT ANALYSES ............ ......................... 15-1

15.1 Technical Information in the Application .............................. 15-1

15.2 Regulatory Evaluation ............................... 15-3

15.3 Technical Evaluation ............................... 15-4

15.3.1 Selection of DBAs .......................... 15-5

15.3.2 Design-Specific (Postulated) X/Q Values ..................... 15-5

15.3.3 Site-Specific X/Qs ....................................... 15-6

15.3.4 Source Terms and Radiological Consequence Evaluations .... ... 15-6

15.4 Conclusions . ................................................. 15-9

17. EARLY SITE PERMIT QUALITY ASSURANCE MEASURES ..... ............... 17-1

17.1 Introduction . .................................................... 17-1

17.1.1 Technical Information in the Application (Organization) .... ....... 17-2

17.1.2 Regulatory Evaluation .................................... 17-3

17.1.3 Technical Evaluation ..................................... 17-3

17.1.4 Conclusion . ........................................... 17-4

*17.2 Quality Assurance Program ...................................... I 7-4

17.2.1 Technical Information in the Application (QA Program) .... ...... 17-4

17.2.2 Regulatory Evaluation ................................... 17-5

17.2.3 Technical Evaluation .................................... 17-5

vii
17.2.4 Conclusion ........... 17-7

17.3 Design Control ............. 17-7

17.3.1 Technical Information in the Application (Design Control) .... .... 17-7

17.3.2 Regulatory Evaluation ................................... 17-8

17.3.3 Technical Evaluation .................................... 17-8

17.3.4 Conclusion ............. ............................... 17-9

17.4 Procurement Document Control .................................. 17-10

17.4.1 Technical Information in the Application (Procurement Document

Control) ............. ................................ 17-10

17.4.2 Regulatory Evaluation .................................. 17-10

17.4.3 Technical Evaluation ................................... 17-10

17.4.4 Conclusion ............ ............................... 17-11

17.5 Instructions, Procedures, and Drawings ............................ 17-11

17.5.1 Technical Information in the Application (Instructions, Procedures,

and Drawings) ......... 17-11

17.5.2 Regulatory Evaluation ......... 17-12

17.5.3 Technical Evaluation ......... 17-12

17.5.4 Conclusion ......... 17-13

17.6 Document Control ......... 17-13

17.6.1 Technical Information in the Application (Document Control) ..... 17-13

17.6.2 Regulatory Evaluation ......... 17-14

17.6.3 Technical Evaluation ......... 17-14

17.6.4 Conclusion ......... 17-15

17.7 Control of Purchased Material, Equipment, and Services ...... ... 17-15

17.7.1 Technical Information in the Application (Control of Purchased

Material, Equipment, and Services) ....... ................. 17-15

17.7.2 Regulatory Evaluation ............. ..................... 17-16

17.7.3 Technical Evaluation ............... .................... 17-16

17.7.4 Conclusion ........................................... 17-20

17.8 Identification and Control of Materials, Parts, and Components .... ...... 17-20

17.8.1 Technical Information in the Application (Identification and Control

of Materials, Parts, and Components) ...... ................ 17-20

17.8.2 Regulatory Evaluation ............. ..................... 17-21

17.8.3 Technical Evaluation ............... .................... 17-21

17.8.4 Conclusion ........................................... 17-21

viii
17.9. Control of Special Processes .................................... 17-22

17.9.1 Technical Information in the Application (Control of Special

Processes) .............. .............................. 17-22

17.9.2 Regulatory Evaluation .................................. 17-22

17.9.3 Technical Evaluation ................................... 17-23

17.9.4 Conclusion ........................................... 17-23

17.10 Inspection . ................................................. 17-23

17.10.1 Technical Information in the Application (Inspection) .... ...... 17-23

17.10.2 Regulatory Evaluation ................................. 17-23

17.10.3 Technical Evaluation .................................. 17-24

17.10.4 Conclusion .......................................... 17-24

17.11 Test Control ............... I ................................. 17-24

17.11.1 Technical Information in the Application (Test Control) .... .... 17-24

17.11.2 Regulatory Evaluation ................................. 17-25

17.11.3 Technical Evaluation .................................. 17-25

17.11.4 Conclusion ............ .............................. 17-26

17.12 Control of Measuring and Test Equipment ......................... 17-27

17.12.1 Technical Information in the Application (Control of M&TE) ..... 17-27

17.12.2 Regulatory Evaluation .................................. 17-27

17.12.3 Technical Evaluation ................................... 17-27

17.12.4 Conclusion .......................................... 17-28

17.13 Handling, Storage, and Shipping ................................ 17-28

17.13.1 Technical Information in the Application (Handling, Storage,

and Shipping) ... .. 17-28

17.13.2 Regulatory Evaluation ........ 17-29

17.13.3 Technical Evaluation ........ 1-7-29

17.13.4 Conclusion ........ 17-29

17.14 Inspection, Test, and Operating Status ........ 17-29

17.14.1 Technical Information in the Application (Inspection, Test, and

Operating Status) ........... 17-29

17.14.2 Regulatory Evaluation ........... 17-30

17.14.3 Technical Evaluation ........... 1.7-30

17.14.4 Conclusion ........... 1,7-31

17.15 Nonconforming Materials, Parts, or Components ..... ...... 1.'-31

ix
17.15.1 Technical Information in the Application (Nonconforming

Materials, Parts, or Components) ........................ 17-31

17.15.2 Regulatory Evaluation ......... ........................ 17-31

17.15.3 Technical Evaluation ......... ......................... 17-32

17.15.4 Conclusion .......................................... 17-32

17.16 Corrective Action ............ ................................ 17-32

17.16.1 Technical Information in the Application (Corrective Action) ..... 17-32

17.16.2 Regulatory Evaluation ................................. 17-33

17.16.3 Technical Evaluation .................................. 17-33

17.16.4 Conclusion .......................................... 17-34

17.17 Quality Assurance Records ..................................... 17-34

17.17.1 Technical Information in the Application (Quality Assurance

Records) ........... ................................ 17-34

17.17.2 Regulatory Evaluation ................................. 17-35

17.17.3 Technical Evaluation .................................. 17-35

17.17.4 Conclusion ........... ............................... 17-37

17.18 Audits . .................................................... 17-37

17.18.1 Technical Information in the Application (Audits) ..... ........ 17-37

17.18.2 Regulatory Evaluation ................................. 17-37

17.18.3 Technical Evaluation .................................. 17-38

17.18.4 Conclusion .......................................... 17-40

17.19 Conclusions . ................................................ 17-40

18. REVIEW BY THE ADVISORY COMMITTEE ON REACTOR SAFEGUARDS .. 18-1

19. CONCLUSIONS .. 19-1

Appendices

Appendix A - Permit Conditions, COL Action Items, Site Characteristics, and Bounding

Parameters .......................................................... A-1

Appendix B - Chronology of Early Site Permit Application for the EGC ESP Site .... ..... B-1

Appendix C - References . .................................................. C-1

Appendix D - Principles Contributors ............. .............................. D-1

x
Figures

2.2.1-l Industrial Facilities in the Vicinity of the ESP Site .......................... 2-12

2.4-1 Clinton Lake ............ 2-57

2.4-2 CPS once-through discharge and subsequent mixing and cooling path .... ...... 2-58

2.4-3 Proposed locations of ESP facility UHS intake and discharge ..... ............ 2-59

2.4-4 The watershed draining into Clinton Lake, delineated manually using topographic

contours . ........................................................ 2-64

2.4-5 Depth-area-duration curves prepared for bracketing Clinton Dam drainage. The dotted

horizontal line corresponds to a drainage area of 289.2 mi , equal to that of Clinton

Dam's drainage area. ................................................ 2-85

2.4-6 Inflow and outflow from Clinton Lake during the PMF event calculated using the

instantaneous-translation level-pool routing method ........................ 2-88

2.4-7 Water surface elevation in Clinton Lake during the PMF event calculated using the

instantaneous-translation level-pool routing method ........................ 2-89

2.4-8 Inflow and outflow Hydrographs for Clinton Lake during the PMF event using the HECHMS model and the seven sub-basins + lake method ....................... 2-91

2.4-9 Water surface elevation of Clinton Lake during the PMF event using the HEC-HMS

model and the seven sub-basins + lake method ........................... 2-92

2.4-10 Dawson Lake and Dam located approximately 17.1 miles north-northeast of the ESP

site. Dawson Lake is located on the North Fork of Salt Creek ................. 2-98

2.4-11 Clinton Power Station site and fetch length .............................. 2-103

2.4-12 Stage-discharge relationship for Salt Creek at Rowell, IL .................... 2-115

2.4-13 Accumulated degree-days since December 1, 1977, at the Decatur meteorologic

station . .......................................................... 2-116

2.4-14 AFDD during 1977-78 as calculated by Engineering Research and Development

Center, Hanover, New Hampshire. .................................... 2-122

2.4-15 Figure 2.4-15 The proposed facility boundary for the ESP site . .............. 2-176

2.5.1-1 Major structural features in Illinois and neighboring States ..... ............ 2-181

2.5.1-2 Schematic diagram showing the Reelfoot scarp and selected features in the area

of the NMSZ . ..................................................... 2185

2.5.1-3 Central fault system of NMSZ ....................................... 2-187

2.5.1-4 Historical seismicity and estimated centers of large prehistoric earthquakes in

site region . ...................................................... 2-189

2.5.1-5 Map showing surveyed stream banks and evidence for paleoliquefaction in the

site vicinity . ...................................................... 2-191

2.5.2-1 Updates to seismicity catalog ........................................ 2-202

2.5.2-2 Reference earthquake response spectra for mean 104 and mean 10 5 hazard . . 2-212

2.5.2-3 Deaggregation results for mean 1 0-4hazard ............................ 2-215

2.5.2-4 Mean site amplification functions for deaggregation earthquakes and weighted

average site amplification functions for reference earthquakes for mean 1 04

hazard . .......................................................... 2-217

2.5.2-5 Rock reference earthquake spectra scaled by weighted average site amplification

functions and soil envelope spectra ..................................... 2-219

2.5.2-6 Comparison of performance-based SSE spectrum for the ESP site and the mean

'l0 and 105 UHRS ................................................ 2-222

xi
2.5.2-7 Four mean seismic hazard curves (1 Hz, 2.5 Hz, 5 Hz, and 10 Hz) for EGC ESP site

plotted on a log-log scale. Dashed lines indicate annual probability of exceedance

intervals of 1 O'4per year and 1 05 per year. .............................. 2-224

2.5.2-8 Lognormal PDF for different values of the lognormal standard deviation value, b 2-226

2.5.2-9 Lognormal CDF for different values of the lognormal standard deviation value, b. 2-227

2.5.2-10 Significant parameter and quantile values for lognormal PDF, including the

HCLPF value ............ ........................................ 2-228

2.5.2-11 Significant parameter and quantile values for lognormal CDF, including the

HCLPF value . ................................................... 2-229

2.5.2-12 EGC ESP 5-Hz mean seismic hazard curve and seismic fragility curve in terms of the

lognormal PDF .............. ..................................... 2-232

2.5.2-13 Product of EGC ESP 5-Hz mean seismic hazard curve and seismic fragility

curve. .............. ........................................... 2-233

2.5.2-14 Comparison of exact and approximate DF. Exact DFvaries with both AR and b,

while approximate DFdepends only on AR ................... 2-237

2.5.2-15 Seismic core damage in terms of mean ground motion recurrence interval for

25 nuclear power plants.. 2-241

2.5.2-16 EGC ESP horizontal and vertical ESP SSE as well as the RG 1.60 DRS

anchored at 0.3g ....................... ........................... 2-243

2.5.2-17 Seismic core damage in terms of mean ground motion recurrence interval for EGC

ESP site and 25 nuclear power plants. ................................. 2-266

2.5.2-18 Comparison of UHRS104 with estimated ground motion response spectra for the

Springfield earthquake ............................................. 2-271

2.5.4-1 Site-specific geologic cross section ................................... 2-278

2.5.4-2 G/Gmax plot resonant column and cyclic torsion test results ..... ............ 2-281

2.5.4-3 Material damping plot resonant column and cyclic torsion test results .... ..... 2-282

2.5.4-4 EGC ESP geotechnical investigation locations .......................... 2-285

2.5.4-5 S- and P-wave velocities and other soil properties ........................ 2-288

2.5.4-6 Modulus reduction and damping test results compared to EPRI (1993) soil

property curves for test UTA-34-A ..................................... 2-299

Tables

2.3.1-1 Applicant's Proposed Tornado Site Characteristics ........................ 2-21

2.3.1-2 Applicant's Proposed Basic Wind Speed Site Characteristic ..... ............ 2-22

2.3.1-3 Applicant's Proposed Winter Precipitation Site Characteristics ..... .......... 2-23

2.3.1-4 Applicant's Proposed Ultimate Heat Sink Meteorological Site Characteristics .... 2-24

2.3.1-5 Applicant's Proposed Ambient Air Temperature and Humidity Site Characteristics 2-25

2.3.1-6 Staff's Proposed Regional Climatology Site Characteristics .................. 2-31

2.3.4-1 Applicant's Proposed Short-Term (Accident Release) Atmospheric Dispersion

Site Characteristics ................................................. 2-46

2.3.4-2 Staff's Proposed Short-Term (Accident Release) Atmospheric Dispersion

Site Characteristics ................................................. 2-48

2.3.5-1 Applicant's Long-Term (Routine Release) Diffusion Estimates ............... 2-50

xii
2.3.5-2 Staff's Proposed Long-Term (Routine Release) Atmospheric Dispersion

Site Characteristics ................................................. 2-53

2.4-1 P're-dam and Post-dam Floods Corresponding to Several Return Periods Estimated

According to NRC Guidelines ......................................... 2-75

2.4-2 L.ocal Intense Precipitation (1-mi 2 PMP) at the Early Site Permit Site .... ........ 2-76

2.4-3 [IMP Values in Inches Near Clinton Dam's Drainage Area .................... 2-85

2.4-4 PMP Depth-Duration Values in Inches for Clinton Dam's Drainage Area .... ..... 2-86

2.4-5 Iime Distribution of PMP for Clinton Dam's Drainage Area ................... 2-86

2.4-6 summary of Maximum PMF Water Surface Elevations (ft MSL) at the ESP Site ... 2-93

2.4-7 Proposed Site Characteristics Related to Hydrology ....................... 2-175

2.5.1-1 Updated Magnitude Distributions for Characteristic New Madrid Earthquakes ... 2-197

2.5.2-1 High- and Low-Frequency Controlling Earthquakes ....................... 2-211

2.5.2-2 Controlling and Deaggregation Earthquakes ............................ 2-216

2.5.2-3 Computation of the Horizontal SSE Spectrum for the ESP Site .... .......... 2-221

2.5.2-4 Comparison of Performance-Based SSE Values ......................... 2-263

2.5.2-5 Unacceptable Performance Frequency Values for /Jfrom 0.3 to 0.6 Values .... 2-264

2.5.2-6 SCDF Values for Clinton Performance-Based SSE ....................... 2-265

2.5.2-7 High- and Low-Frequency Controlling Earthquakes ....................... 2-269

3.5.1.6 1 Public Airports in the Vicinity of the Proposed ESP Site .................... 3-5

3.5.1.6 2 Probability of Aircraft Impacts from Federal Airways ....................... 3-5

13.3-1 State of Illinois Dose Limits for Emergency Workers ....................... 1:3-66

15.3-1 AP100O X/Q Values (s/M3) ............................................ 15-6

15.3-2 Site-Specific X/Q Values .............................................. 15-9

xiii
EXECUTIVE SUMMARY

Title 10 of the Code of Federal Regulations (10 CFR) Part 52, "Early Site Permits; Standard

Design Certifications; and Combined Licenses for Nuclear Power Plants," contains

requirements for licensing new nuclear power plants.' These regulations address early site

permits (ESPs), design certifications, and combined licenses (COLs). The ESP process

(10 CFR Part 52, Subpart A, "Early Site Permits") is intended to address and resolve siterelated issues. The design certification process (10 CFR Part 52, Subpart B, 'Standard Design

Certifications") provides a means for a vendor to obtain U.S. Nuclear Regulatory Commission

(NRC) certification of a particular reactor design. Finally, the COL process (10 CFR Part 52,

Subpart C, "Combined Licenses") allows an applicant to seek authorization to construct and

operate a new nuclear power plant. A COL may reference an ESP, a certified design, both, or

neither. It is incumbent on a COL applicant to resolve issues related to licensing that were not

resolved as part of an ESP or design certification proceeding before the NRC can issue a COL.

This safety evaluation report (SER) describes the results of a review by the NRC staff of an

ESP application submitted by Exelon Generation Company, LLC (EGC or the applicant), for the

Exelon Generation Company ESP site. The staff's review verified the applicant's compliance

with the requirements of Subpart A of 10 CFR Part 52. This SER serves to identify the matters

resolved in the safety review and to identify remaining items to be addressed by a future COL

applicant.

The NRC regulations also contain requirements for an applicant to submit an environmental

report pursuant to 10 CFR Part 51, "Environmental Protection Regulations for Domestic

Licensing and Related Regulatory Activities." The NRC reviews the environmental report as

part of the Agency's responsibilities under the National Environmental Policy Act of 1969, as

amended. The NRC presents the results of that review in a final environmental impact

statement, which is a report separate from this SER.

By letter dated September 25, 2003, EGC submitted an ESP application (ADAMS2 -'

Accession No. ML032721596) for the EGC ESP site. The EGC ESP site is located in DeWitt

County in east-central Illinois about 6 miles east of the city of Clinton. The site is located

between the cities of Bloomington and Decatur to the north and south, respectively, and Lincoln

'Applicants may also choose to seek a construction permit and operating license in accordance with

10 CFR Part 50, "Domestic Licensing of Production and Utilization Facilities," instead of using the 10 CFR Part 52

process.

2ADAMS (Agencywide Documents Access and Management System) is the NRC's information system. It

provides access to all image and text documents that the NRC has made public since November 1, 1999, as well as

bibliographic records (some with abstracts and full text) that the NRC made public before November 1999.

Documents available to the public may be accessed via the Internet at

http://www.nrc.pov/readinc-rm/adams/web-based.html. Documents may also be viewed by visiting the NRC's Public

Document Room at One White Flint North, 11555 Rockville Pike, Rockville, Maryland. Telephone assistance for

using Web-based ADAMS is available at (800) 397-4209 between 8:30 a.m. and 4:15 p.m., eastern standard time,

Monday through Friday, except Federal holidays. The staff is also making this DSER available on the NRC's new

reactor licensing public Web site at http://www.nrc.aov/reactors/new-licensina/esp/clinton.html.

xiv
and Champaign-Urbana to the west and east, respectively, and is adjacent to an existing

nuclear power reactor, Clinton Power Station, operated by AmerGen Energy Company, LLC

(AmerGen).

In accordance with 10 CFR Part 52, Exelon submitted an ESP application that includes (1) a

description of the site and nearby areas that could affect or be affected by a nuclear power

plant(s) located at the site, (2) a safety assessment of the site on which the facility would be

located, including an analysis and evaluation of the major structures, systems, and components

of the facility that bear significantly on the acceptability of the site, and (3) the proposed major

features of an emergency plan. The application describes how the site complies with the

requirements of 10 CFR Part 52 and the siting criteria of 10 CFR Part 100, "Reactor Site

Criteria." 3

This SER presents the conclusions of the staff's review of information the applicant submitted

to the NRC in support of the ESP application. The staff has reviewed the information provided

by the applicant to resolve the open and confirmatory items identified in the draft safety

evaluation report (DSER) and the supplemental DSER for the EGC ESP. In Section 1.6 of this

SER, tie staff provides a brief summary of the process used to resolve these items; details of

the resolution for each open item are presented in the corresponding section of this report.

The staff has identified, in Appendix A to this SER, the proposed permit conditions that it will

recommend the Commission impose if an ESP is issued to the applicant. Appendix A also

includes a list of COL action items or certain site-related items that will need to be addressed at

the COL or construction permit stage, if an applicant desires to construct one or more new

nuclear reactors on the EGC ESP site. The staff determined that these items do not affect -the

staff's regulatory findings at the ESP stage and are, for reasons specified in Section 1.7, more

appropriately addressed at these later stages in the licensing process. In addition, Appendix A

lists the site characteristics and the bounding parameters identified by the staff for this site.

Inspections conducted by the NRC have verified, where appropriate, the conclusions in this

SER. 1The inspections focused on selected information in the ESP application and its

references. This SER identifies applicable inspection reports as reference documents.

The NRC's Advisory Committee on Reactor Safeguards (ACRS) also reviewed the bases foe

the con clusions in this report. The ACRS independently reviewed those aspects of the

application that concern safety, as well as the safety evaluation report, and provided the results

of its review to the Commission in the interim report dated September 22, 2005, and in a final

report dated March 24, 2006. This SER incorporates the ACRS comments and

The applicant has also submitted information intended to partially address some of the general design criteria (GDC) in Appendix A, "General Design Criteria for Nuclear Power Plants," to 10 CFR Part 50, 'Domestic

Licensing of Production and Utilization Facilities." Only GDC 2, 'Design Bases for Protection Against Natural

Phenomena," applies to an ESP application, and it does so only to the extent necessary to determine the safeshutdown earthquake (SSE) and the seismically induced flood. The staff has explicitly addressed partial compliance

with GDC 2, in accordance with 10 CFR 52.17(a)(1) and 10 CFR 50.34(a)(12), only in connection with the applicant's

analysis cf the SSE and the seismically induced flood. Otherwise, an ESP applicant need not demonstrate

compliance with the GDC. The staff has included a statement to this effect in those sections of the SER that do not

relate to the SSE or the seismically induced flood. Nonetheless, this SER describes the staff's evaluation of

information submitted by the applicant to address GDC 2.

xv
recommendations, as appropriate. Appendix E includes a copy of the report by the ACRS on

the final safety evaluation report, as required by 10 CFR 52.23, "Referral to the ACRS."

xvi
ABBREVIATIONS

ABWR Advanced Boiling Water Reactor

ac acre(s)

ACR-700 Advanced CANDU Reactor

ACRS Advisory Committee on Reactor Safeguards

ADAMS' Agencywide Documents Access and Management System

AFDD accumulated freezing degree days

ALARA as low as is reasonably achievable

ALI annual limits on intake

ALWR advanced light water reactor

ANS American Nuclear Society or alert notification system

ANSI American National Standards Institute

ANSS Advanced National Seismic System

AP1 00() Advanced Plant 1000

ASCE American Society of Civil Engineers

ASME American Society of Mechanical Engineers

ASTM American Society for Testing and Materials

AT area type

BA Blytheville arch

BP before present

BWR boiling water reactor

CAR corrective action report

CDF core damage frequency

CEUS central and eastern United States

CFR Code of Federal Regulations

cfs cubic feet per second

CGL commerce geophysical lineament

COL combined license

CP construction permit

CPS Clinton Power Station

CPT cone penetrometer test

CRR cyclic resistance ratio

CRREL Cold Regions Research and Engineering Laboratory

CSR cyclic stress ratio

DAC derived air concentration

DBA design-basis accident

DCD design control document

DCM document control manager

DCO dosimetry control officer

DEIS draft environmental impact statement

DF design factor

DOE U.S. Department of Energy

DRS design response spectrum

DSER draft safety evaluation report

EAB exclusion area boundary

EAS emergency alert system

ECO exposure control officer

xvii
EGC Exelon Generation Company

EIS environmental impact statement

ENS Emergency Notification System

EOC emergency operations center

EOF emergency operations facility

EPA U.S. Environmental Protection Agency

EPRI Electric Power Research Institute

EPZ emergency planning zone

ER environmental report

ERDC U.S. Army Engineering Research and Development Center

ERDS Emergency Response Data System

ERF emergency response facility

ERO emergency response organization

ESBWR Economic and Simple Boiling Water Reactor

ESDA DeWitt County Emergency Services and Disaster Agency.

ESP early site permit

ESW emergency service water

ETE evacuation time estimate

FAA Federal Aviation Administration

FAFC Fluorspar Area fault complex

FBI Federal Bureau of Investigation

FEMA Federal Emergency Management Agency

FDD freezing degree days

FOS factor of safety

FOSID frequency of onset of significant inelastic deformation

fps feet per second

FRERP Federal Radiological Emergency Response Plan

FSER final safety evaluation report

ft feet

GDC general design criterion/criteria

GIS geographic information system

gpm gallons per minute

GPS global positioning system

GRL GRL Engineers, Inc.

GT-MHR Gas Turbine Modular Helium Reactor

HCLPF high-confidence-low-probability-of-failure

HEC Hydrologic Engineering Center

HMR Hydrometeorological Report

HPN health physics network

Hz Hertz

IDNR Illinois Department of Natural Resources

IDNS Illinois Department of Nuclear Safety

IDOT Illinois Department of Transportation

IDOW Illinois Division of Waterways

IDPH Illinois Department of Public Health

IEMA Illinois Emergency Management Agency

ILCS Illinois Complied Statute

INEEL Idaho National Engineering and Environmental Laboratory

xviii
IPRA Illinois Plan for Radiological Accidents

IRIS International Reactor Innovative and Secure

ISCO Illinois State Climatologist Office

ISGS Illinois State Geologic Survey

ISP Illinois State Police

ISWS Illinois State Water Survey

KI potassium iodide

Ibf/ft2 pounds-force per square foot

LLNL Lawrence Livermore National Laboratory

LOCA loss-of-coolant accident

LOOP loss of offsite power

LPZ low population zone

LWR light-water reactor

M magnitude

M&TE measuring and test equipment

m/hr mile(s) per hour

m/s meter(s) per second

Mb body wave magnitude

mi mile(s)

mph mile(s) per hour

MSF magnitude scaling factor

msl mean sea level

Mw moment magnitude

MW megawatt

MWe megawatt electric

MWRCIG Mid-west Regional Operating Group

MWt megawatt thermal

mya million years ago

NARS nuclear accident reporting system

NCDC National Climatic Data Center

NCEER National Center for Earthquake Engineering Research

NEI Nuclear Energy Institute

NHS normal heat sink

NMSZ New Madrid seismic zone

NN New Madrid north

NOAA National Oceanic and Atmospheric Administration

NOS Nuclear Oversight Department (Exelon)

NPHS normal plant heat sink

NRC U.S. Nuclear Regulatory Commission

NS New Madrid south

NSSL National Severe Storms Laboratory

NWS National Weather Service

OBE operating-basis earthquake

OCA owner controlled area

OL operating license

OSC operations support center

OSID onset of significant inelastic deformation

PA protected area or public address

xix
PAG protective action guide

PBMR Pebble Bed Modular Reactor

PDF probability density function

PGA peak ground acceleration

PMF probable maximum flood

PMP probable maximum precipitation

PMWP probable maximum winter precipitation

PMWS probable maximum windstorm

PNNL Pacific Northwest National Laboratories

PPE plant parameter envelope

PQP project quality plan

PRA probabilistic risk assessment

PSHA probabilistic seismic hazard analysis

QA quality assurance

QMS quality management system

R roentgen

RAFT radiological assessment field team

RAI request for additional information

RCTS resonant column and torsional shear

REAC/TS Radiation Emergency Assistance Center/Training Site (DOE)

RF Reelfoot fault

RG regulatory guide

Rp reference probability

RPM radiation protection manager

RS review standard

RTM NRC's Response Technical Manual, Revision 4

S shear

S&L Sargent & Lundy

Sa spectral acceleration

SCDF seismic core damage frequency

SCR stable continental region

SCS Soil Conservation Service

SEI Structural.Engineering Institute

SEOC State emergency operations center

SER safety evaluation report

SFCP State forward command post

SOG Seismic Owners Group

SOP standard operating procedure

SPF standard project flood

SPS standard project storm

SPT standard penetration test

SRM staff requirements memorandum

SRP Standard Review Plan

SSAR site safety analysis report

SSC structure, system, and component

SSE safe-shutdown earthquake

SSI soil-structure interaction

TEDE total effective dose equivalent

xx
TID technical information document

TIGER Topologically Integrated Geographic Encoding and Referencing System

TLD thermoluminescent dosimetry

TN technical note

TSC Testing Services Corporation or technical support center

UFSAR updated final safety analysis report

UHRS uniform hazard response spectrum

UHS ultimate heat sink

USACE U.S. Army Corps of Engineers

USAR updated safety analysis report

USBR U.S. Bureau of Reclamation

USGS U.S. Geological Survey

UT University of Texas

UTM Universal Transverse Mercator

V/H vertical-to-horizontal

V&V verification and validation

Vp compressional wave velocity

Vs shear wave velocity

WRC Water Resources Council

WVFS Wabash Valley fault system

WVSZ Wabash Valley/Southern Illinois seismic zone

xxi

1. INTRODUCTION AND GENERAL DESCRIPTION

1.1 Introduction

Exelon Generation Company, LLC (EGC or the applicant), filed an application with the U.S.

Nuclear Regulatory Commission (NRC), docketed on October 27, 2003, for an early site permit

(ESP) for a site the applicant designated as the EGC ESP site. EGC requested an ESP with a

permit duration of 20 years pursuant to Subpart A, "Early Site Permits," of Title 10 of the Code

of Federal Regulations (10 CFR) Part 52, "Early Site Permits; Standard Design Certificatiors;

and Combined Licenses for Nuclear Power Plants." The proposed site is located approximately

6 miles east of the city of Clinton in east-central Illinois.

Exelon states that the purpose of its application for an ESP is to set aside the proposed site for

future energy generation and sale on the wholesale energy market. This site would be

reserved for a nuclear facility to be operated as a merchant generator plant. In addition, a

component of the site redress plan supports a (limited work) authorization for approval of

construction activities in accordance with 10 CFR 50.10(e)(1) and 10 CFR 52.17(c).

The staff has completed its review in the areas of the site seismology, geology, meteorology,

and hydrology, as well as of hazards to a nuclear power plant that could result from man-made

facilities and activities on or in the vicinity of the site. The staff also assessed the risks of

potential accidents that could occur as a result of the operation of a nuclear plant(s) at the site

and evaluated whether the site would support adequate physical security measures for a

nuclea' power plant(s). The staff evaluated whether the applicant's quality assurance

measures were equivalent in substance to the measures discussed in Appendix B, "Quality

Assurance Criteria for Nuclear Power Plants and Fuel Reprocessing Plants," to 10 CFR

Part 5C, "Domestic Licensing of Production and Utilization Facilities." The NRC found that the

applicant's measures provide reasonable assurance that the ESP information that could be

used in the design and/or construction of structures, systems, and components (SSCs)

important to safety would support satisfactory performance of such SSCs once they were in

service. The staff also evaluated the adequacy of the applicant's program for compliance with

10 CFF1 Part 21, "Reporting of Defects and Noncompliance." Finally, the staff reviewed the

proposed major features of the emergency plan that EGC would implement if new reactor

unit(s) is eventually constructed at the ESP site. The NRC will review the complete and

integrated emergency plan in a separate licensing action.

The EGC ESP application includes the site safety analysis report (SSAR), which describes the

safety assessment of the site, as required by 10 CFR 52.17, "Contents of Applications." The

public may inspect the ESP application via the Agencywide Documents Access and

Management System (ADAMS) under ADAMS Accession No. ML032721596.4 EGC

"ADAMS (Agencywide Documents Access and Management System) is the NRC's information system. It

provides access to all image and text documents that the NRC has made public since November 1, 1999, as well as

bibliographic records (some with abstracts and full text) that the NRC made public before November 1999.

Documents available to the public may be accessed via the Internet at

http://www.nrc.pov/readinp-rm/adams/web-based.html. Documents may also be viewed by visiting the NRC's Public

Documert Room at One White Flint North, 11555 Rockville Pike, Rockville, Maryland. Telephone assistance for

using Web-based ADAMS is available at (800) 397-4209 between 8:30 a.m. and 4:15 p.m., eastern standard time,

Monday through Friday, except Federal holidays. The staff is also making this SER available on the NRC's new

1-1
subsequently revised its application to address requests from the NRC staff for additional

information. The applicant submitted the most recent version, SSAR Revision 4 (application),

to the Commission on April 14, 2006 (ADAMS Accession No. ML061100260).

Appendix B to this report provides a chronological list of the licensing correspondence between

the applicant and the Commission regarding the review of the EGC ESP application under

Project No.718 and Docket No. 52-007. The application and other pertinent information and

materials are available for public inspection at the NRC's Public Document Room at One White

Flint North, 11555 Rockville Pike, Rockville, Maryland. The application and this safety

evaluation report (SER) are also available at the Vespasian Warner Public Library, 310 North

Quincy Street, Clinton, Illinois, as well as on the NRC's new reactor licensing public Web site at

http://www.nrc.gov/reactors/new-licensinp/esp/clinton.html. This SER is also available in

ADAMS under Accession No. ML060470383.

This SER summarizes the results of the staff's technical evaluation of the suitability of the

proposed EGC ESP site for construction and operation of -a nuclear power plant(s) within the

plant parameter envelope (PPE) that EGC specified in its application. This SER delineates the

scope of the technical matters that the staff considered in evaluating the suitability of the site.

NRC Review Standard (RS)-002, "Processing Applications for Early Site Permits,"

Attachment 2, provides additional details on the scope and bases of the staff's review of the

radiological safety and emergency planning aspects of a proposed nuclear power plant site.

RS-002, Attachment 2, contains regulatory guidance based on NUREG-0800, "Standard

Review Plan for the Review of Safety Analysis Reports for Nuclear Power Plants" (hereafter

referred to as the SRP). The SRP reflects the staff's many years of experience in establishing

and promulgating guidance to enhance the safety of nuclear facilities and in evaluating safety

assessments. In addition, this SER documents the resolution of the open and confirmatory

items identified in the draft safety evaluation report (DSER) for the EGC ESP, issued on

February 10, 2005.

In the DSER, the NRC identified Confirmatory Item 1.1-1 to verify that EGC's future revision of

its ESP application is consistent with the information provided in its requests for additional

information (RAls) responses. Throughout the course of the review, the staff requested that the

applicant submit additional information to clarify the description of the EGC ESP site. This

report discusses some of the applicant's responses to these RAls. The staff reviewed the

revisions of the EGC ESP application, up to and including Revision 2 of the SSAR, and

determined that the ESP application is consistent with the information provided in its RAI

responses. Therefore, the staff considers DSER Confirmatory Item 1.1-1 to be resolved.

At the time the DSER was issued, the staff had not completed its review in the areas of

seismology and geology. In the DSER, the staff identified Confirmatory Item 1.1-2 for issuance

of a supplemental DSER at a later date to summarize the results of its technical evaluation of

the suitability of the proposed EGC ESP site with respect to the site's seismology and geology.

The supplemental DSER was issued on August 26, 2005 (ADAMS Accession

No. ML052310459). Therefore, the staff considers Confirmatory Item 1.1-2 to be resolved.

reactor licensing public Web site at http:y/www.nrc.cov/reactors/new-licensina/esp/north-anna.html.

1-2
The applicant also filed an environmental report for the EGC ESP site in which it evaluated

those matters relating to the environmental impact assessment that can be reasonably

reviewed at this time. The staff discussed the results of its evaluation of the environmental

report for the EGC ESP site in a draft environmental impact statement (DEIS) issued on

March 2, 2005 (ADAMS Accession No. ML050610364). The applicant also provided a site

redress plan, in accordance with 10 CFR 52.17(c), for performing the site preparation and

limited construction activities allowed by 10 CFR 52.25(a) (i.e., the activities listed in 10 CFR

50.10(e)(1)). The DEIS also includes the results of the staff's evaluation of that plan.

As described above, the applicant supplemented the information in the SSAR by providing

revisions to the document. The staff reviewed these revisions to determine their impact on the

conclusions in this SER. On February 17, 2006, the NRC issued its SER for the EGC ESP site

and made it publically available. EGC identified that the site characteristic for the probable

maximum flood (PMF) elevation proposed by the staff in the SER was somewhat higher than

that calculated by EGC in its ESP application. By letters dated March 24, 2006, and April 12,

2005, EGC requested that the staff review its revised PMF analysis and adopt its corresponding

PMF lovel as the site characteristic. By letter dated April 14, 2006, EGC provided Revision 4 to

the EGC ESP application, which documented EGC's revised PMF analysis. The changes

reflected in Revision 4 of the application included revisions to the tables, figures and text in

Section 2.4 to reflect EGC's revised PMF analysis. This included changes to the maximum

rainfall rate, the maximum hydrostatic PMF water surface elevation, the coincident wind wave

activity, and the maximum storm surge. EGC presented PMF calculations using two different

synthetic unit hydrograph methods (the Synder method and the Soil Conservation Service

method) with two different conceptual watershed layouts (a two-basin plus lake model and a

seven-basin plus lake model). The staff completed its review of the most recent version,

Revision 4, of the SSAR, as documented throughout this report and, for the reasons set forth

herein, finds it to be acceptable. The changes to the application in Revision 4 resulted in minor

modifications to the staff's SER issued February 17, 2006, including the following changes:

Section 2.4 of this SER was modified to incorporate EGC's revised PMF analysis and the staff's

independent confirmatory analysis; Appendix A of this SER was modified to reflect the new site

characteristics related to the revised PMF elevation; Appendix B of this SER was modified to

include Revision 4 of the application; and Appendix C of this SER was modified to include

reference documents used by the staff in its review of EGC's revised PMF elevation. The

changes to this SER also include modifications to Section 2.4 to better describe the technical

information in the application regarding EGC's ice thickness calculations. The scope of all

other changes to the SER issued on February 17, 2006, resulting from Revision 4, are limited to

corrections of factual inaccuracies; these changes did not impact the staff's conclusions.

Appendix A to this SER contains the list of site characteristics, permit conditions, combined

license (COL) action items, and the bounding parameters that the staff recommends that the

Commission include in any ESP that might be issued for the proposed site. Appendix B to this

SER is a chronology of the principal actions and correspondence related to the staff's review of

the ESF' application for the EGC ESP site. Appendix C lists the references for this SER,

Appendix D lists the principal contributors to this report, and Appendix E includes a copy of the

report by the ACRS.

1 -3
1.2 General Site Description

The EGC ESP facility will be co-located on the property of the existing Clinton Power Station

(CPS) facility. The CPS site, with its associated 4895-acre, man-made cooling reservoir

(Clinton Lake), is an irregular U-shaped site in DeWitt County in east-central Illinois about

6 miles east of the city of Clinton. The site is located between the cities of Bloomington and

Decatur to the north and south, respectively, and Lincoln and Champaign-Urbana to the west

and east, respectively. The total area encompassed by the ESP site boundary is about

14,180 acres. The site includes an area that extends approximately 14 miles along Salt Creek

and 8 miles along the North Fork of Salt Creek, and is about 3 miles northeast of the

confluence of Salt Creek and the North Fork of Salt Creek. Figure 1.2-1 in the site safety

analysis report (SSAR) depicts the site location; Section 2.1 of this SER discusses the site

location in more detail.

With regard to the existing development of the site, CPS Unit 1 is a Boiling Water Reactor 6

(BWR-6), with a rated core thermal power level of 3473 megawatts (thermal) (MWt) and a

gross electrical output of 1138.5 megawatts (electric) (MWe). AmerGen Energy Company, LLC

(AmerGen), is the licensed owner and operator of the CPS. AmerGen is a wholly owned

subsidiary of EGC. EGC is a wholly owned subsidiary of Exelon Ventures Company, LLC,

which in turn is a wholly-owned subsidiary of Exelon Corporation. SSAR Figure 1.2-2 provides

an aerial view of the EGC ESP site showing the existing development.

With regard to the proposed development of the site, AmerGen owns the real estate on which

the EGC ESP facility will sit, including the exclusion area, with the exception of a right-of-way

for the township road that traverses the exclusion area. The applicant entered an access and

indemnity agreement with AmerGen to obtain the rights to conduct preliminary studies and

perform other activities necessary to support the EGC ESP application process. The applicant

has stated that before any construction, it plans to enter into an agreement with AmerGen, that

will grant EGC an exclusive and irrevocable option to purchase, enter a long-term lease, and/or

procure other legal right in the land required for the EGC ESP facility. The staff proposes to

include a permit condition to govern exclusion area control on any ESP that may be issued in

connection with this application. Section 2.1.2 of this report discusses this issue in detail.

The applicant has not selected a specific reactor type for the EGC ESP site. However, to

support its ESP application, Exelon used available information from a range of possible facilities

to characterize the proposed development. The EGC ESP facility would be located

approximately 700 feet south of the current CPS facility on the existing CPS property. SSAR

Figure 1.2-3 shows the location of the EGC ESP site footprint and the distance by sector from

the outside boundary of the footprint to the CPS property line. Depending on the reactor type

selected, the EGC ESP facility could have a total core thermal power rating between

approximately 2400 and 6800 MWt. The EGC ESP facility would consist of a single reactor or

multiple reactors (or modules) of the same reactor type. SSAR Section 1.3 provides an

overview of the reactor designs considered in developing the information necessary to support

Exelon's ESP application. The EGC ESP facility could be any of the reactor designs described

in the application or a new design that falls within the range of the information developed to

characterize the facility (i.e., the plant parameter envelope (PPE)).

1-4
According to the applicant, the EGC ESP facility would be constructed as a large industrial

facility similar in general appearance to the existing CPS facility. However, unlike the existing

plant, which uses the Clinton Lake for normal cooling processes, the EGC ESP facility would

use ccoling towers. Clinton Lake would be used as the source of makeup water for the EGC

ESP facility cooling water systems.

A new intake structure, located on Clinton Lake adjacent to the existing CPS Unit 1 intake

structure, would provide raw water for cooling tower makeup and other plant services. Cooling

tower blowdown and other plant discharges would use the existing CPS Unit 1 discharge flume

as a discharge path to Clinton Lake. The additional discharge flow from the EGC ESP facility

would be insignificant relative to the capacity of the existing discharge flume. The CPS facility's

safety-related systems and equipment would not be shared or cross-connected with the EGC

ESP facility. However the EGC ESP facility would use the existing CPS ultimate heat sink as its

source of makeup water.

The E.SP facility might share some structures, such as the warehouse and training buildings

and parking lots, with CPS. Some support facilities, such as the domestic water supply and

sewage treatment, might also be shared. The applicant would expand the existing switchyard

to accommodate the output of the new facility and to provide the necessary offsite power. E GC

would use the switchyard area intended for the canceled CPS Unit 2 for this purpose. The

applicant would also use the existing transmission right-of-way. SSAR Figure 1.2-4 identifies

the location of the EGC ESP facility's new structures relative to the existing CPS facilities.

1.3 Plant Parameter Envelope

The regulations at 10 CFR Part 52, "Early Site Permits; Standard Design Certifications; and

Combined Licenses for Nuclear Power Plants," and 10 CFR Part 100, "Reactor Site Criteria,"

that apply to an ESP do not require an ESP applicant to provide specific design information.

However, some design information may be required to address 10 CFR 52.17(a)(1), which calls

for "an analysis and evaluation of the major structures, systems, and components of the facility

that bear significantly on the acceptability of the site under the radiological consequence

evaluation factors identified in § 50.34(a)(1) of this chapter."

In Section 1.4 of the SSAR, the applicant provided a list of postulated design parameters,

referred to as the "plant parameter envelope." The applicant states that the PPE is a set of

design parameters that are expected to bound the characteristics of a reactor or reactors that

might later be deployed at a site. This means that the design characteristics of potential

designs would be no more demanding from a site suitability perspective than the bounding

design parameters listed in the PPE tabulation.

The applicant states that it developed the list of plant parameters necessary to define the plantsite interface based on previous industry and Department of Energy-sponsored work performed

in the early 1990s as part of the ESP Demonstration Program, as well as on current reactor

vendor design input data. As a result of earlier and current efforts, the applicant identified

appropriate design parameters to include in the PPE through a systematic review of regulatory

criteria and guidance, ESP application content requirements, and experience with previous site

suitability studies. The plant parameters characterize (1) the functional or operational needs of

the plant from the site's natural or environmental resources, (2) the plant's impact on the site

1-5
and surrounding environs, and (3) the site-imposed requirements on the plant. The PPE values

are generally based on certified design information and the best available information for as yet

uncertified designs. Some of -the-values-have been modified to include margin.

A set of plant parameter values is developed by considering the values provided by various

reactor vendors and by applying appropriate conservatism where required to characterize the

surrogate facility. As applicable, the most limiting (maximum or minimum) bounding value is

selected. The complete set of plant parameter values describes, or envelops, the site-facility

interface. This type of facility characterization is considered sufficient to assess the future use

of the site for a nuclear electric generating facility.

Tables 1.4-1 through 1.4-8 of the applicant's SSAR list the parameters used, the PPE values

selected, and the site characteristic values used in assessing the safety and environmental

impact of constructing and operating the EGC ESP facility. SSAR Table 1.4-9 provides a

description or definition and bases for the plant parameters used to evaluate the safety and/or

environmental impact of locating the proposed nuclear generating capacity at the EGC ESP

site.

The applicant has stated that through the PPE, it had sufficient design information to allow it to

perform the evaluation required by 10 CFR 52.17(a)(1) to determine the adequacy of the

proposed exclusion area and low-population zone (LPZ) for the site. Section 3.3 of the SSAR

reports the results of this evaluation in which the applicant used design information limited to

the release rate of radioactivity to the environment resulting from a design-basis accident for

hypothetical reactors similar to two representative reactor types that vendors have offered for

construction in the United States.

In addition to the information required to support the dose consequence evaluation, the

applicant provides other design information in the PPE. Because the applicant is not requesting

the issuance of an ESP referencing a particular reactor design, the staff's review criterion for

the PPE is that the PPE values should not be unreasonable for a reactor that might be

constructed on the ESP site. The applicant's PPE is based on various reactor designs that are

either certified by the NRC, are in the certification process, or may be submitted for certification

in the future. The PPE references the following designs:

* Advanced Canada Deuterium Uranium (CANDU) Reactor (ACR-700) (Atomic Energy of

Canada, Ltd.)

* Advanced Boiling Water Reactor (ABWR) (General Electric)

* Advanced Plant 1000 (AP1 000) (Westinghouse Electric Company)

* Economic and Simplified Boiling Water Reactor (ESBWR) (General Electric)

* Gas Turbine Modular Helium Reactor (GT-MHR) (General Atomics)

* International Reactor Innovative and Secure Project (IRIS) (consortium led by

Westinghouse)

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* Pebble Bed Modular Reactor (PBMR (Pty) Ltd.)

The staff reviewed the applicant's PPE values and found them to be reasonable, as discussed

in the individual sections in this SER. As previously noted, the applicant identified certain P PE

values as appropriate for inclusion in an ESP, if one is issued. The staff also reviewed the

applicant's proposed list of PPE values and identified certain PPE values as bounding

parameters or controlling PPE values as discussed in the individual sections of this SER. A

controlling PPE value, or bounding parameter value, is one that necessarily depends on a site

characteristic. As the PPE is intended to bound multiple reactor designs, the NRC would review

the actual design selected in a COL or construction permit (CP) application referencing any

ESP that might be issued in connection with this application to ensure that the design falls

within the bounding parameter values. Appendix A to this SER lists the bounding parameters

identified for the EGC ESP site.

If an ESP is issued for the EGC ESP site, an entity may wish to reference the ESP, as well as a

certified design, in a COL or CP application. Such a COL or CP applicant must demonstrate

that the site characteristics established in the ESP bound the postulated site parameters

established for the chosen design and that the design characteristics of the chosen design fall

within the bounding parameter values specified in the ESP. Otherwise, the COL or CP

applicant must demonstrate that the new design, given the site characteristics in the ESP,

complies with the Commission's regulations. If an entity wishes to reference the ESP and a

design that is not certified, the COL or CP applicant must demonstrate that the design

characteristics of the chosen design, in conjunction with the site characteristics established for

the ESP, comply with the Commission's regulations.

1.4 Identification of Agents and Contractors

EGC is the applicant for the ESP and has been the only participant in the review of the

suitability of the EGC ESP site for a nuclear power plant. CH2MHILL, under contract with EGC,

served as the primary contractor for the development of the ESP application, supplying

personnel, systems, and project management.

Several subcontractors also assisted in the development of EGC's ESP application. Parsons

Power Group, Inc., provided engineering services in preparing the SSAR; Testing Service

Corporation provided engineering, technical, and laboratory services associated with

geotechnical activities; Geomatrix Consultants, Inc., performed seismic and geologic data

collection, site response studies, and safe-shutdown earthquake determinations; GRL

Engineers, Inc., conducted standard penetration test measurement work; Stratigraphics

performed cone penetrometer measurements and testing for the geotechnical aspects of the

ESP; and the University of Texas performed soil sample resonant column and torsional shear

testing.

1.5 Summarv of Principal Review Matters

This SER summarizes the results of the NRC staff's technical evaluation of the EGC ESP site.

The staff's evaluation included a technical review of the information and data the applicant

submitted, with emphasis on the following matters:

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population density and land use characteristics of the site environs and the physical

characteristics of the site, including seismology, meteorology, geology, and hydrology,

to evaluate whether these characteristics were adequately described and appropriately

considered in determining whether the site characteristics are in accordance with the

Commission's siting criteria (10 CFR Part 100, Subpart B, "Evaluation Factors for

Stationary Power Reactor Site Applications on or After January 10, 1997")

* potential hazards of man-made facilities and activities to a nuclear power plant or plants

that might be constructed on the ESP site (e.g., mishaps involving storage of hazardous

materials (toxic chemicals, explosives), transportation accidents (aircraft, marine traffic,

railways, pipelines), and the existing nuclear power plant at the nearby CPS)

* potential capability of the site to support the construction and operation of a nuclear

power plant(s) with design parameters within the parameters specified in the applicant's

PPE under the requirements of 10 CFR Parts 52 and 100

* suitability of the site for development of adequate physical security plans and measures

for a nuclear power plant(s)

* proposed major features for a future emergency plan if an applicant decides to seek a

license to construct and operate a nuclear power plant(s) on the ESP site, any

significant impediments to the development of emergency plans for the EGC ESP site,

and a description of contacts and arrangements made with Federal, State, and local

government agencies with emergency planning responsibilities

* quality assurance measures EGC applied to the information submitted in support of the

ESP application and safety assessment

* the acceptability of the applicant's proposed exclusion area and LPZ under the dose

consequence evaluation factors of 10 CFR 50.34(a)(1)

During its review, the staff held several meetings with representatives of EGC and its

contractors and consultants to discuss various technical matters related to the staff's review of

the EGC ESP site (refer to Appendix B to this report). The staff also visited the site to evaluate

safety matters.

1.6 Summary of Open and Confirmatory Items

As a result of its review of Exelon's application for the EGC ESP, the staff identified several

issues that remained open at the time the DSER and supplemental DSER were issued. The

staff considers an issue to be open if the applicant has not provided requested information and

the staff is unaware of what will ultimately be included in the applicant's response. For tracking

purposes the staff assigned each of these issues a unique identifying number that indicates the

section of this report describing it. The resolution of each open item is discussed in the SER

section in which the item appears. For example, Section 2.1 of this report discusses Open

Item 2.1-1.

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In addition, the staff identified several confirmatory items in the DSER. An item is identified as

confirmatory if the staff and the applicant have agreed on a resolution of the particular item, but

the resolution has not yet been formally documented. For example, Section 1.1 of this report

discusses Confirmatory Items 1.1-1 and 1.1-2.

The DSER was issued with 33 open items and 5 confirmatory items; the supplemental DSER

was issued with 7 open items. As set forth in this report, all open items have been resolved and

the confirmatory items have been completed. This SER documents the resolution of all the

open and confirmatory items identified in the DSER and the supplemental DSER.

1.7. Summary of Combined License Action Items

The staff has also identified certain site-related items that will need to be addressed at the COL

or CP stage if a COL or CP applicant desires to construct one or more new nuclear reactors on

the EGC ESP site. This report refers to these items as COL action items. The COL action

items relate to issues that are outside the scope of this SER. The COL action items do not

establish requirements; rather, they identify an acceptable set of information to be included in

the site-specific portion of the safety analysis report submitted by a COL or CP applicant

referencing the EGC ESP. An applicant for a COL or CP should address each of these items in

its application. The applicant may deviate from or omit these items, provided that the COL or

CP application identifies and justifies the deviation or omission. The staff determined that the

COL action items do not affect its regulatory findings at the ESP stage and are, for reasons

specified in this report for each item, more appropriately addressed at later stages in the

licensing process.

The DSER was issued with nine COL action items and the supplemental DSER was issued with

eight CDL action items. The staff reviewed the applicant's responses to the DSER and

supplemental DSER open items and identified a number of new COL action items as a result.

This report highlights these COL action items, and the staff explains them in the applicable

sections of this SER. Appendix A to this SER includes a list of COL action items that must be

addressed by a future COL or CP applicant. The staff identified COL action items in order to

ensure that particular significant issues are tracked and considered during the COL or CP

stage. The COL action items focus on matters that may be significant in any COL or CP

application referencing the ESP for the EGC site, if one is issued. Usually, COL action items

are not necessary for issues covered by permit conditions or explicitly covered by the bounding

parameters. The list of COL action items is not exhaustive.

1.8 Summary of Permit Conditions

The staff has identified certain permit conditions that it will recommend the Commission

impose, if an ESP is issued to the applicant. Appendix A to this SER summarizes these

conditions. These permit conditions, or limitations on the ESP, are based on the provisions of

10 CFR 52.24, "Issuance of Early Site Permit."

The staff proposed 14 permit conditions in the DSER and 1 permit condition in the

supplemental DSER. The applicant's responses to the DSER and supplemental DSER open

items resulted in the resolution of some proposed DSER permit conditions. In addition, the staff

determined that a permit condition is not necessary when an existing NRC regulation requires a

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future regulatory review and approval process to ensure adequate safety during design,

construction, or inspection activities for a new plant. Based on this criterion, the staff removed

a number of permit conditions proposed in the DSER and, in some cases, added new permit

conditions, COL action items, or site characteristics, as appropriate, to account for the concern.

Appendix A to this SER contains the final list of permit conditions, which have been highlighted

throughout this report. Each permit condition has been reassigned a number identifying the

order which appears in this SER. The staff has provided an explanation of each permit

condition in the applicable section of this report.

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2. SITE CHARACTERISTICS

2.1 Geography and Demography

2.1.1 Site Location and Description

2.1.1. I Technical Information in the Application

In Section 2.1.1.1 of the site safety analysis report (SSAR), the applicant presented information

concerning the location and area of the early site permit (ESP) site that could affect the design

of structures, systems, and components (SSCs) important to the safety of a nuclear power

plant(s) falling within the applicant's plant parameter envelope (PPE) that might be constructed

on the proposed ESP site. The applicant stated that the Exelon Generating Company (EGC)

ESP site will be located approximately 700 feet south of the existing Clinton Power Station

(CPS), which lies within Zone 16 of the Universal Transverse Mercator (UTM) coordinates. The

applicant further stated that the exact UTM coordinates for a new unit(s) constructed on the

proposed ESP site will be finalized at the time of a combined license (COL) application. The

applicant provided the following information on site location and area:

* the site boundary for a new unit(s) on the proposed ESP site with respect to the location

of CPS

* the site location with respect to political subdivisions and prominent natural and

manmade features of the area within the low-population zone (LPZ) and the 50-mile

population zone

* the topography surrounding the proposed ESP site

* the distance from the proposed ESP site to the nearest exclusion area boundary (EAB),

including the direction and distance

* the location of potential radioactive material release points associated with a proposed

new unit(s)

* the distance of the proposed ESP site from U.S. and State highways

* confirmation that no physical characteristics unique to the proposed ESP site were

identified that could pose a significant impediment to the development of emergency

plans

2.1.1.2 Regulatory Evaluation

In Request for Additional Information (RAI) 1.5-1, the U.S. Nuclear Regulatory Commission

(NRC) staff asked the applicant to provide a comprehensive listing of regulations applicable -to

its ESP SSAR. In its response to RAI 1.5-1, the applicant stated that NRC Review Standard

(RS)-002, "Processing Applications for Early Site Permits," Attachment 2, identifies the NRC

regulations applicable to its ESP SSAR. RS-002, Attachment 2, identifies the applicable NRC

regulations regarding site location and description in Title 10 of the Code of Federal

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Regulations, (10 CFR) Section 52.17, "Contents of Applications," and Subpart B, "Evaluation

Factors for Stationary Power Reactor Site Applications on or After January 10, 1997," to

10 CFR Part 100, "Reactor'Site Criteria." The staff 'finds that the applicant correctly identified

the applicable regulations. The staff considered the following two regulatory requirements in

reviewing the site location and site area:

(1) 10 CFR Part 100, which requires the consideration of factors relating to the size and

location of proposed sites

(2) 10 CFR 52.17, which requires the applicant to submit information needed to evaluate

factors involving the characteristics of the site environs

According to Section 2.1.1 of RS-002, Attachment 2, an applicant has submitted adequate

information if it satisfies the following criteria:

* The site location, including the exclusion area and the proposed location of a nuclear

power plant(s) of specified type falling within the applicant's PPE that might be

constructed on the proposed site, is described in sufficient detail to determine whether

the requirements of 10 CFR Part 100 and 10 CFR 52.17 are met, as discussed in

Sections 2.1.2, 2.1.3, and 3.3 of this safety evaluation report (SER).

* Highways, railroads, and waterways which traverse the exclusion area are sufficiently

distant from the planned or likely locations of any structures of a nuclear power plant(s)

of specified type falling within the applicant's PPE that might be constructed on the

proposed site so that routine use of these routes is not likely to interfere with normal

plant operation.

2.1.1.3 Technical Evaluation

The proposed EGC ESP site is located approximately 700 feet south of the existing CPS

facility. The CPS lies within Zone 16 of the UTM coordinates. Figure 2.1-8 of the SSAR depicts

the EAB and the LPZ for the proposed ESP site. The applicant stated that the exact UTM

coordinates for a new unit(s) constructed on the proposed ESP site will depend upon the

specific reactor technology selected for deployment. This decision will be finalized at the time

of a COL application. The staff will review the exact UTM coordinates of the new unit(s) at the

time of a COL application. This is COL Action Item 2.1-1.

The applicant elected to define the EAB envelope as a circular radius of 3,362 feet (0.64 miles)

and the LPZ as a circular radius of 13,182 feet (2.5 miles) from the center of.the proposed ESP

facility footprint. The EAB for the proposed ESP site overlaps the existing EAB for CPS;

however, the two are not concentric. Also, the EAB for the existing CPS is slightly smaller, with

a circular radius of 3199 feet (0.6 miles), and both CPS and the proposed ESP site have the

same LPZ. The applicant established the EAB and the LPZ to ensure that the radiological

consequence evaluation factors identified in 10 CFR 50.34(a)(1) and the siting evaluation

factors in Subpart B of 10 CFR Part 100 are met. No persons live within either the CPS EAB or

the proposed ESP site EAB. The staff verified that the exclusion area distance is consistent

with the distance used in the radiological consequence analyses the applicant performed and

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which Section 3.3 of the SSAR describes, as well as the analysis the staff performed and which

Section 3.3 of this SER describes.

The proposed ESP site, located in east-central Illinois, falls within Harp Township in DeWitt

County. Specifically, the site is about 6 miles east of the City of Clinton and lies between the

cities of Bloomington and Decatur, 22 miles to the north and 22 miles to the south, respectively.

Regionally, the proposed site is located between the cities of Lincoln and Champaign-Urbana,

28 miles to the west and 30 miles to the east, respectively. The nearest major highways are

Illinois State Routes 54, 10, and 48, all of which cross the CPS facility property. Other major

highways within the region include Interstate 155 to the west, Interstate 72 to the southeast,

Interstate 55 to the northwest, Interstate 74 to the northeast, Interstate 39 to the north, and

Interstate 57 to the east. The closest of these highways (State Route 54) approaches within

1 mile north of the proposed ESP facility footprint. Routine use of State Route 54 is not likely to

interfere with normal plant operation.

The gaseous effluent release limits for a new unit(s) would apply at the proposed ESP

exclusion area site boundary, and the liquid effluent release limits for a new unit(s) would apply

at the end of the discharge canal into Clinton Lake, the outfall of which joins the Sangamon

River approximately 56 miles downstream. The staff finds that these release points are

acceptable for determining whether the radiation exposures to the public meet the criterion, "as

low as reasonably achievable," cited in Appendix I, "Numerical Guides for Design Objectives

and Limiting Conditions for Operation to Meet the Criterion 'As Low as is Reasonably

Achievable,' for Radioactive Material in Light-Water-Cooled Nuclear Power Reactor Effluents,"

to 10 ClFR Part 50, "Domestic Licensing of Production and Utilization Facilities." (For a further

discussion of this subject, see Section 5.4 of the staff's environmental impact statement (EIS)

for the lExelon ESP application.)

In addition, for the reasons set forth in Section 13.3 of this SER, the staff finds that no physical

characteristics unique to the proposed ESP site have been identified that could pose a

significant impediment to the development of emergency plans.

2.1.1.4 Conclusions

As set forth above, the applicant provided and substantiated information concerning the site

location and area that could affect the design of SSCs important to the safety of a nuclear

power plant(s) of specified type falling within the applicant's PPE that might be constructed on

the proposed ESP site. The staff has reviewed the applicant's information, as described above,

and concludes that it is sufficient for the staff to evaluate compliance with the siting evaluation

factors in 10 CFR Part 100 and 10 CFR 52.17, as well as with the radiological consequence

evaluation factors in 10 CFR 50.34(a)(1). The staff further concludes that the applicant

provided sufficient details about the site location and site area to allow the staff to evaluate, as

documented in Sections 2.1.2, 2.1.3, and 3.3 of this SER, whether the applicant met the

relevant requirements of 10 CFR Part 100 and 10 CFR 52.17.

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2.1.2 Exclusion Area Authority and Control

2.1.2.1 Technical Information in the Application

In Section 2.1.2 of the SSAR, the applicant presented information concerning its plan to ensure

the legal authority necessary to determine all activities within the designated EAB, if the

applicant decides to proceed with the development of a new reactor unit(s) at the proposed

ESP site. The regulations at 10 CFR 100.3, "Definitions," require that a reactor licensee have

the authority to determine all activities within the designated exclusion area, including the

exclusion or removal of personnel and property. With respect to this requirement, the applicant

stated the following:

EGC will ensure that it has or will be granted the necessary authority, rights, and

control of the EGC ESP Site, including the exclusion area prior to commencing

actions allowed pursuant to any ESP granted from the Application.

In RAI 2.1.2-1, the staff asked the applicant for additional information regarding its approach to

obtaining a grant from the appropriate regulatory agencies and other private parties for the

necessary authority, rights, and control of the ESP site. In its response, the applicant stated the

following:

EGC plans to enter into an agreement with AmerGen prior to construction that

will grant EGC an exclusive and irrevocable option to purchase, enter a longterm lease for, and/or procure other legal right in the land required for the EGC

ESP facility. Additionally, EGC will enter into an Exclusion Area Agreement with

AmerGen. This agreement will provide EGC with authority to determine the

activities within the EGC ESP exclusion area, including the exclusion of

personnel and property, to the extent necessary to comply with applicable NRC

guidance. EGC anticipates that this Agreement and the lease will extend for

99 years.

2.1.2.2 Regulatory Evaluation

In RAI 1.5-1, the staff asked the applicant to provide a comprehensive listing of NRC

regulations applicable to its ESP SSAR. In its response to RAI 1.5-1, the applicant stated that

RS-002, Attachment 2, identifies the NRC regulations applicable to its ESP SSAR. RS-002,

Attachment 2, identifies the applicable NRC regulations regarding exclusion area authority and

control as 10 CFR 52.17, 10 CFR Part 100, and 10 CFR 50.34(a)(1). The staff reviewed this

portion of the application for conformance with the applicable regulations, and considered the

corresponding regulatory guidance.

In reviewing the applicant's legal authority to determine all activities within the designated

exclusion area, the staff considered the relevant requirements of 10 CFR 100.3 which state the

following:

Exclusion area means that area surrounding the reactor, in which the reactor

licensee has the authority to determine all activities including exclusion or

removal of personnel and property from the area. This area may be traversed by

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a highway, railroad, or waterway, provided these are not so close to the facility

as to interfere with normal operations of the facility and provided appropriate and

effective arrangements are made to control traffic on the highway, railroad, or

waterway, in case of emergency, to protect the public health and safety....

Activities unrelated to operation of the reactor may be permitted in an exclusion

area under appropriate limitations, provided that no significant hazards to the

public health and safety will result.

To meet the requirements of 10 CFR Part 100, the applicant must demonstrate, before the

issuance of an ESP, that it has an exclusion area and an LPZ, as defined in 10 CFR 100.3, and

that it has the required authority within the exclusion area, also defined in 10 CFR 100.3. If not,

the applicant must provide reasonable assurance that it will have such authority before

construction of a new unit(s) commences.

2.1.2.3 Technical Evaluation

The applicant has stated that it plans to enter into an agreement with AmerGen, before any

construction, that will grant Exelon an exclusive and irrevocable option to purchase, enter a

long-term lease, and/or procure other legal right in the land required for the EGC ESP facility.

The applicant has not attempted to demonstrate that it currently has the authority to determine

all activities, including exclusion or removal of personnel and property from the area, as

required by 10 CFR 100.3. To meet the exclusion area control requirements of 10 CFR

100.21 (a), "Non-Seismic Site Criteria," and 10 CFR 100.3, the applicant does not need to

demonstrate total control of the property before issuance of the ESP. In the draft safety

evaluation report (DSER), the NRC staff stated that the applicant must provide reasonable

assurance that it can acquire the required control, i.e., that it has the legal right to obtain control

of the exclusion area. The staff had not then obtained information sufficient to enable the staff

to determine whether the applicant had such a legal right. Accordingly, the NRC staff identified

DSER Open Item 2.1-1, which stated:

Demonstrate that the applicant has the legal right to control the exclusion area,

or has an irrevocable right to obtain such control.

Specifimally, the applicant should provide a detailed explanation of the corporate relationship

between Exelon (the parent company) and AmerGen (the subsidiary).

In its response to the open item, the applicant indicated as follows: AmerGen is the licensed

owner and operator of the Clinton Power Station. AmerGen is a wholly-owned subsidiary of the

applicant, Exelon Generation Company, LLC (EGC). EGC is a wholly owned subsidiary of

Exelon Ventures Company, LLC, which in turn is a wholly-owned subsidiary of Exelon

Corporation. Additionally, the AmerGen Management Committee, which has the authority to

manage AmerGen, authorized AmerGen's officers to negotiate all necessary agreements to

support EGC with its ESP application, which may include, without limitation, a long-term interest

in the real estate that is the subject of the ESP application and an exclusion area agreement.

(See lelter from Marilyn C. Kray, Vice President, Project Development, Exelon Nuclear, to NRC,

"Response to Draft Safety Evaluation Report (DSER) Items" (April 26, 2005), ADAMS

Accession No. ML051230326.)

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Based on the above information, the staff has determined that AmerGen is prepared to

negotiate with EGC in order to grant the applicant an exclusive and irrevocable option to

purchase, enter a long-term lease, and/or procure other legal right in the land required for the

EGC ESP facility, and no new nuclear power plant could be built in the absence of an

agreement. It further appears that there is no legal impediment to EGC's acquisition of such

rights.

Accordingly, the NRC staff proposes to include a condition in any ESP that might be issued

regarding the Clinton site, to govern exclusion area control. This condition would require that

an agreement granting EGC an exclusive and irrevocable option to purchase, enter a long-term

lease, and/or other legal right in the land required to satisfy the requirements of 10 CFR

Part 100 for the EGC ESP facility, be obtained and executed before submission of an

application for a COL seeking authority to construct and operate a nuclear power plant

referencing the ESP. Such a condition provides reasonable assurance for purposes of

issuance of an ESP. This is Permit Condition 1. Therefore, DSER Open Item 2.1-1 is closed.

The applicant stated that the CPS operator, AmerGen, owns the property associated with the

proposed ESP site, with the exception of a right-of-way for the township road that traverses the

exclusion area. This road provides access to privately owned property which lies outside the

proposed ESP exclusion area. The applicant further stated that in an emergency, Exelon,

together with the local law enforcement agency, will control access to the exclusion area via this

road. Furthermore, the property ownership and mineral rights provide AmerGen the authority to

control activities, including exclusion and removal of personnel and property, within the

exclusion area. There are no residents within the EAB.

Should the NRC grant the ESP, and the ESP holder decide to perform the activities authorized

by 10 CFR 52.25, 'Extent of Activities Permitted," the ESP holder, or the applicant for a

construction permit (CP) or COL who references the permit, will need to obtain the authority to

undertake such activities on the ESP site. In obtaining such a right, the ESP holder, or the

applicant for a CP or COL who references the permit, will also need to obtain the corresponding

right to implement the site redress plan described in the staff's final EIS in the event that no

plant is built on the ESP site. This is Permit Condition 2.

A small area of Clinton Lake lies within the proposed ESP EAB and is used for public recreation

lake activities. Should the NRC grant the ESP and the ESP holder decide to apply for a COL

(or for a CP and operating license), the ESP holder will need to make arrangements with the

appropriate Federal, State, local, or other public agencies to provide for control of the portion of

Clinton Lake that lies within the exclusion area. These public agencies, together with the ESP

holder, will need sufficient authority over these bodies of water to allow for the exclusion and

ready removal, in an emergency, of any persons present on them. This is COL Action

Item 2.1-2.

2.1.2.4 Conclusions

As set forth above, the applicant provided and substantiated information concerning its plan to

obtain legal authority to determine all activities within the designated exclusion area. The staff

has reviewed the applicant's information and concludes that it is sufficient to evaluate

compliance with the exclusion area control requirements of 10 CFR 100.21 (a) and 10 CFR

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100.3. In addition, the applicant appropriately described the exclusion area and the methods by

which it will control access and occupancy of this exclusion area during normal operation and in

the event of an emergency situation.

Based on the above, the staff concludes that the applicant's exclusion area is acceptable and

meets the requirements of 10 CFR Part 100, subject to the limitation and conditions identified in

this SEER. Such permit conditions provide reasonable assurance that an ESP provides for

control of the exclusion area. Further, the ESP holder must demonstrate that it will have

authority to perform the activities authorized by 10 CFR 52.25, should it choose to do so, and

the corresponding right to implement the site redress plan, as described in the discussion of

Permit Condition 2 above.

2.1.3 Population Distribution

2.1.3.1 Technical Information in the Application

In SSAR Section 2.1.3, the applicant estimated and provided the population distribution within a

50-mile radius of the proposed ESP site, based on the most recent U.S. Census data, and the

projected population estimates up to 2060, including transient populations. The applicant also

provided the population distribution within the LPZ, facilities and institutions within the vicinity of

the LP;7, the nearest population center, population densities within a 50-mile radius of the

proposed ESP site for 2000, and estimated population data for 2060.

The population distribution provided by the applicant encompasses nine concentric rings at

various distances out to 50 miles from the proposed ESP site and 16 directional sectors. The

applicant also estimated and provided transient population data out to 50 miles for 2000 and

projected population estimates to 2060 based on the recreational use of Clinton Lake State

Recreational Area, seasonal residents, and business and migrant workers that normally do not

live in the area.

2.1.3.2 Regulatory Evaluation

In RAI 1.5-1, the staff asked the applicant to provide a comprehensive listing of NRC

regulations applicable to its ESP SSAR. In its response to RAI 1.5-1, the applicant stated that

RS-002, Attachment 2, identifies the NRC regulations applicable to its ESP SSAR. RS-002,

Attachment 2, identifies the applicable NRC regulations and guidance regarding population

distribution as 10 CFR 52.17, 10 CFR Part 100, and Regulatory Guide (RG) 4.7, "General Site

Suitability Criteria for Nuclear Power Stations," issued April 1998. The staff reviewed this

portion of the application for conformance with the applicable regulations, and considered the

corresponding regulatory guidance.

The stalf considered the following regulatory requirements in its review of this SSAR section:

* 10 CFR 52.17, which requires each applicant to provide a description and safety

assessment of the site and which requires site characteristics to comply with the criteria

of 10 CFR Part 100

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* 10 CFR Part 100, which establishes requirements with respect to population center

distance and the LPZ

In particular, the staff considered the population density and use characteristics of the site

environs, including the exclusion area, LPZ, and population center distance. The regulations in

10 CFR Part 100 provide definitions and other requirements for determining an exclusion area,

LPZ, and population center distance.

As stated in Section 2.1.3 of RS-002, Attachment 2, the applicable requirements of 10 CFR

52.17 and 10 CFR Part 100 are deemed to have been met if the population density and use

characteristics of the site meet the following criteria:

* Either there are no residents in the exclusion area or, if residents do exist, they are

subject to ready removal, in case of necessity.

* The specified LPZ is acceptable if it is determined that appropriate protective measures

could be taken on behalf of the enclosed populace in the event of a serious accident.

* The population center distance (as defined in 10 CFR Part 100) is at least one and onethird times the distance from the reactor to the outer boundary of the LPZ.

* The population center distance is acceptable if there are no likely concentrations of

greater than 25,000 people over the lifetime of a nuclear power plant(s) of specified

type, or falling within a PPE, that might be constructed on the proposed site (plus the

term of the ESP) closer than the distance designated by the applicant as the population

center distance. The boundary of the population center shall be determined upon

considerations of population distribution. Political boundaries are not controlling.

* The population data supplied by the applicant in the safety assessment are acceptable if

(1) they contain population data for the latest census, projected year(s) of startup of a

nuclear power plant(s) of specified type (or falling within a PPE) that might be

constructed on the proposed site (such date(s) reflecting the term of the ESP) and

projected year(s) of end of plant life, all in the geographical format given in Section 2.1.3

of RG 1.70, "Standard Format and Content of Safety Analysis Reports for Nuclear

Power Plants-LWR Edition," Revision 3, issued November 1978, (2) they describe the

methodology and sources used to obtain the population data, including the projections,

(3) they include information on transient populations in the site vicinity, and (4) the

population data in the site vicinity, including projections, are verified to be reasonable by

other means, such as U.S. Census publications, publications from State and local

governments, and other independent projections.

* If the population density at the ESP stage exceeds the guidelines given in RG 4.7,

special attention to the consideration of alternative sites with lower population densities

is necessary. A site that exceeds the population density guidelines of Regulatory

Position C.4 of RG 4.7 can nevertheless be selected and approved if, on balance, it

offers advantages compared with available alternative sites, when all of the

environmental, safety, and economic aspects of the proposed and alternative sites are

considered.

2-8
2.1.3.3 Technical Evaluation

The staff reviewed the population data in the site environs, as presented in the applicant's

SSAR, to determine whether the exclusion area, LPZ, and population center distance for the

proposed ESP site comply with the requirements of 10 CFR Part 100 and the acceptance

criteria in Section 2.1.3.2 of this SER. The staff also evaluated whether, consistent with

Regulatory Position C.4 of RG 4.7, the applicant should consider alternate sites with lower

population densities. The staff also reviewed whether appropriate protective measures could

be taken on behalf of the enclosed populace within the emergency planning zone (EPZ), which

encompasses the LPZ, in the event of a serious accident.

The staff compared and verified the applicant's population data against U.S. Census Bureau

Internet data. The staff reviewed the projected population data provided by the applicant,

including transient populations for 2010, 2020, 2030, 2040, 2050, and 2060 (see Section 1',.3

of this SER). If the ESP were approved and issued in 2006, assuming a COL application is

submitted around the middle of the ESP term, with a projected startup of a new unit(s) in atout

2020 and an operational period of 40 years, the projected year for end of plant life is about

2060. Accordingly, the staff finds that the applicant's projected population data cover an

appropriate number of years and are therefore reasonable.

The staff reviewed the transient population data provided by the applicant. The transient

population up to a 50-mile radius is based on recreational use of Clinton Lake Recreational

Area, seasonal residents, special populations (e.g., schools, hospitals, nursing homes, and

correctional facilities), and business and migrant workers who do not normally live in the area.

The applicant stated that it collected the transient population estimates for the larger business

transient population, recreation areas, and special populations using surveys performed during

August and September 2002; the DeWitt County Emergency Services and Disaster Agency

Coordinator verified the data. The applicant further stated that it obtained the data on the

recreation area population from the Illinois Department of Natural Resources. The applicant

obtained data on migrant workers from the Bureau of Economic Analysis, U.S. Department of

Commerce. Based on this information, the staff finds that the applicant's estimate of the

transient population is reasonable.

The staff notes that no member of the public lives within the exclusion area.

Section 3.3 of the SSAR describes the applicant's evaluation of design-basis accidents (DBAs);

Section 3.3 of this SER describes the staff's independent verification of the applicant's

evaluation. These analyses demonstrate that the radiological consequences of design-basis

reactor accidents at the proposed EAB and LPZ would be within the dose consequence

evaluation factors set forth in 10 CFR 50.34(a)(1).

The applicant stated that the nearest population center greater than 25,000 people likely to

exist over the lifetime of the proposed ESP site is Decatur, Illinois, with a population of 81,860,

located approximately 22 miles south-southwest of the proposed ESP site. The distance to

Decatur is well in excess of the minimum population center distance of 3.3 miles (one and onethird tim Ds the distance of 2.5 miles from the reactor to the outer boundary of the LPZ as

required per 10 CFR 100.21 (b)). The proposed LPZ is the area immediately surrounding the

exclusion area encompassed by a circle, centered on the proposed ESP facility footprint, with a

radius of 2.5 miles.

2-9
Therefore, the staff concludes that the proposed ESP site meets the population center distance

requirement, as defined in 10 CFR Part 100. The staff determined that it is unlikely that a

population center with 25,000 people or more will exist within the 3.3-mile minimum population

center distance during the lifetime of any new unit(s) that might be constructed on the site. This

conclusion is based on projected cumulative resident and transient populations within 10 miles

of the site during the lifetime of any new unit(s) (i.e., to 2060).

The staff evaluated the site against the criterion in Regulatory Position C.4 of RG 4.7 regarding

the need to consider alternative sites with lower population densities. This criterion specifies

that if the population densities in the vicinity of the proposed site, including the transient

population, projected at the time of initial site approval and within about 5 years thereafter, were

to exceed 500 persons per square mile averaged over any radial distance out to 20 miles

(cumulative population at a distance divided by the area at that distance), then alternative sites

should be considered. The staff has determined that population densities for the proposed ESP

site would be well below 500 persons per square mile. Therefore, the staff concludes that the

site conforms to Regulatory Position C.4 in RG 4.7, Revision 2. Assuming that construction of

a new nuclear reactor(s) at the proposed site would begin near the middle of the term of the

ESP, and based on its review of the applicant's population density data and projections, the

staff finds that the site also meets the guidance of RS-002, Attachment 2, regarding population

densities over the lifetime of any facility that might be constructed at the site. Specifically, the

population density over that period would be expected to remain below 500 persons per

square mile averaged out to a radial distance of 20 miles from the site.

The staff reviewed the applicant's information regarding its ability to take appropriate protective

measures on behalf of the permanent and transient residents in the LPZ in the event of a

serious accident. The applicant stated that the LPZ was selected to provide reasonable

probability that appropriate protective measures could be taken in such an event. The staff

finds that the applicant's statement is satisfactory because it is consistent with emergency

planning for the 1 0-mile plume exposure EPZ. The LPZ is located entirely within the 1 0-mile

EPZ. Comprehensive emergency planning for the protection of all persons within the 1 0-mile

EPZ, as addressed in Section 13.3 of this SER, would include those persons within the LPZ.

Based on the information the applicant presented on this subject and the staff's review provided

in Section 13.3 of this SER, the staff concludes that appropriate protective measures could be

taken on behalf of the populace enclosed within the LPZ in the event of a serious accident.

2.1.3.4 Conclusions

As set forth above, the applicant provided an acceptable description of current and projected

population densities in and around the site. These densities projected at the time of initial site

approval (assuming a new unit(s) is constructed on the site) and within about 5 years thereafter

are within the guidelines of Regulatory Position C.4 of RG 4.7. The applicant has properly

specified the LPZ and population center distance. The staff finds that the proposed LPZ and

population center distance meet the definitions in 10 CFR 100.3. Therefore, the staff concludes

that the applicant's population data and population distribution are acceptable and meet the

requirements of 10 CFR 52.17 and 10 CFR Part 100. In Section 3.3 of this SER, the staff

documents that the radiological consequences of bounding DBAs at the EAB and the outer

boundary of the LPZ also meet the requirements of 10 CFR 52.17.

2-10
2.2 Nearby Industrial, Transportation, and Military Facilities

2.2.1-2.2.2 Identification of Potential Hazards in Site Vicinity

For an ESP application, the NRC staff reviews the site distance from industrial, military, and

transportation facilities and routes. Facilities and routes of potential concern include air,

ground, and water traffic; pipelines; and fixed manufacturing, processing, and storage facilities.

The staff's review focuses on potential external hazards or hazardous materials that are present

or which may reasonably be expected to be present during the projected lifetime of a nuclear

power plant(s) that might be constructed on the proposed site. The staff prepared

Sections 2.2.1 through 2.2.2 of this SER in accordance with the review procedures described in

RS-002, Attachment 2, using information presented in Section 2.2 of the applicant's SSAR,

responses to staff RAls, and the reference materials described in the appropriate sections of

RS-002, Attachment 2.

2.2.1.1-2.2.2.1 Technical Information in the Application

Section 2.2 of the SSAR presents information on the industrial, transportation, and military

facilities in the vicinity of the proposed ESP site.

Specifically, in Section 2.2.2.1, the applicant states that the proposed site is in DeWitt County,

Illinois, which is a rural and agricultural area. According to the applicant, the 461-acre ESP site

is zoned for industrial uses. The applicant identifies three small industrial facilities within

5 miles of the proposed ESP site: two agricultural chemical and fertilizer production and

storage facilities, and a propane storage facility. Figure 2.2.1-1 shows the locations of the

facilities. EGC's wholly owned subsidiary, AmerGen, owns the surrounding areas within the

exclusion area boundary. No industrial facilities, pipelines, or other developments are located in

the proposed exclusion area other than CPS, operated by AmerGen.

Section 2.2.1 of the SSAR describes the roads within 5 miles of the proposed ESP site.

Several Illinois State routes (Routes 54, 48, and 10) pass 1 mile or more from the proposed

site, and U.S. Route 51 passes about 6 miles west of the proposed site. The applicant states

that the Gilman Line of the Canadian National Railroad parallels State Route 54 and passes

about 1 mile to the north of the proposed site.

In SSAR Section 2.2.2.3, the applicant states that five pipelines cross the CPS property; one of

these pipelines passes within 1 mile of the ESP site. The Shell/Equilon 14-inch pipeline

currently transports gasoline and diesel, but is configured so it could transport higher volatilit.y

products like propane. The SSAR states that the pipeline owner has agreed to notification

protocols if propane or other high-volatility substances are moved through the pipeline.

However, the SSAR states that recent discussions with the pipeline owner indicate that the use

of the p peline is not likely to change. Table 2.2-4 of the SSAR indicates that three other

pipelines carrying refined petroleum products pass no closer than 12,000 feet from the ESP

site.

2-11
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Figure 2.2.1-1 Industrial facilities In the vicinity of the ESP site.

2-12
In SSAR Section 2.2.2.5, the applicant describes aircraft activities (nearby airports and airways)

in the vicinity of the proposed ESP site. SSAR Figure 2.2-1 identifies four small private airstrips

within B miles of the ESP site. The SSAR indicates that these small private strips have turf

runways of 1500-2000 feet and can only accommodate small single- or twin-engine propeller

craft. The airstrip closest to the ESP site (Spencer), owned by AmerGen, is not operational.

A heliport at CPS is for the exclusive use of CPS staff. The applicant revised SSAR

Section 2.2.2.5.1 in response to RAI 2.2.2-1 to include flight traffic estimates for these airstrips.

The aircraft activities associated with the three operational airstrips in the vicinity of the ESFP

site involve light aircraft. These airstrips handle an estimated 800 operations per year in aircraft

traffic. In SSAR Figure 2.2-3, EGC indicates that four low-altitude Federal airways cross near

the ESP site. Airway V313 passes 2 miles east of the ESP site. Airway V233 passes 3 miles

northwest. Airway V72 passes 5 miles to the northeast, and Airway V434 passes 6 miles northnortheast of the ESP site.

The SS)AR states that Clinton Lake is the only navigable waterway in the vicinity of the ESP

site. The only water navigation on the lake is recreational boating. Seven public boat launch

ramps and one marina provide boat access to the lake.

2.2.1.2-2.2.2.2 Regulatory Evaluation

In RAI 1.5-1, the staff asked the applicant to provide a comprehensive list of NRC regulations

applicable to its ESP SSAR. In its response to RAI 1.5-1, the applicant stated that RS-002,

Attachment 2, identifies the NRC regulations applicable to its ESP SSAR. The staff considered

the following regulatory requirements identified in RS-002, Attachment 2, in reviewing

information on potential site hazards that could affect the safe design and siting of a nuclear

power plant(s) that might be constructed at the proposed site within the applicant's PPE:

* 10 CFR 52.17(a)(1)(vii) with respect to information on the location and description of any

nearby industrial, military, or transportation facilities and routes

* 10 CFR 100.20(b) with respect to information on the nature and proximity of man-related

hazards

* 1 0 CFR 100.21 (e) with respect to potential hazards associated with nearby

transportation routes and industrial and military facilities

In SSAR Section 2.2, the applicant identifies the following applicable NRC guidance on potential

hazards in the vicinity of the proposed ESP site:

* RG 1.91, "Evaluation of Explosions Postulated to Occur on Transportation Routes Near

Nuclear Power Plant Sites," issued February 1978

* RG 1.78, Revision 1, "Evaluating the Habitability of a Nuclear Power Plant Control Room

During a Postulated Hazardous Chemical Release," issued December 2001

* RG 1.70, Revision 3

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* NUREG-0800, Revision 3, "Standard Review Plan for the Review of Safety Analysis

Reports for Nuclear Power Plants," issued in July 1981 (Standard Review Plan (SRP))

* RS-002, Attachment 2

The staff used the regulatory positions and criteria in RG 1.91 and RG 1.78, Revision 1, which

describe acceptable methods for hazard evaluation, to determine the applicant's compliance

with the NRC regulations listed above.

Sections 2.2.1-2.2.2, 2.2.3, and 3.5.1.6 of RS-002, Attachment 2, and RG 1.70, Revision 3,

provide guidance on the information appropriate for identifying, describing, and evaluating

potential man-related hazards. The staff reviewed this portion of the application for

conformance with the applicable regulations, and considered the corresponding regulatory

guidance.

2.2.1.3-2.2.2.3 Technical Evaluation

The staff evaluated the potential for man-related hazards in the vicinity of the proposed ESP

site by reviewing (1) the information in SSAR Sections 2.2.1-2.2.2, (2) the applicant's

responses to the staff's RAls, (3) information obtained during the staff's visit to the proposed

ESP site and its vicinity, and (4) other publicly available reference material published by the

U.S. Geological Survey (USGS) (see the Clinton, Heyworth, Maroa, Farmer City North, Farmer

City South, LeRoy, Weldon East, Weldon West, and DeWitt, Illinois, 7.5-minute quadrangle

maps) and other topographic maps (see Illinois Atlas and Gazetteer, issued in 2000), aerial

imagery (Terraserver-usa.com, 2004), and Geographic Information System (GIS) coverage files

(see the Platts POWERmap GIS spatial data, issued 2004, which include map layers depicting

natural gas pipelines, railroads, and electric transmission lines).

The staff reviewed the information provided by the applicant on nearby industrial facilities.

Because the ESP facility would be located adjacent to the existing CPS facility, the applicant

relied on the CPS updated safety analysis report (USAR), which identifies and evaluates the

potential hazards from nearby industrial facilities. The applicant provided a list of the volumes

of the chemical and potentially hazardous materials stored at the CPS site. Van Horn-DeWitt

stores herbicides, insecticides, and fertilizers within 5 miles of the site. Cornbelt FS has a large

propane tank at its facility in DeWitt. The staff's review did not identify any relevant facilities not

previously noted by the applicant.

The applicant neither identified nor evaluated any hazards that the existing CPS may pose to a

new facility that might be constructed and operated on the proposed ESP site. Design-specific

interactions between the existing unit and any new units would need to be evaluated and

addressed in a COL application that references an ESP for the EGC ESP site. This is COL

Action Item 2.2-1.

2.2.1.4-2.2.2.4 Conclusions

As discussed above, in accordance with the requirements of 10 CFR 52.17 and the guidance of

RG 1.70, Revision 3, the applicant's SSAR provides enough information on potential site

hazards, for the staff to evaluate the applicant's compliance with the requirements of 10 CFR

2-14
100.20 and 10 CFR 100.21. The staff reviewed the nature and extent of activities involving

potentially hazardous materials at industrial, military, and transportation facilities near the ESP

site to identify any potential hazards that might pose an undue risk to the proposed facility in

this ESP application. Figure 2.2.1-1 shows the locations of the facilities in relation to the E.SP

site. On the basis of its evaluation of the SSAR, a review of the information in responses to

RAls, and independently obtained information, the staff concludes that the applicant has

identified all potentially hazardous activities on and near the site. SSAR and SER

Sections 2.2.3 and 3.5.1.6 discuss the evaluation of the hazards.

2.2.3 Evaluation of Potential Accidents

In SSAR Section 2.2.3, the applicant identifies potential accident situations on and near

the ESID site. The staff reviewed this information to determine its completeness and accuracy

as a basis for the potential accidents that need to be considered in the design of a facility that

might be constructed on the proposed ESP site within the applicant's PPE (see SER

Section 2.2.1-2.2.2).

The applicant elected to use a PPE approach as a surrogate for plant design in analyzing

potential accidents. The applicant has not determined the precise design of the facility control

room. Some potential accidents on or near of the ESP site might affect control room habitability

(e.g.,toxic gases, asphyxiants). The design of the actual facility that might be constructed o:n

the proposed site must address design basis accidents (as determined by the review conducted

using Section 2.2.3 of RS-002, Attachment 2). The staff will review these potential accidents at

the COL or CP stage, using the guidance in SRP Section 6.4.

The staff reviewed the applicant's probability analyses of potential accidents involving

hazardous materials or activities on and near a new nuclear power plant(s) constructed on the

ESP site and determined that these analyses used the appropriate data and analytical models.

The staff also reviewed the applicant's analyses of the consequences of accidents involving

nearby industrial, military, and transportation facilities to determine if any should be identified as

design-basis events.

2.2.3.1 Technical Infornation in the Application

Section 2.2.3 of the SSAR presents information on potential accidents including flammable

vapor cluds, aircraft crashes, and toxic chemicals. The SSAR states that potential accidents

involving transportation routes or flammable, explosive, chemical, or toxic storage at the CPS'

site were dismissed as design concerns in the CPS USAR. The SSAR further states that

certain tDxic chemical hazards cannot be evaluated until the COL stage because the precise

design of the ESP control room habitability systems will not be known until then.

Section :2.2.2.5.3 of the SSAR describes the applicant's analysis of the potential for accidents

originating from airports or airways. SER Section 2.2.1-2.2.2 discusses the locations of

airports and airways, as identified by the applicant. The applicant relied on the CPS USAR and

the SRP for guidance on determining the accident probabilities of airways 5 miles from the ESP

site. The applicant determined that the probability of accidents from plane crashes in the civil

and military airways in the vicinity was less than the SRP guideline of about 10 ' per year.

2-15
The SSAR also states that none of the airports within 10 miles of the ESP site support

operations in excess of the threshold criteria in RG 1.70, Revision 3. Section 2.2.3.1.3 of the

SSAR describes the applicant's analysis of potential accidents involving toxic chemicals. The

Van Horn-DeWitt facility stores and distributes agricultural products such as pesticides,

herbicides, and fertilizers. This facility is next to State Route 54, about 2.6 miles from the ESP

site. The applicant used the guidance in RG 1.78 to demonstrate that a potential spill of

anhydrous ammonia is not a concern because of the small number of shipments made to the

Van Horn-DeWitt facility.

The applicant also found that the CPS USAR used the guidance in RG 1.78 to determine that

the likelihood of potential accidents on the Gilman Line of the Canadian National Railroad,

which runs parallel to State Route 54, is acceptably low. However, CPS has committed to

survey the rail line every 3 years to keep abreast of changes in hazardous material shipments.

The applicant states in SSAR Section 2.2.3.1.2, that a new analysis will be required at the COL

stage for the hazards associated with the Gilman Line. Specifically, the applicant will have to

evaluate the location of the control room of the EGC ESP facility, the control room ventilation

system design, and the analytic methodology for dispersion and transport of airborne

hazardous materials.

SSAR Section 2.2.3.1.2 also states that the probability of a flammable vapor cloud and an

explosion and subsequent overpressure, which could exceed the RG 1.91 acceptance criteria,

is less than 106 per year.

2.2.3.2 Regulatory Evaluation

In RAI 1.5-1 the staff asked the applicant to provide a comprehensive list of NRC regulations

applicable to its ESP SSAR. In its response to RAI 1.5-1, the applicant stated that RS-002,

Attachment 2, identifies the NRC regulations applicable to its ESP SSAR. The staff considered

the following regulatory requirements identified in RS-002, Attachment 2, in reviewing

information on potential accidents that could affect the safe design and siting of a nuclearpower plant(s) that might be constructed at the proposed site within the applicant's PPE:

* 10 CFR 52.1 7(a)(1 )(vii) with respect to the location and description of any nearby

industrial, military, or transportation facilities and routes

* 10 CFR 100.20(b) with respect to the nature and proximity of man-related hazards

* 10 CFR 100.21 (e) with respect to the evaluation of potential hazards associated with

nearby transportation routes and industrial and military facilities

In SSAR Section 2.2, the applicant identifies the following applicable NRC guidance regarding

the evaluation of potential accidents in the vicinity of the proposed ESP site:

* RG 1.91

* RG 1.78, Revision 1

* RG 1.70, Revision 3

* NUREG-0800 (SRP)

* RS-002, Attachment 2

2-16
The slaff used the regulatory positions and criteria in Revision 3 of RG 1.70 to determine the

applicant's compliance with the regulations listed above. Sections 2.2.1-2.2.2, 2.2.3, and

3.5.1.0i of RS-002, Attachment 2, and RG 1.70, Revision 3, provide guidance on the information

appropriate for identifying, describing, and evaluating potential accidents. The staff reviewed

this portion of the application for conformance with the applicable regulations, and considered

the co'responding regulatory guidance.

2.2.3.3 Technical Evaluation

The staff evaluated potential accidents in the vicinity of the proposed ESP site by reviewing

(1) the information provided by the applicant in SSAR Section 2.2.3, (2) the applicant's

responses to RAls, (3) information obtained during a visit to the proposed ESP site and its

vicinity, and (4) other publicly available reference material published by the USGS (see the

Clinton, Heyworth, Maroa, Farmer City North, Farmer City South, LeRoy, Weldon East, Weldon

West, and DeWitt, Illinois, 7.5-minute quadrangle maps) and other topographic maps (see the

Illinois Atlas and Gazetteer), aerial imagery (see Terraserver-usa.com, 2004), and GIS

coverage files (see the Platts POWERmap GIS spatial data).

Section 2.2.1-2.2.2 of this SER describes potential hazards affecting the ESP site. These

hazards include the presence of commercial airways and airport facilities in or near the ESP

site, the onsite storage of chemicals and other materials at the CPS site, three additional

industrial plant sites in the vicinity, and the Gilman Line of the Canadian National Railroad. The

staff notes that the CPS USAR did not find that the potential hazards from flammable, chemical,

explosive, and toxic material storage at CPS constitute design concerns. Therefore, the staff

believes it is unlikely that these hazards would be significant for the ESP site. However, the

staff will review the impact of these hazards at the COL stage to verify that no design-specific

vulnerabilities exist.

Section 3.5.1.6 of this SER provides the staff's evaluation of aircraft hazards.

The staff reviewed the applicant's analysis of the effects of potential explosions and the

formation of flammable vapor clouds. The staff finds that, because of the distance of the

potential ESP facility from the worst-case train tank explosion accident (according to RG 1.91),

no significant damage would be expected to the typical nuclear power plant safety related

structures, systems, and components that might be located on the ESP site. The staff relied on

the CPS USAR analysis of a single year of rail shipment data during the 1981-1982 period.

Reporting of significant changes in the shipment data for the Gilman Rail Line will be required

at the COL stage to account for current shipment characteristics and the actual design of the

control room systems of the new nuclear unit(s).

To ensure that the hazards of the Gilman Rail Line remain acceptably low, the applicant has

noted that the rail shipment data for hazardous materials may need to be periodically updated.

The staff reviewed the applicant's analysis of potential toxic chemical accidents. These

accidents include train and truck tanker spills of anhydrous ammonia, chemical materials that

are stored and used on site at CPS and that could be used and stored at future facilities that

might be constructed on the ESP site, and anhydrous ammonia storage tank failure at the Van

Horn-DeWitt facility. Since the PPE does not specify a control room design, no specific

2-17
determination can be made with respect to control room habitability in the event of a toxic

chemical accident at the site or in the vicinity. Although the applicant cited the USAR's

inventory of toxic chemicals, the actual determination of their impact on a specific plant design

cannot be determined at the ESP stage without a precise set of plant design parameters.

Therefore, the staff cannot evaluate the potential effects of accidents on control room

habitability at this time. The staff will evaluate such effects at the COL stage.

2.2.3.4 Conclusions

As discussed above, the applicant has identified potential accidents related to the presence of

hazardous materials or activities on or near the ESP site that could affect a nuclear power

plant(s) represented by the chosen PPE. The applicant also identified accidents that should be

considered as design-basis events at the COL or CP stage according to 10 CFR Part 100.

Therefore, the staff concludes that the site location is acceptable with regard to potential

accidents that could affect a nuclear power plant(s) based on the applicant's PPE that might be

constructed on the site, and that the site location meets the requirements of 10 CFR

52.17(a)(1)(vii), 10 CFR 100.20(b), and 10 CFR 100.21(e).

2.3 Meteorology

To ensure that a nuclear power plant(s) can be designed, constructed, and operated on an

applicant's proposed ESP site in compliance with the NRC regulations, the NRC staff evaluates

regional and local climatological information, including climate extremes and severe weather

occurrences, that may affect the design and siting of a nuclear plant. The staff reviews

information concerning the atmospheric dispersion characteristics of a nuclear power plant site

to determine whether the radioactive effluents from postulated accidental releases, as well as

routine operational releases, are within Commission guidelines. The staff prepared

Sections 2.3.1 through 2.3.5 of this SER in accordance with the review procedures described in

RS-002, Attachment 2, using information presented in Section 2.3 of the SSAR, responses to

staff RAls, and generally available reference materials, as described in the applicable sections of

RS-002, Attachment 2.

2.3.1 Regional Climatology

2.3.1.1 Technical Information in the Application

In this section of the SSAR, Exelon Generation Company, LLL (EGC or the applicant) presented

information concerning the averages and the extremes of climatic conditions and regional

meteorological phenomena that could affect the design and siting of a nuclear power plant(s)

that falls within the applicant's PPE and that might be constructed on the proposed site. The

applicant provided the following information:

* a description of the general climate of the region with respect to types of air masses,

synoptic features (high- and low-pressure systems and frontal systems), general airflow

patterns (wind direction and speed), temperature and humidity, precipitation (rain, snow,

and sleet), and relationships between synoptic-scale atmospheric processes and local

(site) meteorological conditions

2-18
* seasonal and annual frequencies of severe weather phenomena, including tornadoes,

waterspouts, thunderstorms, lightning, hail (including probable maximum size), and high

air pollution potential

* meteorological site characteristics to be used as minimum design and operating bases,

including the following:

- the maximum snow and ice load (water equivalent) on the roofs of safety-related

structures

- the ultimate heat sink (UHS) meteorological conditions resulting in the maximum

evaporation and drift loss of water and minimum water cooling

- the tornado parameters, including translational speed, rotational speed, and the

maximum pressure differential with the associated time interval

- the 1 00-year return period straight-line winds

- other meteorological conditions used for design- and operating-basis

considerations

The applicant characterized the regional climatology pertinent to the EGC ESP site using data

reported by the U.S. National Weather Service (NWS) at the Peoria, Illinois, and Springfield,

Illinois, first-order weather stations, as well as nearby cooperative observer stations, such as

Decatur, Illinois. The applicant considered the Peoria and Springfield weather stations to be

representative of the climate at the EGC ESP site, because of their relatively close proximity to

the site and similarities in terrain and vegetation features. The applicant obtained information on

severe weather from a variety of sources, such as publications by the National Climatic Data

Center (NCDC), the American Society of Civil Engineers (ASCE), the Illinois State Climatolcgist

Office (ISCO), and the Illinois State Water Survey (ISWS).

The EGCC ESP site is located in the central climatic division of Illinois. The applicant described

the climate as continental, with cold winters, warm summers, and frequent, short-period

fluctuations in temperature, humidity, cloudiness, and wind direction. The great variability in the

central Illinois climate is because of its location in a confluence zone, particularly during the

cooler months, between different air masses. The air masses that affect central Illinois typically

include maritime tropical air, which originates in the Gulf of Mexico; continental tropical air, which

originates in Mexico and the southern Rockies; Pacific air, which originates in Mexico and the

eastern North Pacific Ocean; and continental polar and continental arctic air, which originates in

Canada.

The applicant noted that, for the most part, the general synoptic conditions dominate the

climactic characteristics of the site region. However, during periods of extreme temperatures or

light wind conditions, the local conditions influence the site's meteorology. Nearby Clinton Lake

can have a moderating effect with respect to extreme temperatures in the immediate vicinity of

the site.

2-19
The applicant reported that Peoria and Springfield average approximately 2.2 hail days per year,

with about 55 percent of all hail days occurring in the spring. There is considerable year-to-year

variation in the number of days with hail, with some years reporting as many as 8 hail days.

During the 13-year period from 1955 to 1967, the 1-degree latitude by longitude square

containing the EGC ESP site (approximately 9400 square kilometers) had 15 hailstorms

producing hail 0.75 inch in diameter or greater.

According to the applicant, about 48 thunderstorm days can be expected yearly, most frequently

during June and July. The applicant conservatively estimated that there are approximately

9.4 lightning flashes to earth per year per square kilometer around the site area. Considering

the frequency of thunderstorms and the size of the EGC ESP site (14,000 acres or 56.7 square

kilometers (the EGC ESP site boundary is the same as the Clinton Power Station (CPS) property

lines), the applicant estimated the expected frequency of lightning flashes at the site at 533 per

year. The expected frequency of lightning flashes within the 3.3 square kilometer exclusion area

is 31 flashes per year.

The applicant originally reported 11 tornadoes for DeWitt County during the period 1950-2002.

Since there were numerous tornadoes reported in Illinois during 2003, the staff requested, in

RAI 2.3.1-1, that the applicant update the tornado data presented in its SSAR to include tornado

occurrences recorded during 2003. In its response to RAI 2.3.1-1, the applicant revised its

tornado statistics for DeWitt County, stating that 18 tornadoes were reported during the period

1950-2003. Using various sets of tornado data statistics for the EGC ESP site region, the

applicant calculated an annual tornado probability for a tornado of any intensity in the EGC ESP

site region as ranging from 1.5x1 03 to 3.1 x1 0 3, which corresponds to a tornado return period

ranging from 325 to 670 years. For violent tornadoes (F4 or greater; wind speeds in excess of

207 miles per hour (mi/h)), the applicant calculated an annual tornado probability ranging from

3.8x1 0-5 to 7.9x1 05, which corresponds to a return period ranging from 12,800 to 26,300 years.

The applicant chose a tornado site characteristic wind speed of 300 mi/h based on the maximum

tornado wind speed recommended in SECY-93-087, "Policy, Technical, Licensing Issues---

Pertaining to Evolutionary and Advanced Light-Water Reactor (ALWR) Designs," for use in the

design of evolutionary and passive advanced light-water reactors (ALWRs). Since it does not

believe that citing SECY-93-087 (or any other document related to design certification) is an

adequate justification for selecting a site characteristic tornado wind speed, the staff requested,

in RAI 2.3.1-9, that the applicant provide a safety justification for choosing 300 mi/h as the site

characteristic tornado wind speed. In its response to RAI 2.3.1-9, the applicant cited a tornado

study covering much of the United States east of the Rocky Mountains which showed that the

maximum tornado wind speed expected in central Illinois (where the EGC ESP site is located),

at a probability level of 10-7 per year, is between 250 and 300 mi/h. The applicant chose the

other tornado site characteristics (e.g., maximum pressure drop, rate of pressure drop) based on

the characteristics associated with a tornado wind speed of 300 mi/h, as identified in the staff's

interim position on the design-basis tornado (NRC, "ALWR Design-Basis Tornado").

Table 2.3.1-1 lists the applicant's proposed tornado site characteristics.

2-20
Table 2.3.1-1 Applicant's Proposed Tornado Site Characteristics

SITE

CHARACTERISTIC VALUE DESCRIPTION

Maximum 300 mi/h The design assumption for the sum of maximum

Wind Speed rotational and maximum translational wind speed

components

Maximum 60 mi/h The design assumption for the component of tornado

Translational Speed wind speed resulting from the movement of the tornado

over the ground

Maximum 240 mi/h The design assumption for the component of tornadc

Rotational Speed wind speed caused by the rotation within the tornado

Radius of Maximum 150 feet The design assumption for distance from the center of

Rotational Speed the tornado at which the maximum rotational wind speed

occurs

Maximum 2.0 pounds- The design assumption for the decrease in ambient

Pressure Drop force per pressure from normal atmospheric pressure resulting

square inch from the passage of the tornado

(Ibf/in. 2)

Rate of Pressure 1.2 Ibf/in.2/s The assumed design rate at which the pressure drops

Drop resulting from the passage of the tornado

The applicant stated that the highest "fastest mile" wind speeds observed at the Peoria and

Springfield weather stations were 75 mi/h. In RAI 2.3.1-3, the staff requested that the applicant

clarify the fastest mile and peak wind speed data that it presented in the SSAR. As part of its

response to RAI 2.3.1-3, the applicant reported that the Peoria and Springfield data represent

the 67-year period between 1930 and 1996. The applicant selected this wind speed value as the

basic wind speed site characteristic. In RAI 2.3.1-2, the staff asked the applicant to also provide

a 3-second gust wind speed that represents a 100-year return. In its response to RAI 2.3.1-2,

the applicant provided a 3-second gust wind speed value of 96 mi/h, but did not propose this

value as a site characteristic. Instead, the applicant stated that the 3-second gust wind speed

site characteristic will be determined at the COL or CP stage, based on the applicable design

standard at the time. In its subsequent letter dated April 26, 2005, the applicant chose to identify

the 3-se.-ond gust wind speed value of 96 mi/h as a site characteristic at the ESP stage rather

than at the COL stage.

Table 2.:3.1-2 presents the applicant's proposed basic wind speed site characteristics.

2-21
Table 2.3.1-2 Applicant's Proposed Basic Wind Speed Site Characteristics

SITE

CHARACTERISTIC VALUE DESCRIPTION

Basic Wind Speed 75 mi/h The design wind, or fastest mile of wind with a 1 00-year return

I period, for which the facility is designed

3-Second Gust 96 mi/h The 3-second gust wind velocity associated with a 1 00-year

return period at 33 feet (10 meters) above the ground level in the

site area

In the SSAR, the applicant reported that severe winter storms, which usually produce snowfall in

excess of 6 inches and are often accompanied by damaging glaze ice, produce more damage

than any other form of short-term severe weather, including hail, tornadoes, and lightning.

Central Illinois had 107 occurrences of a 6-inch snow or glaze damage area during the years

from 1900 through 1960, and about 42 of those storms deposited more than 6 inches of snowfall

in DeWitt County. During this same 61-year period, there were 92 severe glaze storms in

Illinois, defined as damaging, widespread, or both. The EGC ESP site region averaged slightly

more than 5 days of glaze per year during the period 1901-1962, and 11 localized areas within

the central third of Illinois can expect to receive damaging glaze during a typical 1 0-year period.

An average of one storm every 3 years will produce glaze ice 0.75 inch or thicker on wires.

According to the applicant, the estimated 2-day and 7-day maximum snowfalls for the EGC ESP

site region associated with a 50-year recurrence interval are 15.2 inches and 22.0 inches,

respectively. The staff requested clarification on the regional snowfall and snowpack data, as

well as the winter probable maximum precipitation value (also known as the "probable maximum

winter precipitation" or PMWP) in RAls 2.3.1-4, 2.3.1-5, 2.3.1-6, and 2.3.1-10. In its response to

RAI 2.3.1-4, the applicant stated that the maximum monthly and 24-hour snowfalls recorded in

the Springfield area are 24.4 inches and 15.0 inches, respectively. In its response to

RAI 2.3.1-10, the applicant noted that the maximum recorded monthly snowfall in the EGC ESP

site region is 30.5 inches, which was recorded in Decatur.

The applicant initially provided a 100-year return period ground-level snowpack estimate of

22 pounds-force per square foot (Ibf/ft2), which it later revised to 24.4 lbf/ft2 in response to

RAI 2.3.1-5. The applicant also provided a 48-hour PMWP value of 15.2 inches of water, which

it subsequently revised to 16.6 inches of water in response to RAI 2.3.1-6. The 48-hour PMWP

value of 16.6 inches corresponds to approximately 86 Ibf/ft2. The combined 1 00-year return

snowpack and the estimated PMWP is 110.4 lbf/ft2, which the applicant contends is an extremely

conservative and highly unlikely snow/ice roof loading for a structure in Illinois. In its response to

RAI 2.3.1-6, the applicant proposed defining the site characteristic ground snow load as

40 lbf/ft2, which represents a combination of the 100-year return snowpack (24.4 Ibf/ft2) and the

maximum recorded monthly snowfall in the region (30.5 inches of snow, which is approximately

equivalent to 3 inches of water or 15.6 lbf/ft2).

Table 2.3.1-3 cites the applicant's proposed winter precipitation site characteristics.

2-22
Table 2.3.1-3 Applicant's Proposed Winter Precipitation Site Characteristics

SITE CHARACTERISTIC VALUE DESCRIPTION

Snow Load 40 Ibf/ft2 The maximum load on structure roofs resulting from the

accumulation of snow that can be accommodated by a plant

_ _ _ _ _I ___ design

In the SSAR, the applicant indicated that the controlling meteorological parameters for the type

of UHS that it selected (i.e., mechanical draft cooling towers with makeup water from Clinton

Lake) is the wet-bulb temperature. In RAI 2.3.1-7, the NRC staff requested that the applicant

clarify the meteorological data that it would use to evaluate the performance of the UHS

mechanical draft cooling towers with respect to maximum evaporation, drift loss, and minimum

water cooling, as discussed in RG 1.27, "Ultimate Heat Sink for Nuclear Power Plants." In its

response to RAI 2.3.1-7, the applicant reiterated that it calculated a maximum evaporation rate

of 700 gallons per minute (Item 3.3.7 in SSAR Table 1.4-1) based on the maximum system heat

load arid the amount of water that would need to be evaporated to dissipate that heat load. The

applicant considers this a highly conservative value because the actual amount of evaporative

cooling that would be necessary would be less for any time period, including the worst 30-day

period discussed in RG 1.27. The applicant stated that the final design of the cooling towers

would account for the bounding ambient air temperature and humidity site characteristic

conditions presented in SSAR Table 1.4-1, which include a design wet-bulb temperature of

77.2 OF that is exceeded less than 1 percent of the time and a maximum wet-bulb temperature of

86 OF. The applicant indicated that it did not expect drift loss to be a critical design parameter

since the drift in a modern cooling tower is typically very low (on the order of 0.1 percent or less).

In Open Item 2.3-1, the staff reiterated that the applicant did not adequately identify the

meteorological data to use in evaluating the performance of a mechanical draft cooling tower

UHS with respect to maximum evaporation and minimum water cooling, as discussed in

RG 1.27. In its submission to the NRC dated April 4, 2005, the applicant responded to Open

Item 2.3-1 by examining temperature and humidity data from both the Peoria and Springfield

weather stations for the years 1961-1990 to determine the meteorological site characteristics for

the UHS, in accordance with RG 1.27. The applicant stated that the controlling parameters for

the type of UHS it selected are the wet-bulb temperature and the coincident dry-bulb

temperature. The applicant considered the worst (i.e., highest) 30-day running average of wetbulb temperatures and coincident dry-bulb temperatures to represent the meteorological

conditions resulting in maximum evaporation and drift loss. Likewise, the applicant considered

the worst (i.e., highest) 1-day and 5-day running average of wet-bulb temperatures and

coincident dry-bulb temperatures to represent the meteorological conditions resulting in

minimum water cooling. Consequently, the applicant calculated the worst 1-day, worst 5-day,

and worst 30-day running average wet-bulb temperatures and coincident dry-bulb temperatures

as UHS meteorological site characteristic values.

In Open Item 2.3-2, the staff identified the need for an additional UHS meteorological site

characteristic for use in evaluating the potential for water freezing in the UHS water storage

facility, a phenomenon which would reduce the amount of water available for use by the UHS. In

its submission to the NRC dated April 26, 2005, the applicant responded to Open Item 2.3-2 by

proposing to use the maximum cumulative degree-days below freezing during the winter as the

2-23
relevant site characteristic. This site characteristic is discussed in detail in Section 2.4.7 of this

SER.

Table 2.3.1-4 presents the applicant's proposed UHS meteorological site characteristics.

Table 2.3.1-4 Applicant's Proposed Ultimate Heat Sink Meteorological Site

Characteristics

SITE CHARACTERISTIC VALUE DESCRIPTION

Maximum 30-Day Average 74.7 'F The historical maximum 30-day running average wetWet-Bulb Temperature bulb temperature observed in the site region

Coincident 30-Day Average 82 'F The 30-day average dry-bulb temperature that coincides

Dry-Bulb Temperature with the historical maximum 30-day average wet-bulb

temperature

Maximum 1-Day Average 81 OF The historical maximum 1-day average wet-bulb

Wet-Bulb Temperature temperature observed in the site region

Coincident 1-Day Average 87.6 0F The 1-day average dry-bulb temperature that coincides

Dry-Bulb Temperature with the historical maximum 1-day average wet-bulb

temperature

Maximum 5-Day Average 79.7 OF The historical maximum 5-day average wet-bulb

Wet-Bulb Temperature temperature observed in the site region

Coincident 5-Day Average 86.2 'F The 5-day average dry-bulb temperature that coincides

Dry-Bulb Temperature with the historical maximum 5-day average wet-bulb

temperature

The applicant stated that central Illinois is in a relatively favorable dispersion regime that has a

relatively low frequency of extended periods of high air pollution potential. Inversions based

below 500 feet occur in the general area of the EGC ESP site during approximately 33 percent

of the total hours throughout the year and occur most frequently in the fall (39 percent of the

total time) and least frequently in the winter and spring (29 percent of the total time for each

season). Seasonal morning average mixing layer heights in the EGC ESP site region range

from a low of 330 meters during the summer to a high of 490 meters in the spring, and seasonal

afternoon average mixing layer heights range from a low of 690 meters in the winter to a high of

1600 meters in the summer.

In RAI 2.3.1-8, the staff requested that the applicant provide ambient air temperature and

humidity site characteristics. In its response to RAI 2.3.1-8, the applicant provided dry-bulb and

wet-bulb temperature site characteristics based on temperature and humidity data recorded at

the Peoria and Springfield weather stations. Table 2.3.1-5 presents the applicant's proposed

ambient air temperature and humidity site characteristics.

2-24
Table 2.3.1-5 Applicant's Proposed Ambient Air Temperature and Humidity Site!

Characteristics

SITE CHARACTERISTIC VALUE DESCRIFTION

Maximum Dry- 2% annual 88 OF with 74 OF concurrent wet-bulb Wet-bulb and

Bulb exceedance dry-bulb

Temperature temperatures 1% annual 91 'IF associatec with

exceedance the listed

0.4% annual 94 'F with 77 OF concurrent wet-bulb exceedance

exceedance values and the 1 00-year return

0% annual 117 OFperiod

exceedance

1 00-year 117 OF with 86 'F concurrent wet-bulb

return period

Minimum 1% annual 0 OF

Dry-Bulb exceedance

Temperature 0.4% annual

0.4% nnual-6 °F

exceedance

0% annual -360 F

exceedance

100-year -360 F

return period

Maximum 1% annual 78 0F

Wel -Bulb exceedance

Temperature 0.4% annual

exceedance

0% annual 86 OF

exceedance

100-year 86 OF

return period

2.3.1.2 Regulatory Evaluation

In response to RAI 1.5-1, the applicant stated that RS-002, Attachment 2, identifies the

regulations applicable to the ESP SSAR. RS-002, Attachment 2, identifies the following

applicable NRC regulations regarding regional climatology:

* Appendix A, "General Design Criteria for Nuclear Power Plants," to Part 50, "Domest c

l.icensing of Production and Utilization Facilities," of Title 10 of the Code of Federal

Regulations (10 CFR), General Design Criterion (GDC) 2, "Design Bases for ProtectiDn

Against Natural Phenomena," with respect to information on severe regional weather

2-25
phenomena that have historically been reported for the region and that are reflected in

the design bases for SSCs important to safety

* Appendix A to 10 CFR Part 50, GDC 4, "Environmental and Dynamic Effects Design

Bases," with respect to information on tornadoes that could generate missiles

* 10 CFR 1 00.20(c) and 10 CFR 100.21 (d), with respect to the consideration of the

regional meteorological characteristics of the site

In SSAR Sections 1.1.1, 1.5, and 2.3.1, the applicant identified the following applicable NRC

guidance regarding regional climatology:

* RG 1.27, Revision 2, with respect to the meteorological conditions that should be

considered in the design of the UHS

* Section 2.3.1 of RG 1.70 with respect to the type of general climate and regional

meteorological data that should be presented

* RG 1.76, "Design-Basis Tornado for Nuclear Power Plants," issued April 1974, with

respect to the characteristics of the design-basis tornado

The staff reviewed this portion of the application for conformance with the applicable regulations,

and considered the corresponding regulatory guidance, with the exception that an ESP applicant

need not demonstrate compliance with the GDC.

Section 2.3.1 of RS-002, Attachment 2, and RG 1.70 provide the following guidance on

information appropriate for determining regional climatology:

* The description of the general climate of the region should be based on standard climatic

summaries that the National Oceanic and Atmospheric Administration compiles.

Consideration of the relationships between regional synoptic-scale atmospheric

processes and local (site) meteorological conditions should be based on appropriate

meteorological data.

* Data on severe weather phenomena should be based on standard meteorological

records from nearby representative NWS, military, or other stations recognized as

standard installations that have long periods of data on record. The applicability of these

data to represent site conditions during the expected period of reactor operation should

be substantiated.

* Tornado site characteristics may be based on RG 1.76 or the staff's interim position on

design-basis tornado characteristics (NRC, "ALWR Design-Basis Tornado"). An ESP

applicant may specify any tornado wind speed site characteristics that are appropriately

justified, provided that it conducts a technical evaluation of site-specific data.

* Basic (straight-line) wind speed site characteristics should be based on appropriate

standards, with suitable corrections for local conditions.

2-26
* The UHS meteorological data, as stated in RG 1.27, should be based on long-period

regional records that represent site conditions. Suitable information may be found in

climatological summaries for the evaluation of wind, temperature, humidity, and other

meteorological data used for UHS design.

* Freezing rain estimates should be based on representative NWS station data.

* High air pollution potential information should be based on U.S. Environmental Protection

Agency (EPA) studies.

* All other meteorological and air quality data to be used for safety-related plant design

and operating bases should be documented and substantiated.

2.3.1.3 Technical Evaluation

The stEff evaluated regional meteorological conditions using information that the NCDC,

National Severe Storms Laboratory (NSSL), ISCO, and ASCE reported. The staff reviewed

statistics for the following climatic stations located in the vicinity of the EGC ESP site:

* Clinton, Illinois, located approximately 7 miles west-southwest of the ESP site

* Decatur, Illinois, located approximately 24 miles south-southwest of the ESP site

* Lincoln, Illinois, located approximately 26 miles west of the ESP site

* Springfield, Illinois, located approximately 50 miles west-southwest of the ESP site

* Peoria, Illinois, located approximately 56 miles west-northwest of the ESP site

The staff concurs with the applicant's description of the general climate of the region, which is

consistent with a narrative of the climate of Illinois published by ISCO (ISCO, "Climate of

Illinois"). The staff also finds the applicant's estimates of thunderstorm-day frequency consistent

with regional data and its estimates of expected frequency of lightning flashes to be consistent

with accepted methodology.

Hail often accompanies severe thunderstorms and can be a major weather hazard, causing

damage to crops and property. According to NSSL, the threat of hail occurring within 25 miles of

the EGG ESP site is approximately 2-3 days per year for damaging hail, or hail 0.75 inch in

diameter or greater, and 0.50 to 0.75 days per year for hail 2 inches or more in diameter

(NSSL, 'Severe Thunderstorm Climatology").

The above discussion on lightning and hail provides a general climatic understanding of the

severe weather phenomena in the site region but does not result in the generation of site

characteristics for use as design or operating bases.

According to NSSL, the mean number of days per year with the threat of tornados occurring

within 2'5 miles of the EGC ESP site is approximately 1.0 to 1.2 days per year for any tornado,

approximately 0.20 to 0.25 days per year for a significant tornado (F2 or greater; wind speeds in

excess of ,113 mVh), and approximately 0.01 5'to 0.020 days per year for a violent tornado (Fa4 or

greater; wind speeds in excess of 207 mi/h) (NSSL, "Severe Thunderstorm Climatology").

2-27
At the staff's direction, Pacific Northwest National Laboratories (PNNL) prepared a technical

evaluation report evaluating the tornado site characteristics for the EGC ESP site (Ramsdell,

"Technical Evaluation Report on Design Basis Tornadoes for the EGC ESP Site"). This report

derived a best estimate annual tornado strike probability of 1.2x1 0-, based on tornado data

from the period January 1950 through August 2003. This corresponds to a mean recurrence

interval of 833 years, which is slightly less conservative than the applicant's calculated tornado

return period (i.e., 325 to 670 years). The PNNL report also derived a best estimate 107 per

year occurrence tornado site characteristic wind speed of 300 mi/h, which is equal to the

applicant's tornado site characteristic wind speed. The applicant chose the other design-basis

tornado characteristics (such as translation speed, rotational speed, etc.) associated with a

tornado wind speed of 300 mi/h as identified in the staff's interim position (NRC, "ALWR Design

Basis Tornado"). Therefore, the staff concludes that the applicant's design-basis tornado site

characteristics are acceptable.

The applicant's proposed basic wind speed site characteristic of 75 mi/h is compatible with the

fastest mile wind speeds having a 1 percent annual probability of being exceeded (100-year

mean recurrence interval) of 75 mi/h and 74 mi/h for Peoria and Springfield, respectively, as

reported in Table A7 of American National Standards Institute (ANSI) A58.1-1982, "Minimum

Design Loads for Buildings and Other Structures." Therefore, the staff concludes that a

fastest mile basic wind speed site characteristic of 75 mi/h is acceptable.

The applicant also defined a 3-second gust wind speed site characteristic of 96 mi/h, based on a

100-year return period at 10 meters above the ground. The applicant determined this value in

accordance with the guidance provided by Structural Engineering Institute (SEI)/ASCE 7-02,

'Minimum Design Loads for Buildings and Other Structures." Therefore, the staff concludes that

a 3-second gust basic wind speed site characteristic of 96 mi/h is acceptable.

The NCDC reports a 50-year period return period uniform radial ice thickness of 1 inch because

of freezing rain, with a concurrent 3-second gust wind speed of 40 mi/h for the EGC ESP site

area (Jones et al., 'The Development of a U.S. Climatology of Extreme Ice Loads").

Snowfall in the site vicinity averages approximately 21.9 inches per year, based on historical

data collected during the period 1971-2000 at the Decatur cooperative weather station. The

highest monthly and seasonal total snowfalls recorded at Decatur during the period of record

1893-2001 were 30.5 inches and 49.7 inches, respectively (ISCO, "Historical Climate

Summary-112193 Decatur, IL"). One of the highest reported 24-hour snowfall observations in

the site region was 17.0 inches in December 1972 at Springfield (ISCO, "Historical Climate

Summary-118179 Springfield WSO AP, IL").

RG 1.70 specifies both the weight of the 100-year return period snowpack and the weight of the

48-hour PMWP as a means of assessing the potential snow loads on the roofs of safety-related

structures. The staff's branch position on winter precipitation loads (see memorandum dated

March 24, 1975, from Harold R. Denton to R. R. Maccary) provides clarification as to the load

combinations to be used in evaluating the roofs of safety-related structures. Consistent with the

staff's branch position on winter precipitation loads, the winter precipitation loads included in the

combination of normal live loads considered in the design of a nuclear power plant that might be

constructed on a proposed ESP should be based on the weight of the 100-year snowpack or

snowfall, whichever is greater, recorded at ground level. Likewise, the winter precipitation loads

2-28
included in the combination of extreme live loads considered in the design of a nuclear power

plant that might be constructed on a proposed ESP should be based on the weight of the

100-year snowpack at ground level plus the weight of the 48-hour PMWP at ground level for the

month corresponding to the selected snowpack. A COL or CP applicant may choose to justify

an alternative method for defining the extreme winter precipitation load by demonstrating that the

48-hour PMWP could neither fall nor remain on the top of the snowpack and/or building roofs.

The applicant identified a 100-year return period snowpack of 24.4 lbf/ft2 for the EGC ESP site,

determining this value in accordance with the guidance of ASCE 7-98, "Minimum Design Loads

for Buildings and Other Structures.' Because the applicant performed its analysis in accordance

with the appropriate guidance and the results bound the observations described above, the staff

concludes that a 100-year return period snowpack site characteristic value of 24.4 lbf/ft2 is

acceptable.

The applicant identified a 48-hour PMWP value of 16.6 inches of water for the EGC ESP site.

The applicant determined this value for a 296 square-mile drainage area (representing the

drainage area surrounding the ESP site) using information available from HMR 51, "Probable

Maximum Precipitation Estimates, United States East of the 105w" Meridian," and HMR 53,

"Seascnal Variation of 10-Square-Mile Probable Maximum Precipitation Estimates, United

States East of the 105th Meridian." The staff performed an independent 48-hour PMWP

evalualion for a smaller (more conservative) 10 square-mile drainage basin using information

available from HMR 53. The staff derived a 48-hour PMWP value of 18.2 inches of water for

those months with the historically highest snow depths (i.e., December through March). The

staff's slightly higher value is most likely the result of using a smaller drainage area (i.e.,

10 square miles versus 296 square miles). Nonetheless, since the staff's 48-hour PMWP value

is within 10 percent of the applicant's 48-hour PMWP value, the staff concludes that the

applicanit's 48-hour PMWP site characteristic value of 16.6 inches of water is acceptable.

The applicant proposed a site characteristic ground snow load value of 40 lbf/ft2, which

represents a combination of the 100-year return snowpack (24.4 lbf/ftW) and the maximumrecorded monthly snowfall in the region (30.5 inches of snow, which is approximately equivalent

to 15.6 lbf/ft2). The applicant believes that the extreme winter precipitation roof load of

110.4 Itf/ft2 (which represents the combined loading of the 100-year return snowpack and the

48-hour PMWP) is an unreasonable snow/ice roof loading for a structure at the EGC ESP size.

Nonetheless, the staff has chosen not to include the applicant's proposed ground snow load

value of 40 lbf/ft2 as an ESP site characteristic. Once the roof design is known, the COL or CP

applicant has the option to demonstrate that the 48-hour PMWP could neither fall nor remain

entirely -n top of the 100-year snowpack and/or building roofs.

In response to Open Item 2.3-1, the applicant provided UHS meteorological site characteristics

to use in evaluating the performance of a mechanical draft cooling tower UHS with respect to

maximum evaporation and minimum water cooling. To verify the applicant's site characteristics,

the staff examined 30 years (1 961-1990) of hourly temperature and humidity data from Peoria

and Springfield (NCDC, "Solar and Meteorological Surface Observational Network (SAMSON)

for Central U.S. CDROM"). The staff calculated 1 -day, 5-day, and 30-day average wet-bulb

temperatures from the hourly data and selected the periods with the highest average wet-bulb

temperatures as the worst periods. The resulting maximum 1-day, 5-day, and 30-day average

2-29
wet-bulb temperature values were similar to the values presented by the applicant. Therefore,

the staff considers open Items 2.3-1 resolved.

The applicant provided an additional UHS meteorological site characteristic for use in evaluating

the potential for water freezing in the UHS water storage facility in response to Open Item 2.3-2.

This site characteristic is discussed in detail in Section 2.4.7 of this SER. Based on the

discussion in Section 2.4.7 of this SER, the staff considers open Items 2.3-2 resolved.

Based on the discussion presented above, the staff concludes that the UHS meteorological site

characteristics proposed by the applicant are acceptable.

Large-scale episodes of atmospheric stagnation are not common in the site region. During the

40-year period from 1936 to 1975, high-pressure stagnation conditions lasting for 4 days or

more occurred about 15 times, with an average of 5.4 stagnation days per case. Only two of

these stagnation cases lasted 7 days or longer (Korshover, 'Climatology of Stagnating

Anticyclones East of the Rocky Mountains, 1936-1975"). This discussion of atmospheric

stagnation provides a general climatic understanding of the air pollution potential in the region.

Section 2.3.2 of this SER discusses the ESP air quality conditions considered for design and

operating bases. Sections 2.3.4 and 2.3.5 of this SER present the atmospheric dispersion site

characteristics used to evaluate short-term postaccident airborne releases and long-term routine

airborne releases.

Normal climatic data for the period 1971-2000 that the NCDC reported for the central climatic

division of Illinois indicate that the annual mean temperature in the area is about 50.9 OF and

ranges from a low monthly mean value of 22.9 OF in January to a high monthly mean value of

74.9 OF in July (NCDC, 'Central Illinois Divisional Normals-Temperature, Period 1971-2000").

One of the highest temperatures recorded in the site region was 113 0F at Decatur on July 14,

1954 (ISCO, "Historical Climate Summary-112193 Decatur, IL"), Lincoln on July 15, 1936

(ISCO, "Historical Climate Summary-1 15079 Lincoln, IL"), and Peoria on July 15, 1936 (ISCO,

'Historical Climate Summary-1 16711 Peoria WSO Airport, IL"). One of the lowest --

temperatures recorded in the site region was -29 OF at Lincoln on December 26, 1914 (ISCO,

'Historical Climate Summary-1 15079 Lincoln, IL").

The annual mean wet-bulb temperatures at Peoria and Springfield are 47.0 OF and 47.5 OF,

respectively. The Peoria wet-bulb temperatures range from a high monthly mean value of

69.2 OF in July to a low monthly mean value of 23.4 0F in January, while the Springfield wet-bulb

temperatures range from a high monthly mean value of 68.4 OF in July to a low monthly mean

value of 25.5 0F in January. The annual mean relative humidity is 70 percent at both Peoria and

Springfield (NCDC, "Peoria, Illinois, 2003 Local Climatological Data, Annual Summary with

Comparative Data," and NCDC, "Springfield, Illinois, 2003 Local Climatological Data, Annual

Summary with Comparative Data").

For the following reasons, the staff concurs with the applicant's temperature and humidity site

characteristics. The applicant's 2-percent, 1-percent, and 0.4-percent annual exceedance

maximum dry-bulb (and, where applicable, concurrent wet-bulb) temperatures, the 1-percent and

0.4-percent annual exceedance minimum dry-bulb temperatures, and the 1-percent and

0.4-percent exceedance maximum wet-bulb temperatures are based on the Peoria and

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Springfield data published by the NCDC (NCDC, "Engineering Weather Data CDROM").(1) *The

staff believes that the applicant used the record highest temperature for Illinois, as reported by

both the NCDC (NCDC, 'Temperature Extremes") and ISCO (ISCO, "Illinois Records"), to

represent the 0-percent annual exceedance and 100-year return period maximum dry-bulb

temperature values. Likewise, the applicant apparently used the record lowest temperature for

Illinois, as reported by both the NCDC (NCDC, 'Temperature Extremes") and ISCO (ISCO,

"Illinois Records"), to represent the 0-percent annual exceedance and 100-year return period

minimum dry-bulb temperature values. The applicant estimated the 1 00-year return period

maximum wet-bulb temperature from the 2-percent occurrence and median annual extreme high

wet-butb temperatures reported for Peoria, Springfield, and Decatur (NCDC, "Engineering

Weather Data CDROM").

To veri y the applicant's 1 00-year return period data, the staff also calculated 1 00-year return

period maximum and minimum dry-bulb temperatures and maximum wet-bulb temperatures

using NCDC data for Peoria and Springfield during the period 1961-1990 (NCDC, 'Solar and

Meteorological Surface Observational Network (SAMSON) for Central U.S. CDROM") and

algorithms based on the Gumbel Type 1 extreme value distribution defined in Chapter 27,

'Climatic Design Information," of the 2001 American Society of Heating, Refrigerating and

Air-Conditioning Engineers (ASHRAE) Handbook, Fundamentals. The staff found that the

1 00-year return period maximum and minimum dry-bulb temperatures and maximum wet-bulb

temperature values presented by the applicant bound the corresponding values that the staff

calculated.

The staff will include the regional climatology site characteristics listed in Table 2.3.1-6 in any

ESP permit that the NRC might issue for the EGC ESP site.

Table 2.3.1-6 Staff's Proposed Regional Climatic Site Characteristics

SITE CHARACTERISTIC VALUE DESCRIPTION

Ambieni Air Temperature and Humidity

Maximum 2% annual 88 OF with 74 0F concurrent wet- The ambient dry-bulb temperature (and

Dry-Bulb exceedance bulb coincident wet-bulb temperature) that will be

Temperature exceeded 2% of the time annually

1% annual 91 OF The ambient dry-bulb temperature that will

. exceedance be exceeded 1% of the time annually

0.4% annual 94 OF with 77 'F concurrent wet- The ambient dry-bulb temperature (and

exceedance bulb coincident wet-bulb temperature) that will be

exceeded 0.4% of the time annually

1 00-year 117 0FThe ambient dry-bulb temperature that has a

return period 1% annual probability of being exceeded

(100-year mean recurrence interval)

-

1 The data presented by the applicant as minimum 1-percent and 0.4-percent annual

exceedance values are equivalent to the NCDC 99.0 and 99.6 percent occurrence values.

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SITE CHARACTERISTIC VALUE DESCRIPTION

Minimum 99% annual 0 0F The ambient dry-bulb temperature below

Dry-Bulb exceedance which dry-bulb temperatures will fall 1% of

Temperature the time annually

99.6% annual -6 F The ambient dry-bulb temperature below

exceedance which dry-bulb temperatures will fall 0.4% of

the time annually

100-year -36 F The ambient dry-bulb temperature for which

return period a 1% annual probability of a lower dry-bulb

temperature exists (100-year mean

recurrence interval)

Maximum 1% annual 78 OF The ambient wet-bulb temperature that will

Wet-Bulb exceedance be exceeded 1% of the time annually

Temperature 0.4%0 annual 80 F The ambient wet-bulb temperature that will

exceedance be exceeded 0.4% of the time annually

100-year 86 OF The ambient wet-bulb temperature that has a

return period 1% annual probability of being exceeded

(100-year mean recurrence interval)

Basic Wind Speed

Fastest Mile 75 mi/h The fastest-mile wind speed to be used in

determining wind loads, defined as the

fastest-mile wind speed at 33 feet

(10 meters) above the ground that has a 1%

annual probability of being exceeded

(100-year mean recurrence interval)

3-Second Gust 96 mi/h The 3-second gust wind speed to be used in

determining wind loads, defined as the

3-second gust wind speed at 33 feet

(10 meters) above the ground that has a 1%

annual probability of being exceeded

(100-year mean recurrence interval)

Tomado

Maximum Wind Speed 300 mi/h Maximum wind speed resulting from passage

of a tornado having a probability of

occurrence of 10-7 per year

Translational Speed 60 mi/h Translation component of the maximum

tornado wind speed

Rotational Speed 240 mih Rotation component of the maximum tornado

wind speed

Radius of Maximum Rotational 150 feet Distance from the center of the tornado at

Speed which the maximum rotational wind speed

occurs

Maximum Pressure Drop 2.0 Ibf/in.2 Decrease in ambient pressure from normal

atmospheric pressure resulting from passage

of the tornado

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SITE CHARACTERISTIC VALUE | DESCRIPTION

Maximum Rate of Pressure 1.2 lbf/in.2/s Rate of pressure drop resulting from thi

Drop passage of the tornado

Winter Precipitation

100-Year Snowpack 24.4 Ibf/ft2 Weight of the 100-year return period

snowpack (to be used in determining normal

winter precipitation loads for roofs)

48-Hour Probable Maximum 16.6 in. of water Probable maximum precipitation during the

Winter Precipitation winter months (to be used in conjunction with

the 100-year snowpack in determining

extreme winter precipitation loads for roofs)

Ultimate Heat Sink

Meteorological Conditions 81 OF wet-bulb temperature with Historic worst 1-day average wet-bulb

Resulting in the Minimum coincident 87.6 OF dry-bulb temperature and coincident dry-bulb

Water Cooling during Any temperature temperature

1 Day

Mete )rological Conditions 79.7 0F wet-bulb temperature with Historic worst 5-day average wet-bulb

Resulting in the Minimum coincident 86.2 OF dry-bulb temperature and coincident dry-bulb

Water Cooling during Any temperature temperature

Consecutive 5 Days

Meteorological Conditions 74.7 OF wet-bulb temperature with Historic worst 30-day average wet-bulb

Resulting in the Maximum coincident 82 'F dry-bulb temperature and coincident dry-bulb

Evaporation and Drift Loss temperature temperature

during Any Consecutive

30 Days .-

The staff acknowledges that long-term climatic change resulting from human or natural causes

may introduce trends into design conditions. However, no conclusive evidence or consensus of

opinion is available on the rapidity or nature of such changes. If in the future the ESP site is no

longer in compliance with the terms and conditions of the ESP (e.g., new information shows that

the climatic site characteristics no longer represent extreme weather conditions resulting from

climate change), the staff will seek to modify the ESP or impose requirements on the site in

accordance with the provisions of 10 CFR 52.39, "Finality of Early Site Permit Determinations."

2.3.1.4 Conclusions

As set forth above, the applicant presented and substantiated information relative to the regional

meteorological conditions important to the safe design and siting of a nuclear power plant(s)

falling within its PPE that might be constructed on the proposed site. The staff reviewed the

available information provided and, for the reasons given above, concludes that the identification

and con sideration of the regional and site meteorological characteristics set forth above meet

the requirements of 10 CFR 100.20(c) and 10 CFR 100.21 (d).

The staff finds that the applicant considered the most severe regional weather phenomena in

establishing the site characteristics identified above. The staff has generally accepted the

methodologies used by the applicant to determine the severity of the weather phenomena

reflected in these site characteristics, as documented in SERs for previous licensing actions.

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Accordingly, the staff concludes that the use of these methodologies results in site

characteristics containing margin sufficient for the limited accuracy, quantity, and period of time

in which the data were accumulated. In view of the-above, the site characteristics identified

above are acceptable for use as part of the design bases for SSCs important to safety, as may

be proposed in a COL application.

With regard to tornado wind speed, the applicant cited a tornado study covering much of the

United States east of the Rocky Mountains, including central Illinois where the EGC ESP site is

located. The staff conducted its own evaluation of site-specific tornado data and concluded that

the results justify the applicant's proposed site tornado characteristics. In addition, the staff finds

that these tornado site characteristics are acceptable for the design-basis tornado used for the

generation of missiles. .

The staff reviewed the applicant's proposed site characteristics related to climatology for

inclusion in an ESP for the site, if one is issued, and finds these characteristics acceptable. The

staff also reviewed the applicant's proposed design parameters (PPE values) for inclusion in

such an ESP (SSAR Section 1.3) and finds them to be reasonable. The staff did not perform a

detailed review of these parameters.

2.3.2 Local Meteorology

2.3.2.1 Technical Information in the Application

In this section of the SSAR, the applicant presented local (site) meteorological information. This

SSAR section also addresses the potential influence of construction and operation of a nuclear

power plant(s) falling within the applicant's PPE on local meteorological conditions that might in

turn adversely impact such plant(s) or the associated facilities. Finally, the applicant provided a

topographical description of the site and its environs and presented the following information:

* a description of the local (site) meteorology in terms of airflow, temperature, atmospheric

water vapor, precipitation, fog, atmospheric stability, and air quality

* an assessment of the influence on the local meteorology of the construction and

operation of a nuclear power plant(s) and its facilities falling within the applicant's PPE

that might be built on the proposed site, including the effects of plant structures, terrain

modification, and heat and moisture sources resulting from plant operation

* a topographical description of the site and its environs, as modified by the structures of a

nuclear power plant(s) falling within the applicant's PPE that might be constructed on the

proposed site

The applicant characterized local meteorological conditions using data collected from the

meteorological monitoring program at the existing CPS. According to the applicant, the

meteorological variables collected by the CPS monitoring program are appropriate for use in

describing local meteorological conditions because of the proximity of the CPS meteorological

tower to the ESP site. The applicant used two periods of record to characterize local

meteorological conditions-April 1972 through April 1977 (pre-CPS construction) and January

2000 through August 2002 (post-CPS construction).

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The applicant presented wind data from the 10-meter (33-foot) level of the CPS onsite

meteorological tower for both the pre-CPS construction period (1 972-1977) and the post-CPS

construction period (2000-2002). The 1972-1977 wind direction data indicate that the

predominant wind directions were from the south and south-southwest (about 10 percent of the

time fcr each sector). The 2000-2002 wind data indicate that the predominant wind directions

were from the south (about 11 percent of the time) and south-southwest (about 10 percent of the

time). The 1972-1977 median wind speed was about 3.8 meters per second (m/s) as compared

to the 2000-2002 median wind speed of approximately 2.8 m/s. Seasonal variations are also

evident from the data, with winter months showing generally higher wind speeds, fewer caIrns,

and more west-northwest wind in comparison to the summer months.

The average ambient dry-bulb temperature recorded on site during the period of record

1972-1977 was 10.5 `C (50.9 OF), ranging from a low monthly mean value of -5.1 0C (22.8 OF)

in January to a high monthly mean value of 23.6 CC (74.5 OF) in July. The annual average

relative humidity during the same period of record was 68.3 percent. The annual average

dewpoint temperature was 4.7 0C (40.5 0F), ranging from a low monthly mean value of -7.8 0C

(18.0 01) in January to a high monthly mean value of 16.5 OC (61.7 OF) in July. Table 2.3-13 of

the SSAR also contains a summary of CPS wet-bulb temperature measurements.

In RAI :2.3.2-6, the staff inquired about the CPS wet-bulb temperature statistics, given that nearly

all of the CPS wet-bulb temperature values presented in SSAR Table 2.3-13 exceeded the

corresponding CPS dry-bulb temperature values presented in SSAR Table 2.3-9. In its

response to RAI 2.3.2-6, the applicant agreed that the wet-bulb temperatures presented in

SSAR Table 2.3-13 were inconsistent with what would be expected when compared to the drybulb temperatures in SSAR Table 2.3-9. Since it did not use the wet-bulb temperatures

presented in Table 2.3-13 to define any site characteristics, the applicant committed to deleting

the SSAR Table 2.3-13 wet-bulb temperature data from the SSAR.

Since the temperature and humidity data presented in the SSAR were collected during the

period 1972-1977 (before the installation of Clinton Lake and the operation of the CPS oncethrough cooling system), the staff asked the applicant in RAI 2.3.2-2 whether these data remain

representative of the EGC ESP site, given that the site is now adjacent to a heated lake. The

applicant responded that, since the meteorological tower is located approximately 0.5 miles from

the nearest shoreline and the nearest shoreline is more than 4 miles downstream of the CP';

thermal plume discharge location, it expects that the heating effects attributable to elevated

water temperatures in the lake are minimal, if even measurable, at the location of the

meteorological tower. The applicant made qualitative comparisons of the 1972-1977 and

2000-2002 temperature and humidity datasets, concluding that the two datasets were

compatible, given the kinds of variations that would be expected for the two periods of record.

The average yearly precipitation recorded on site during the period of record, 1972-1977, was

25.47 inches, with monthly averages ranging from 1.15 inches in February to 4.16 inches in

June.

According to the applicant, the closest locations to the EGC ESP site that have a fog dataset are

Peoria and Springfield. Peoria averages 20 days per year of heavy fog, whereas Springfield

averages 18.5 days of heavy fog per year. The highest occurrence of fog is in the winter months

for both ocations. The applicant noted that the Peoria and Springfield fog statistics should be

2-35
considered regional estimates because they do not account for any local fog occurrences

resulting from the once-through cooling system (Clinton Lake) used by the existing CPS. The

applicant presented the results of an analytical model used as part of the license application for

CPS to estimate the impacts of fog associated with the presence of Clinton Lake and the oncethrough cooling system. This model predicted that 316 hours of heavy fog would occur at the

CPS reactor building complex. The model also predicted the maximum horizontal extent of

steam fog from Clinton Lake as 1 mile or less, with the extent of extremely dense steam fog

being limited to an area immediately adjacent to Clinton Lake.

The SSAR presents atmospheric stability data for the periods 1972-1977 and 2000-2002,

based on delta-temperature measurements between the 60-meter and 10-meter levels on the

CPS meteorological tower and the variation of horizontal wind direction. Data for the later time

period show that neutral (Pasquill type "D") and slightly stable (Pasquill type "E") conditions

predominate, occurring about 35 percent and 25 percent of the time, respectively. 'Moderately

stable (Pasquill type "F') and extremely stable (Pasquill type "G") conditions occur about

9 percent and 4 percent of the time, respectively.

In RAI 2.3.2-5, the staff asked the applicant to identify the air quality characteristics that would

be included in the design and operating bases for a nuclear plant(s) that might be constructed

on the ESP site. The applicant responded that the ESP site is located within the east-central

Illinois Interstate Air Quality Control Region, which has been designated as in attainment of the

national ambient air quality standards. Before construction, the Illinois EPA will require the ESP

facility to obtain air permits demonstrating that the ambient air quality standards will not be

threatened or exceeded as a result of the facility's operation.

The applicant stated that the construction and operation of the ESP facility may influence the

local meteorology of the area in the immediate vicinity of the ESP facility, primarily because of

minor changes to the topography resulting from the construction of additional buildings and

supporting infrastructure and the use of cooling towers for system heat rejection to the

atmosphere. The applicant expects that the minor changes in local topography will not have a

significant impact on diffusion characteristics except in the immediate vicinity of the buildings

themselves.

The use of natural draft cooling towers or mechanical draft cooling towers or both for system

heat rejection will result in visible moisture plumes from the cooling towers, primarily during

winter months when ambient air temperatures are cool and the air is moist. Icing caused by the

freezing of condensed water vapor from the cooling tower plumes could affect vertical surfaces

(such as buildings and equipment) and horizontal surfaces (such as roadways) in the immediate

vicinity of the cooling towers. The applicant expects that these impacts will occur only at onsite

locations. In the SSAR, the applicant stated that the quantification of these ambient impacts will

require a more in-depth assessment once it determines the facility's cooling system

configuration and design parameters.

The applicant stated that the ESP site region is characterized by relatively flat terrain ranging

from 95 feet below to 25 feet above the site elevation within 5 miles of the site. A large portion

of the topographic relief in the immediate site area is filled by Clinton Lake, which is

approximately 45 feet below plant grade. Because of the lake's complex configuration, overwater trajectories would generally be less than 1.1 miles. The applicant expects that the low hills

2-36
and shallow river valleys that exist in the site region could exert a small effect upon nocturnal

wind drainage patterns and fog frequency under certain atmospheric conditions.

2.3.2.2 Regulatory Evaluation

In response to RAI 1.5-1, the applicant stated that RS-002, Attachment 2, identifies the

regulations applicable to the ESP SSAR. RS-002, Attachment 2, identifies the following

applicable NRC regulations regarding local meteorology:

* Appendix A to 10 CFR Part 50, GDC 2, with respect to information on severe regional

weather phenomena that has historically been reported for the region and that is

reflected in the design bases for SSCs important to safety

* 10 CFR 100.20(c) and 10 CFR 100.21 (d), with respect to the consideration that has been

given to the regional meteorological characteristics of the site

In SSAR Sections 1.1.1 and 1.5, and in response to RAI 2.3.3-2, the applicant identified the

following applicable NRC guidance regarding local meteorology:

* RG 1.23, second proposed Revision 1, "Meteorological Measurement Programs for

Nuclear Power Plants," issued April 1986, with respect to the criteria for an acceptable

onsite meteorological measurements program

* Section 2.3.2 of RG 1.70, with respect to the type of local meteorological information that

should be presented, including the potential impact of the plant on local meteorology and

the local meteorological and air quality conditions used for design- and operating-basis

considerations

The staff reviewed this portion of the application for conformance with the applicable regulations,

and considered the corresponding regulatory guidance, with the exception that an ESP appl cant

need not demonstrate compliance with the GDC.

Section 2.3.2 of RS-002, Attachment 2, and RG 1.70 provide the following guidance on

information appropriate for a presentation on local meteorology:

* Local meteorological data based on onsite measurements and data from nearby NWS

stations or other standard installations should be presented in the format specified in

Section 2.3.2 of RG 1.70. Guidance related to onsite meteorological measurements is in

RG 1.23.

* A topographical description of the site and environs should be provided. Section 2.3.2.2

of RG 1.70 provides guidance on the topographical description.

* A discussion and evaluation of the influence of a nuclear power plant(s) and its facilities

Of specified type (or falling within a PPE) that might be constructed on the proposed site

cn local meteorological and air quality conditions should be provided. Potential changes

in the normal and extreme values resulting from plant construction and operation should

te discussed.

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2.3.2.3 Technical Evaluation

The staff evaluated local meteorological conditions using data from the CPS onsite

meteorological monitoring system, as well as climatic data that NCDC and ISCO reported.

Section 2.3.3 of this SER provides a discussion of the representativeness of the CPS onsite

data.

The staff's review of the applicant's wind data from April 1972 through April 1977 and January

2000 through August 2002 shows that the data from these two periods compare well, with a

general shift toward lower wind speeds in the more recent data. A comparison of the

atmospheric stability distributions for these two measurement periods indicates that there may

have been a shift in the distribution toward unstable conditions between the earlier period and

the later period. This shift may be because of the heated cooling water in Clinton Lake from

CPS affecting the lower level of the delta-temperature measurements. Clinton Lake was created

and heated for the first time after the applicant completed the first data collection period and

before it began the second data collection period.

The NCDC-reported normal climatic data for the period 1971-2000 for the central climatic

division of Illinois indicate an annual mean temperature in the area of 50.9 0F, ranging from a

low monthly mean value of about 22.9 OF in January to a high monthly mean value of about

74.9 OF in July (NCDC, "Central Illinois Divisional Normals-Temperature, Period 1971-2000").

These climatic division mean temperature values compare well with the mean temperature

values recorded on site during the period of record 1972-1977 (e.g., annual mean temperature

of 10.5 0C (50.9 0F) with a low monthly mean value of -5.1 OC (22.8 OF) in January and a

high monthly mean value of 23.6 OC (74.5 OF) in July): One of the highest temperatures

recorded in the site region was 113 'F at Decatur on July 14, 1954 (ISCO, "Historical Climate

Summary-1 12193 Decatur, IL"), and one of the lowest temperatures recorded in the site region

was -29 'F at Lincoln on December 26, 1914 (ISCO, "Historical Climate Summary-1 15079

Lindoln, IL"). These values bound the highest and lowest temperatures recorded on site,

35.2 OC (95.4 OF) and -28.8 OC (-19.8 IF), respectively, during the relatively short onsite period

of record, 1972-1977.

The annual mean wet-bulb temperature at Peoria is 47.0 OF and ranges from a high monthly

mean value of 69.2 OF in July to a low monthly mean value of 23.5 OF in January. The normal

relative humidity at Peoria (71 percent) is similar to the onsite annual relative humidity

(68.3 percent). Likewise, the mean dewpoint temperature at Peoria (42.2 OF) is compatible with

the onsite annual dewpoint temperature of 4.7 OC (40.5 OF) (NCDC, "Peoria, Illinois, 2003 Local

Climatological Data, Annual Summary with Comparative Data").

Precipitation for the central Illinois climatic division averages 37.39 inches per year, with

monthly climate division normals ranging from a minimum of about 1.70 inches in January and

February to a maximum of about 4.29 inches in May (NCDC, "Central Illinois Divisional

Normals-Precipitation, Period 1971-2000"). Onsite precipitation data recorded during the

period 1972-1977 show slightly lower precipitation totals. Maximum and minimum monthly

amounts of precipitation observed in the area are 16.96 inches in May 1961 at Clinton (ISCO,

"Historical Climate Summary-111743 Clinton, IL") and 0 inches in September 1979 at

Springfield (ISCO, "Historical Climate Summary-1 18179 Springfield WSO AP, IL"). One of the

2-38
highest 1-day precipitation totals recorded for the site region was 14.25 inches at Clinton or,

May 8, 1961 (ISCO, "Historical Climate Summary-i 11743 Clinton, IL").

The staff reviewed the applicant's description of the local meteorology and determined that it

represents the conditions at and near the site. The wind, temperature, precipitation, and

atmospheric stability data are based on onsite data recorded by the CPS meteorological

monitoring system. Section 2.3.3 of this SER provides a discussion of the representativeness of

the CPS onsite data. The other meteorological summaries are based on data from nearby

station; with long periods of record. A review of the recorded extreme values shows that they

are reflected in the site characteristics presented in SSAR Section 2.3.1.

The staff reviewed the topographic maps and topographic cross sections included in the SSAR,

concluding that the information needed is well labeled and can be readily extracted.

Because of the limited and localized nature of the expected terrain modifications associated with

the development of the ESP facility, the staff finds that these terrain modifications, along with the

resulting plant structures and associated improved surfaces, will not have enough of an impact

on local meteorological conditions to affect plant design and operation. However, the use o0

natural draft cooling towers or mechanical draft cooling towers or both would cause visible

moisture plumes and icing on nearby surfaces during the winter months. The applicant noted

that the quantification of these ambient impacts will require a more in-depth assessment once

the facility's cooling system configuration and design parameters are determined. The COL or

CP applicant will then need to describe how these potential increases in atmospheric moisture

and icing would impact plant design and operation. This is COL Action Item 2.3-1.

Since the EGC ESP site is located in an air quality control region that has been designated as

being in attainment of the national ambient air quality standards, the staff finds that it is not likely

that the ESP site air quality conditions would be a significant factor in the design and operating

bases for the ESP facility.

2.3.2.4 Conclusions

As set forth above, the applicant presented and substantiated information on local

meteorological, air quality, and topographic characteristics of importance to the safe design

and operation of a nuclear power plant(s) falling within its PPE that might be constructed on

the proposed site. The staff reviewed the available information provided, and, for the reasons

given, concludes that the applicant's identification and consideration of the meteorological, air

quality, and topographical characteristics of the site and the surrounding area meet the

requirements of 10 CFR 100.20(c) and 10 CFR 100.21 (d) and are sufficient to determine the

acceptability of the site.

The staff also reviewed available information relative to severe local weather phenomena at the

site and in the surrounding area. As set forth above, the staff concludes that the applicant

identified the most severe local weather phenomena at the site and surrounding area.

2-39
2.3.3 Onsite Meteorological Measurements Program

2.3.3.1 Technical Information in the Application

In this section of the SSAR, the applicant presented the following information concerning its

onsite meteorological measurements program, including instrumentation and measured data:

* a description of meteorological instrumentation, including siting of sensors, sensor

performance specifications, methods and equipment for recording sensor output, the

quality assurance program for sensors and recorders, and data acquisition and reduction

procedures

* meteorological data, including consideration of the period of record and amenability of

the data for use in characterizing atmospheric dispersion conditions

The applicant currently uses the existing onsite meteorological measurements program for the

CPS facility to collect data for the EGC ESP site and intends to use it in the future for any

additional reactors that might be constructed on the ESP site.

The existing CPS monitoring program began in April 1972. The applicant referenced and used

two different periods of onsite meteorological data in the SSAR. The first period, April 1972

through April 1977, is representative of the EGC ESP site before construction of CPS (including

the filling of Clinton Lake). The applicant used data from this first period in the original

construction and operating license environmental reports and the updated safety analysis report

for CPS. The applicant used data from the second period, January 2000 through August 2002,

to characterize current site-specific meteorological conditions. The applicant obtained data from

both periods from the same instrumented onsite tower at the same levels above ground. During

the course of operation, the applicant replaced various electronic components and sensors with

equivalent or upgraded components as a matter of routine maintenance and repair.

In RAI 2.3.3-2, the staff asked the applicant to clarify the EGC ESP meteorological monitoring

program commitments to regulatory guidance documents. In response to RAI 2.3.3-2, the

applicant indicated that, since the meteorological monitoring system at CPS began operation,

the system has been in compliance with NRC requirements. The CPS meteorological

monitoring system currently meets the guidance of ANSI/American Nuclear Society

(ANS) 2.5-1984, "Standard for Determining Meteorological Information at Nuclear Power Plants,"

proposed as Revision 1 to RG 1.23 with some exceptions.

The CPS meteorological monitoring program consists of a guyed, triaxial, open lattice 199-foottall tower located approximately 3200 feet south-southeast of the center of the CPS containment

structure and approximately 1800 feet south-southeast of the center of the proposed location for

a future EGC ESP facility. Wind speed and direction are measured at the 10-meter (33-foot)

and 60-meter (198-foot) elevations. Ambient temperature and dewpoint temperature are

measured at the 10-meter elevation and vertical temperature difference (delta-temperature) is

measured between the 60-meter and 10-meter elevations. Precipitation is monitored at the

ground level.

2-40
For the 1972-1977 period of operation, meteorological data were recorded on strip charts. The

hourly database used for the climatic data summaries and atmospheric dispersion analyses was

derived from the strip charts. For the 2000-2002 period of operation, a microprocessor

recorded the meteorological data and generated the hourly database used for the climatic data

summaries and atmospheric dispersion analyses presented in the SSAR.

The wind sensors are mounted on booms approximately twice the tower face width and are

positioned so that the tower does not influence the prevailing south-southwest windflow. The

ambient temperature, dewpoint temperature, and delta-temperature sensors are housed in

motor-aspirated shields to insulate them from the effects of precipitation and thermal radiation.

The meteorological monitoring system is calibrated at least semiannually. Data recovery for the

2000-2002 period of record used to evaluate atmospheric dispersion exceeded 90 percent.

Measurements are also available from a backup system. The backup monitoring system

consists of wind speed and wind direction sensors located at the 1 0-meter level on the CPS

microwave tower. The backup system is intended to function when the primary system is out of

service, providing further assurance that basic meteorological information will be available during

and immediately following an accidental release of airborne radioactivity.

In RAI 2.3.3-1, the staff asked the applicant to provide an hourly listing of the January

2000-August 2002 onsite meteorological database used to generate the SSAR Section 2.3.4

short-term diffusion estimates and the SSAR Section 2.3.5 long-term diffusion estimates. In its

response to RAI 2.3.3-1, Exelon provided a copy of the January 2000-December 2002

database.

2.3.3.2 Regulatory Evaluation

In response to RAI 1.5-1, the applicant stated that RS-002, Attachment 2, identifies regulations

applicable to the ESP SSAR. RS-002, Attachment 2, identifies the following applicable NRC

regulations regarding onsite meteorological measurement programs:

Appendix 1, "Numerical Guides for Design Objectives and Limiting Conditions for

Operation to Meet the Criterion 'As Low as is Reasonably Achievable' for Radioactive

Material in Light-Water-Cooled Nuclear Power Reactor Effluents," to 10 CFR Part 50, as

it relates to meteorological data used to determine compliance with the numerical guides

for doses in meeting the criterion of "as low as is reasonably achievable" (ALARA)

* 10 CFR 100.20(c), 10 CFR 100.21 (c), and 10 CFR 100.21 (d), as they relate to

meteorological data collected for use in characterizing the site's meteorological

conditions

In SSAR Sections 1.1.1, 1.5, and 2.3.3, as well as in its response to RAI 2.3.3-2, the applicant

identified the following applicable NRC guidance regarding onsite meteorological measurements

programs:

* FRG 1.23, with respect to the criteria for an acceptable onsite meteorological

measurements program

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* Section 2.3.3 of RG 1.70, with respect to describing the meteorological measurements at

the site and providing joint frequency distributions of wind speed and direction by

atmospheric stability class

The staff reviewed this portion of the application for conformance with the applicable regulations,

and considered the corresponding regulatory guidance.

Both RG 1.23 and RS-002, Attachment 2, Section 2.3.3, document the criteria for an acceptable

onsite meteorological measurements program. The onsite meteorological measurements

program should produce data that describe the meteorological characteristics of the site and its

vicinity for the purpose of making atmospheric dispersion estimates for both postulated

accidental and expected routine airborne releases of effluents, as well as for comparing with

offsite sources to determine the appropriateness of climatological data used for design

considerations.

Section 2.3.3 of RS-002, Attachment 2, and RG 1.70 provide guidance on information

appropriate for presentation on an onsite meteorological measurements program. As set forth in

this guidance, at least one annual cycle of onsite meteorological data should be provided.

These data should be presented in the form of joint frequency distributions of wind speed and

wind direction by atmospheric stability class in the format described in RG 1.23. If a site has a

high occurrence of low wind speeds, a finer category breakdown should be used for the lower

speeds so that data are not clustered in a few categories. A listing of each hour of the hourly

averaged data should also be provided on electronic media in the format described in

Appendix A to RS-002, Attachment 2, Section 2.3.3. Evidence of how well these data represent

long-term conditions at the site should be discussed.

2.3.3.3 Technical Evaluation

The staff evaluated the onsite meteorological measurements program by reviewing the program

description presented in the SSAR and conducting a site visit. The site visit consisted of

reviewing the meteorological monitoring system location and exposure, sensor type and

performance specifications, data transmission and recording, data acquisition and reduction, and

instrumentation maintenance and calibration procedures. In addition, the staff reviewed an

hourly listing of the January 2000-December 2002 meteorological database that the applicant

provided in its response to RAI 2.3.3-1.

The staff considers the meteorological data collected by the existing CPS monitoring program to

be representative of the dispersion conditions at the EGC ESP site. The EGC ESP site is within

the existing CPS site, and the new nuclear unit(s) are intended to be in close proximity to the

existing facility. The CPS meteorological tower is located far enough away from existing plant

structures to preclude any adverse impact on measurements. The base of the tower is at an

elevation similar to plant grade at both CPS and at the proposed location for a future EGC ESP

facility. The ground cover at the base of the meteorological tower is primarily native grasses.

The staff reviewed the location of the meteorological tower with respect to nearby ground

features and potential obstructions to flow (e.g., trees, buildings), including existing and

proposed plant structure layouts, and concluded that there are minimal adverse effects on

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the measurements taken at the towers. The staff also evaluated the types and heights of

the meteorological variables being measured and found them compatible with the criteria

of RG 1.23. During the site visit, the staff reviewed the sensor types and performance

specifications, data transmission, and recording methods, as well as the inspection,

maintenance, and calibration procedures and frequencies, and found them to be consistent:

with the guidance in RG 1.23.

The staff performed a quality review of the post-CPS construction (January 2000-December

2002) hourly meteorological database that the applicant provided in response to RAI 2.3.3-1

using the methodology described in NUREG-0917, 'Nuclear Regulatory Commission Staff

Computer Programs for Use with Meteorological Data." The staff performed further review using

computer spreadsheets. Its examination of the data revealed generally stable and neutral

atmospheric conditions at night and unstable and neutral conditions during the day, which was

expected. Wind speed, wind direction, and stability class frequency distributions for each

measurement channel were reasonably similar from year to year. The post-CPS construction

2000-'002 wind speed, wind direction, and stability class frequency distributions were also

reasonably consistent with the pre-CPS construction 1972-1977 data, with a general shift

toward lower wind speeds and more unstable conditions in the more recent data. The shift

toward unstable conditions may have resulted from the effect of the heated cooling water in

Clinton Lake from CPS on the lower level of the delta-temperature measurements or from the

more frequent use of the variation of horizontal wind direction to determine atmospheric stability.

The staff compared the January 2000-December 2002 joint frequency distribution used by ihe

applicant as input to the NRC-sponsored PAVAN atmospheric dispersion model

(NUREG/CR-2858, "PAVAN: An Atmospheric Dispersion Program for Evaluating Design Basis

Accidental Releases of Radioactive Materials from Nuclear Power Stations") and a staffgeneralted January 2000-December 2002 joint frequency distribution from the hourly database

and found them to be consistent.

2.3.3.4 Conclusions

As set forth above, the applicant provided and substantiated information on the onsite

meteorological measurements program. The staff reviewed the available information relative to

the meteorological measurements program and the data collected by the program. On the basis

of this review and as set forth above, the staff concludes that the system provides data adequate

to represent onsite meteorological conditions, as required by 10 CFR 100.20. The onsite data

also provide an acceptable basis for (1) making estimates of atmospheric dispersion for designbasis accident and routine releases from a nuclear power plant(s) falling within the applicant's

PPE that might be constructed on the proposed site, and (2) meeting the requirements of

10 CFR Part 100 and Appendix I to 10 CFR Part 50.

2.3.4 Short-Term Diffusion Estimates

2.3.4.1 Technical Information in the Application

In this section of the SSAR, the applicant presented the following information on atmospheric:

dispersion estimates for postulated accidental airborne releases of radioactive effluents to the

EAB and LPZ:

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* atmospheric transport and diffusion models to calculate relative concentrations for

postulated accidental radioactive releases

* meteorological data summaries used as input to diffusion models

* specification of diffusion parameters

* probability distributions of relative concentrations

* determination of relative concentrations used for assessment of consequences of

postulated radioactive atmospheric releases from design-basis and other accidents

The applicant used PAVAN to estimate relative concentration (X/Q) values at the EAB and LPZ

for potential accidental releases of radioactive material. The PAVAN model implements the

methodology outlined in RG 1.145, "Atmospheric Dispersion Models for Potential Accident

Consequence Assessments at Nuclear Power Plants."

The PAVAN code estimates X/Q values for various time-averaging periods ranging from 2 hours

to 30 days. The meteorological input to PAVAN consists of a joint frequency distribution of wind

speed, wind direction, and atmospheric stability data. The PAVAN code computes X/Q values at

the EAB and LPZ for each combination of wind speed and atmospheric stability for each of the

16 downwind direction sectors. The code then ranks X/Q values for each sector in descending

order, and it derives an associated cumulative frequency distribution based on the frequency

distribution of wind speed and stabilities for that sector. The X/Q value that is equaled or

exceeded 0.5 percent of the total time is determined for each sector, and the highest

0.5 percentile X/Q value among the 16 sectors becomes the maximum sector-dependent

X/Q value. The code also ranks X/Q values independent of wind direction into a cumulative

frequency distribution for the entire site. The PAVAN program then selects the X/Q value that is

equaled or exceeded 5 percent of the total time. The code uses larger of the two values, the

maximum sector-dependent 0.5-percent X/Q value or the overall site 5-percent X/Q value to

represent the X/Q value for a 0-2-hour time period.

To determine X/Q values for longer time periods, PAVAN calculates annual average X/Q values.

Logarithmic interpolation is then used between the 0-2-hour X/Q values and the annual average

X/Q values to calculate the values for intermediate time periods (i.e., 8 hours, 16 hours,

72 hours, and 624 hours).

The applicant used the following input data and assumptions in applying the PAVAN model to

the EGC ESP site:

* The initial meteorological input to PAVAN consisted of a joint frequency distribution of

wind speed, wind direction, and atmospheric stability data based on January 2000

through August 2002 onsite meteorological data. The wind data were from the 10-meter

(33-foot) level of the onsite meteorological tower. The stability data were derived from

* the vertical temperature difference (delta-temperature) measurements taken between the

60-meter (198-foot) and 10-meter (33-foot) levels of the onsite meteorological tower, as

well as horizontal wind variability. In RAI 2.3.3-4, the staff asked the applicant to explain

why it used only 32 months of onsite data (January 2000 through August 2002) to

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generate the x/C values, since potential bias could exist resulting from the

underrepresentation of autumn and the early winter months. The applicant responded

that the data from the period January 2000 through August 2002 represented the most

recent continuous data record available that was obtained and processed using a

consistent methodology. While there is a potential for a seasonal bias in the 32-month

period of record data, the applicant noted that it performed a variety of comparisons with

the original 1972-1977 data analyses and concluded that there were no undue biases in

the results.

The staff made an independent evaluation of the resulting atmospheric diffusion

estimates by rerunning the PAVAN computer model using a joint frequency distribution

derived from the 3-year meteorological database (January 2000-December 2002)

provided in the applicant's response to RAI 2.3.3-1 and concluded that the resulting EAB

X/Q value could increase as much as 10 percent. Consequently, the staff identified in

Open Item 2.3-3 the need to use appropriately conservative meteorological data to

calculate short-term accident atmospheric dispersion estimates.

* The applicant modeled one ground-level release point and took no credit for building

wake effects.

* The proposed EAB is the perimeter of a circle having a radius of 1025-meter centered on

the ESP facility footprint (e.g., the proposed area for locating the ESP site powerblock

structures), and the proposed LPZ is the area encompassed by a 4018-meter radius

circle centered on the same ESP facility footprint. The applicant placed the release point

at the center of the ESP facility footprint for the purposes of determining the downwind

distances to the EAB and LPZ (1025 meters and 401 8 meters, respectively). In

RAI 2.3.4-2, the staff asked the applicant to recalculate the EAB and LPZ X/Q values

-using the shortest distances between the ESP plant envelope boundaries and the EAB

and LPZ radii for each downwind sector. The applicant responded that, although the

major potential release point(s) would be somewhat displaced from the center point, it did

not expect the resultant changes in X/Q values to be significant and did not recalculate

Ihe EAB and LPZ X/Q values. The staff made an independent evaluation of the resulting

atmospheric diffusion estimates by rerunning the PAVAN computer model and concluded

that reducing the downwind distance to the EAB from 1025 meters to 805 meters coUld

result in increasing the EAB X/Q value by as much as 30 percent. Consequently, the

staff identified in Open Item 2.3-3 the need to use appropriately conservative distances

from postulated release points to calculate short-term accident atmospheric dispersion

estimates.

In its submission to the NRC dated April 4, 2005, the applicant responded to Open Item 2.3-3

by recalculating its short-term accident X/Q values using 3 complete years of meteorological

data (January 2000-December 2002) and a distance of 805 meters to the EAB. The applicant

also provided a copy of the input files it used to execute PAVAN. The applicant stated that

805 meters is the minimum distance to the proposed EAB from any point on the envelope of the

ESP facility footprint.

Based on the PAVAN modeling results presented in its submission dated April 4, 2005, the

applicant proposed the short-term (accident release) atmospheric dispersion site characteristics

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presented in Table 2.3.4-1 for inclusion in an ESP, should one be issued for the applicant's

proposed ESP site.

Table 2.3.4-1 Applicant's Proposed Short-Term (Accident Release) Atmospheric

Dispersion Site Characteristics

SITE CHARACTERISTIC VALUE DEFINITION

0-2 hour x/Q Value @ EAB 2.52x1 0-4 s/M3 The atmospheric dispersion coefficients used

(5% value) in the SSAR to estimate dose consequences

of accidental airborne releases 0-8hour x/Q Value @ LPZ 3.O0xl O~ s/rn3

(5% value)

8-24 hour x/Q Value @ LPZ 2.02x1 0-5 s/M3

(5% value)

1-4 day X/Q Value @ LPZ 8.53x10 6 s/rM3

(5% value)

4-30 day X/Q Value @ LPZ 2.48x1 0-6 s/m3

(5% value)

2.3.4.2 Regulatory Evaluation

In response to RAI 1.5-1, the applicant stated that RS-002, Attachment 2, identifies the NRC regulations

applicable to the ESP SSAR regarding short-term (accident release) diffusion estimates. RS-002,

Attachment 2, identifies the applicable regulation as 10 CFR 100.21, with respect to the meteorological

considerations used in the evaluation to determine an acceptable exclusion area and LPZ.

In SSAR Sections 1.5 and 2.3.4, the applicant identified the following applicable NRC guidance regarding

accident release diffusion estimates:

* RG 1.23, with respect to the criteria for an acceptable onsite meteorological measurements

program

* Section 2.3.4 of RG 1.70, with respect to providing conservative and realistic estimates

of atmospheric diffusion at the EAB and LPZ, based on the most representative meteorological

data and impacts caused by local topography

* RG 1.145, with respect to acceptable methods for choosing atmospheric dispersion factors (X/Q

values) for evaluating the consequences of potential accidents

The staff reviewed this portion of the application for confirmation with applicable regulations, and

considered the corresponding regulatory guidance.

Section 2.3.4 of RS-002, Attachment 2, and RG 1.70 provide the following guidance on information

appropriate for a presentation on short-term (accident release) diffusion estimates. The application should

present or describe the following:

* conservative estimates of atmospheric transport and diffusion conditions at appropriate distances

from the source for postulated accidental releases of radioactive materials to the atmosphere

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a description of the atmospheric dispersion models used to calculate relative concentrations (XIQ

values) in air resulting from accidental releases of radioactive material to the atmosphere, with

models documented in detail and substantiated within the limits of the model so that the staff can

evaluate their appropriateness to site characteristics, plant characteristics (to the extent knovn),

and release characteristics

* the meteorological data used for the evaluation (as input to the dispersion models), which

represent annual cycles of hourly values of wind direction, wind speed, and atmospheric stability

for each mode of accidental release

* an explanation of the variation of atmospheric diffusion parameters used to characterize lateral and

vertical plume spread (ay and o,) as a function of distance, topography, and atmospheric

conditions, as related to measured meteorological parameters, and a description of a methodology

for establishing these relationships that is appropriate for estimating the consequences of

accidents within the range of distances that are of interest with respect to site characteristics and

established regulatory criteria

* cumulative probability distributions of relative concentrations (X/Q values) and the probabilities of

these X/Q values being exceeded for appropriate distances (e.g., the EAB and LPZ) and time

periods, as specified in Section 2.3.4.2 of RG 1.70, as well as an adequate description of the

methods used for generating these distributions

* the relative concentrations used for assessing the consequences of atmospheric radioactive

releases from design-basis and other accidents

2.3.4.3 Technical Evaluation

The applicant generated its atmospheric diffusion estimates for postulated accidental airborne releases of

radioact ve effluents to the EAB and LPZ using the staff-endorsed computer code PAVAN. The staff

evaluated the applicability of the PAVAN model and concluded that no unique topographic features

preclude the use of the PAVAN model for the EGC ESP site. The staff also reviewed the applicant's input

to the PMVAN computer code, including the assumptions used concerning plant configuration and release

characteristics and the appropriateness of the meteorological data input. The staff found that the appl cant

made conservative assumptions by ignoring building wake effects and treating all releases as ground-level

releases.

The stafl made an independent evaluation of the resulting atmospheric diffusion estimates by running the

PAVAN computer model using the following input data and assumptions:

* The meteorological input to PAVAN consisted of a joint frequency distribution of wind speed, wind

direction, and atmospheric stability data derived from the complete 3-year meteorological database

(January 2000-December 2002) provided in the applicant's response to RAI 2.3.3-1. Unlike the

Capplicant's joint frequency distribution, the staff used a larger number of wind speed categories at

the lower wind speeds as suggested in Section 4.6 of NUREG/CR-2858. The important aspect of

having a large number of lower wind speed categories is to generate more X/Q values at the lower

end of the cumulative X/Q frequency since the 0.5 percent X/Q value is desired.

* The staff ignored building wake effects and treated all releases as ground-level releases.

* The proposed EAB is the perimeter of a circle having a radius of 1025-meter centered on the ESP

facility footprint, and the proposed LPZ is the area encompassed by a 4018-meter radius circle

centered on the same ESP facility footprint. To calculate the X/Q values for the EAB, the staff used

the shortest distance to the proposed EAB from any point on the envelope of the ESP facility

footprint (805 meters). Similarly, to calculate the X/Q values for the LPZ, the staff used the shortest

2-47
distance to the proposed LPZ from any point on the envelope of the ESP facility footprint (3798

meters).

The staff obtained PAVAN results similar to that of the applicant.

From this review, the staff concludes that the applicant used an adequately conservative atmospheric

dispersion model and appropriate meteorological data to calculate relative concentrations for appropriate

offsite (EAB and LPZ) distances and directions from postulated release points for accidental airborne

releases of radioactive materials.

To evaluate atmospheric dispersion characteristics with respect to radiological releases to the control

room, detailed design information (e.g., vent heights, intake heights, distance and direction from release

vents to the room) is necessary. Because little detailed design information is available for the nuclear

power plant(s) that might be constructed on the proposed site, the COL or CP applicant will need to

evaluate the dispersion of airborne radioactive materials to the control room at the COL or CP stage. This

is COL Action Item 2.3-2.

The staff intends to include the short-term (accident release) atmospheric dispersion factors listed in

Table 2.3.4-2 as site characteristics in any ESP that might be issued for the EGC ESP site. Based on the

discussion above, the staff considers open Item 2.3-3 resolved.

Table 2.3.4-2 Staff's Proposed Short-Term (Accident Release) Atmospheric Dispersion

Site Characteristics

SITE CHARACTERISTIC VALUE DEFINITION

0-2hour X/Q Value @ EAB 2.52x1 0-4 s/M3 The 0-2 hour atmospheric dispersion factor to be used

(5% value) to estimate dose consequences of design-basis

accidents at the EAB

0-8 hour X/Q Value @ LPZ 3.00xl 0` s/M3 The 0-8 hour atmospheric dispersion factor to be used

(5% value) to estimate dose consequences of design-basis

accidents at the LPZ

8-24 hour X/Q Value @ 2.02x10-5 s/M3 The 8-24 hour atmospheric dispersion factor to be

LPZ used to estimate dose consequences of design-basis

(5% value) accidents at the LPZ

1-4 day X/Q Value @ LPZ 8.53x10-6 s/M3 The 1-4 day atmospheric dispersion factor to be used

(5% value) to estimate dose consequences of design-basis

accidents at the LPZ

4-30 day X/Q Value @ LPZ 2.48x10-6 s/r 3 The 4-30 day atmospheric dispersion factor to be used

(5% value) to estimate dose consequences of design-basis

accidents at the LPZ

2.3.4.4 Conclusions

As set forth above, the applicant made conservative assessments of postaccident atmospheric

dispersion conditions using its meteorological data and appropriate diffusion models. The

applicant calculated representative atmospheric transport and diffusion conditions for the EAB

and the LPZ. The staff has reviewed the applicant's proposed short-term atmospheric

dispersion site characteristics for inclusion in an ESP for the applicant's site, should one be

2-48
issued, and, as discussed above, finds these characteristics to be acceptable. Therefore, the

staff concludes that the applicant's atmospheric dispersion estimates are appropriate for the

assessment of consequences from radioactive releases for postulated (i.e., design-basis)

accidents, in accordance with 10 CFR 100.21.

Based on these considerations, the staff concludes that the applicant's short-term atmospheric

dispersion estimates are acceptable and meet the relevant requirements of 10 CFR Part 1 C0.

The staff will address atmospheric dispersion estimates used to evaluate radiological doses for

the control room in its review of the COL or CP application that references this information.

2.3.5 LIong-Term Diffusion Estimates

2.3.5.1 Technical Information in the Application

In this -section of the SSAR, the applicant presented its atmospheric diffusion estimates for

routine releases of effluents to the atmosphere, providing the following information:

* the atmospheric dispersion models used to calculate concentrations in air and the

amount of material deposited as a result of routine releases of radioactive material to the

atmosphere

* the meteorological data used as input to diffusion models

* diffusion parameters

* relative concentration (X/Q) and relative deposition (D/Q) values used to assess the

consequences of routine airborne radioactive releases

* points of routine release of radioactive material to the atmosphere, the characteristics of

each release mode, and the location of potential receptors for dose computations

The applicant used the subprogram XDCALC from the MIDAS suite of software programs to

estimate! the X/Q and D/Q values resulting from routine releases. The applicant indicated that

the XDCALC model is consistent with the guidance in RG 1.1 11, "Methods for Estimating

Atmospheric Transport and Dispersion of Gaseous Effluents in Routine Releases from LightWater-Cooled Reactors." The applicant used the following input data and assumptions in

applying the XDCALC model for the EGC ESP site:

* The meteorological input to XDCALC consisted of hourly CPS onsite wind speed, wini

direction, and atmospheric stability data from January 2000 through August 2002. The

wind data were from the 10-meter level of the onsite meteorological tower. The stability

data were derived from the vertical temperature difference (delta-temperature)

measurements taken between the 60-meter and 1 0-meter levels of the onsite

meteorological tower, as well as horizontal wind variability.

* The applicant modeled one ground-level release point, assuming a minimum building

cross-sectional area of 2069 square meters and a containment building height of

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76.1 meters. The applicant placed the release point at the center of the ESP facility

footprint for the purposes of determining the downwind distances to the EAB and LPZ.

The applicant calculated annual average undepleted/no decay, undepleted/2.26-day decay, and

depleted/8.00-day decay X/Q values and D/Q values for the site boundary, EAB, LPZ, and

special receptors of interest (nearest milk cow, milk goat, garden, meat animal, and residence

within 5 miles in each downwind sector), as well as for various radial sectors out to a distance of

50 miles.

Table 2.3.5-1 lists the long-term atmospheric dispersion estimates that the applicant derived

based on the XDCALC modeling results.

Table 2.3.5-1 Applicant's Long-Term (Routine Release) Diffusion Estimates

x/Q VALUE (s/m3 )

TYPE OF UNDEPLETED UNDEPLETED DEPLETED

LOCATION NO DECAY 2.26-DAY DECAY 8.00-DAY DECAY D/Q VALUE (1/M2)

EAB 2.04x10-6 2.04x10-6 1.84x10-6 1.46x10-8

(1025 meters NNE) (1025 meters NNE) (1025 meters NNE) (1025 meters NNE)

Nearest 1.1 Ox1 0-6 1.10x10-6 9.63x10-7 6.76x10-9

Milk Cow (1500 meters N) (1500 meters N) (1500 meters N) (1500 meters N)

Nearest 9.90x1 Q-8 9.72x1 0-8 7.28x1 0-8 4.21 x10-10

Goat Milk (8000 meters NNE) (8000 meters NNE) (8000 meters NNE) (8000 meters NNE)

Nearest 1.10x1 0-6 1.1Ox1- 6 9.63x10-7 6.76x10-9

Garden (1500 meters N) (1500 meters N) (1500 meters N) (1500 meters N)

Nearest 1.10x10-6 1.10x10-6 9.63x10-7 6.76x10-9

Meat Animal (1500 meters N) (1500 meters N) (1500 meters N) (1500 meters N)

Nearest 1.50x1 0-6 1.49x1 0-6 1.34X1 0-6 6.76x10 9

Resident (1170 meters SW) (1170 meters SW) (1170 meters SW) (1500 meters N)

2.3.5.2 Regulatory Evaluation

In response to RAI 1.5-1, the applicant stated that RS-002, Attachment 2, identifies the NRC

regulations applicable to the ESP SSAR regarding long-term (routine release) diffusion

estimates. RS-002, Attachment 2, identifies the applicable regulation as 1 0 CFR 100.21 (c)(1),

with respect to evaluating site atmospheric dispersion characteristics and establishing dispersion

parameters such that radiological effluent release limits associated with normal operation from

the type of facility proposed to be located at the site can be met for any individual located off

site.

The staff finds that the applicant should have also identified Appendix I to 10 CFR Part 50, which

requires demonstrating compliance with the numerical guides for doses contained in this

appendix by characterizing atmospheric transport and diffusion conditions to estimate the

2-50
radiological consequences of routine releases of materials to the atmosphere. Nonetheless, the

staff finds that the applicant meets these regulatory requirements.

In SSAR Sections 1.5 and 2.3.5, the applicant identified the following applicable NRC guidance

regarding routine release diffusion estimates:

* Section 2.3.5 of RG 1.70, with respect to providing realistic estimates of annual aver age

atmospheric transport and diffusion characteristics to a distance of 50 miles from the

plant, including a detailed description of the model used and a calculation of the

maximum annual average atmospheric dispersion factor (X/Q value) at or beyond the site

boundary for each venting location

* RG 1.109, "Calculation of Annual Doses to Man from Routine Releases of Reactor

Effluents for the Purpose of Evaluating Compliance with 10 CFR Part 50, Appendix I,"

with respect to the criteria for identifying specific receptors of interest (applicable at the

ESP stage to the extent the applicant provides receptors of interest)

* RG 1.111 with respect to the criteria for characterizing atmospheric transport and

diffusion conditions for evaluating the consequences of routine releases

The staff finds that the applicant should 'have also identified RG 1.112, "Calculation of Releases

of Radioactive Materials in Gaseous and Liquid Effluents from Light-Water-Cooled Power

Reactors," issued May 1977, with respect to the criteria to be used to identify release points and

release characteristics (applicable to the extent the applicant provides release points and

release characteristics at the ESP stage). Nonetheless, the staff finds that the applicant meets

the criteria in all applicable RGs for performing routine release diffusion estimates.

Section 2.3.5 of RS-002, Attachment 2, and RG 1.70 provide the following guidance on

information appropriate for a presentation on long-term (routine release) diffusion estimates:

* nThe applicant should provide a description of the atmospheric dispersion models used to

calculate concentrations in air and the amount of material deposited as a result of routine

releases of radioactive material to the atmosphere. The models should be sufficiently

documented and substantiated to allow a review of their appropriateness for site

characteristics, plant characteristics (to the extent known), and release characteristics.

* lThe applicant should discuss the relationship between atmospheric diffusion parameters,

such as vertical plume spread (or), and measured meteorological parameters. The

applicant should substantiate the appropriateness of the use of these parameters in

estimating the consequences of routine releases from the site boundary to a radius of

50 miles from the plant site.

* The applicant should provide the meteorological data used as input to the dispersion

models. Data used for this evaluation should represent hourly average values of winc'

speed, wind direction, and atmospheric stability, which are appropriate for each mode of

release. The data should reflect atmospheric transport and diffusion conditions in the

vicinity of the site throughout the course of a year.

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* The applicant should provide the X/Q and D/Q values used for assessing the

consequences of routine radioactive gas releases, as described in Section 2.3.5.2 of

RG 1.70.

* The applicant should identify points of routine release of radioactive material to the

atmosphere, the characteristics of each release mode, and the location of potential

receptors for dose computations (if available at the ESP stage). Bounding values for

these parameters may be provided at the ESP stage. In such a case, the applicant will

need to confirm, at the COL or CP stage, that the parameters submitted at the ESP

stage bound the actual values provided at the COL or CP stage, and that the

calculational methodology used for the confirmation is consistent with that employed at

the ESP stage.

2.3.5.3 Technical Evaluation

The applicant generated its atmospheric diffusion estimates for routine airborne releases of

radioactive effluents to the site boundary, EAB, LPZ, and special receptors of interest using the

MIDAS software subprogram XDCALC. The applicant stated that the XDCALC code is

consistent with the guidance in RG 1.111. The staff reviewed the applicant's input assumptions

to the XDCALC computer code concerning plant configuration and release characteristics and

found these assumptions to be appropriate. The staff found that the applicant made

conservative assumptions by treating all releases as ground-level releases.

The staff made an independent evaluation of the applicant's resulting atmospheric diffusion

estimates by executing the staff computer code XOQDOQ (NUREG/CR-2919, "XOQDOQ:

Computer Program for the Meteorological Evaluation of Routine Effluent Releases at Nuclear

Power Stations") using the onsite January 2000-December 2002 meteorological data provided

as part of the applicant's response to RAI 2.3.3-1. The XOQDOQ model implements the

methodology outlined in RG 1.111. The staff obtained results similar to those obtained by the

applicant.

From this review, the staff concluded that the applicant used an appropriate atmospheric

dispersion model and adequate meteorological data to calculate relative concentration and

relative deposition at appropriate distances from postulated release points for evaluation of

routine airborne releases of radioactive material. Any COL or CP application referencing this

information will need to confirm that the specific release point characteristics (e.g., release

height, building height, and cross-sectional area) and the direction and distance to specific

locations of receptors of interest (e.g., EAB and the nearest milk cow, goat milk, garden, meat

animal, and resident) used to generate the ESP long-term (routine release) atmospheric

dispersion site characteristics bound the actual values provided at the COL or CP stage. This is

COL Action Item 2.3-3.

The staff will include the long-term (routine release) atmospheric dispersion factors listed in

Table 2.3.5-2 as site characteristics in any ESP that the NRC might issue for the EGC ESP site.

2-52
Table 2.3.5-2 Staff's Proposed Long-Term (Routine Release) Atmospheric Dispersion

Site Characteristics

SITE CHARACTERISTIC VALUE DEFINITION

Annual Average 2.04x10-6 s/rn3 The maximum annual average EAB undepleted/no decay

Undepleted/No Decay x/Q value for use in determining gaseous pathway doses to

X/Q Value @ EAB the maximally exposed individual

Annual Average 2.04x10-6 s/M3 The maximum annual average EAB undepleted/2.26-da'y

Und epleted/2.26-Day decay X/Q value for use in determining gaseous pathway

Decay X/O Value @ EAB doses to the maximally exposed individual

Annual Average 1.84x10 6 s/r3 The maximum annual average EAB depleted/8.00-day decay

Depleled/8.00-Day Decay X/Q value for use in determining gaseous pathway dose.s to

X/Q Value @ EAB the maximally exposed individual

Annual Average 1.46x10 8 1/m2 The maximum annual average EAB D/Q value for use in

D/Q Value @ EAB determining gaseous pathway doses to the maximally

exposed individual

Ainual Average 1.10x10-6 s/M3 The maximum annual average milk cow undepleted/no decay

Undepleted/No Decay X/Q value for use in determining gaseous pathway doses; to

X/Q Value @ Nearest the maximally exposed individual

Milk Cow

Annual Average 1.10x10-6 s/M3 The maximum annual average milk cow undepletedl2.26-day

Undopleted/2.26-Day decay X/Q value for use in determining gaseous pathway

Decay X/Q Value @ doses to the maximally exposed individual

Nearest Milk Cow

Annual Average 9.63x1 0- s/rM3 The maximum annual average milk cow depleted/8.00-day

Depleted/8.00-Day Decay decay X/Q value for use in determining gaseous pathway

X/O Vtalue @ Nearest doses to the maximally exposed individual

Milk Cow

Annual Average 6.76x10-9 1/m2 The maximum annual average milk cow D/0 value for use in

D/Q Value @ Nearest determining gaseous pathway doses to the maximally

Milk Cow exposed individual

Annual Average 9.90x1 0- s/rM3 The maximum annual average goat milk undepleted/no

Undepleted/No Decay decay X/Q value for use in determining gaseous pathway

X/Q Value @ Nearest doses to the maximally exposed individual

Goat Milk

Anlual Average 9.72x1 O- s/m3 The maximum annual average goat milk undepleted/2.26-day

Undepleted/2.26-Day decay X/Q value for use in determining gaseous pathway

Decay X/Q Value @ doses to the maximally exposed individual

Nearest Goat Milk

Annual Average 7.28x10-8 s/m3 The maximum annual average goat milk depleted/8.00-day

DepletedV8.00-Day Decay decay X/Q value for use in determining gaseous pathway

X/Q Value @ Nearest doses to the maximally exposed individual

Goat Milk

2-53
SITE CHARACTERISTIC VALUE DEFINITION

Annual Average 4.21 x C10 ' 1/r 2 The maximum annual average meat animal D/Q value for

D/Q Value @ Nearest use in determining gaseous pathway doses to the maximally

Goat Milk exposed individual

Annual Average 1.1Ox10-6 s/m3 The maximum annual average garden undepleted/no decay

Undepleted/No Decay X/Q value for use in determining gaseous pathway doses to

X/Q Value @ Nearest the maximally exposed individual

Garden

Annual Average 1 .10x10-6 s/M3 The maximum annual average garden undepleted/2.26-day

Undepleted/2.26-Day decay X/Q value for use in determining gaseous pathway

Decay X/Q Value @ doses to the maximally exposed individual

Nearest Garden

Annual Average 9.63x10 ' s/m3 The maximum annual average garden depleted/8.00-day

Depleted/8.00-Day Decay decay X/Q value for use in determining gaseous pathway

X/Q Value @ Nearest doses to the maximally exposed individual

Garden

Annual Average 6.76x10 91/rn2 The maximum annual average garden D/Q value for use in

DIQ Value @ Nearest determining gaseous pathway doses to the maximally

Garden exposed individual

Annual Average 1.1 Ox1 o-6 s/M3 The maximum annual average meat animal undepleted/no

Undepleted/No Decay decay X/Q value for use in determining gaseous pathway

X/Q Value @ Nearest doses to the maximally exposed individual

Meat Animal

Annual Average 1.10x10-6 s/m3 The maximum annual average meat animal

Undepleted/2.26-Day undepleted/2.26-day decay X1Q value for use in determining

Decay X/Q Value @ gaseous pathway doses to the maximally exposed individual

Nearest Meat Animal

Annual Average 9.63x10-7 s/m3 The maximum annual average meat animal

Depleted/8.00-Day Decay depleted/8.00-day decay X/Q value for use in determining

X/Q Value @ Nearest gaseous pathway doses to the maximally exposed individual

Meat Animal

Annual Average 6.76x10-9 1/rn2 The maximum annual average meat animal D/Q value for

D/Q Value @ Nearest use in determining gaseous pathway doses to the maximally

Meat Animal exposed individual

Annual Average 1.50x10-6 s/m3 The maximum annual average resident undepleted/no decay

Undepleted/No Decay X/Q value for use in determining gaseous pathway doses to

X/Q Value @ Nearest the maximally exposed individual

Resident

Annual Average 1.49x10-6 s/m3 The maximum annual average resident undepleted/2.26-day

Undepleted/2.26-Day decay X/Q value for use in determining gaseous pathway

Decay X/Q Value @ doses to the maximally exposed individual

Nearest Resident

Annual Average 1.34x1 0-6 s/mr3 The maximum annual average resident depleted/8.00-day

Depleted/8.00-Day Decay decay X/Q value for use in determining gaseous pathway

X/Q Value @ Nearest doses to the maximally exposed individual

Resident

2-54
SITE CHARACTERISTIC VALUE DEFINITION

Annual Average 6.76x10-9 1/m2 The maximum annual average resident D/Q value for use in

D/Q Value @ Nearest determining gaseous pathway doses to the maximally

Resident I _Iexposed individual

2.3.5.4 Conclusions

As set forth above, the applicant provided meteorological data and an atmospheric dispersion

model appropriate for the characteristics of the site and release points. The applicant calculated

representative atmospheric transport and diffusion conditions for 16 radial sectors from the site

boundary to a distance of 50 miles, as well as for specific receptor locations. The staff reviewed

the long-term atmospheric dispersion estimates that the applicant proposed for inclusion as site

characteristics in an ESP for the site (if one is issued) and, for the reasons set forth above, finds

these estimates to be acceptable. Therefore, the staff concludes that the applicant provided the

information necessary to address the requirements of 10 CFR 100.21 (c)(1).

Based on these considerations, the staff concludes that the applicant's characterization of Iingterm atmospheric transport and diffusion conditions is appropriate for use in demonstrating

compliance with the numerical guides for doses contained in Appendix I to 10 CFR Part 50.

The applicant provided bounding values for points of routine release of radioactive material to

the atmosphere, the characteristics of each release mode, and the location of potential receptors

for dose computations. Any COL or CP applicant will need to confirm that the parameters

submitted at the ESP stage bound the actual values provided at the COL or CP stage and that

the calculational methodology used for the confirmation is consistent with that employed at the

ESP stage.

2-55
2.4 Hydrologic Engineering

The Exelon Generation Company (EGC or the-applicant) early site permit (ESP) site is located

6 miles (mi) east of Clinton, which is in DeWitt County in central Illinois, and is adjacent to the

currently operating Clinton Power Station (CPS) Unit 1. Clinton Lake, an impoundment on Salt

Creek, currently serves as the principal water source for the existing unit, which uses a oncethrough cooling system to dissipate heat from the turbine condenser. Water held behind a.

submerged dam constructed within the North Fork of Salt Creek in Clinton Lake provides the

30-day shutdown cooling water supply for the CPS Unit 1 ultimate heat sink (UHS). The

applicant refers to this water source as the submerged UHS pond.

The ESP facility would also use Clinton Lake as the source of cooling water. The applicant

proposed that the ESP facility use closed-cycle cooling with wet, dry, or wet/dry hybrid cooling

towers as the plant's normal heat sink (NHS). Clinton Lake would supply makeup water for the

ESP facility's NHS. The UHS for the ESP facility would consist of mechanical draft cooling

tower(s) with no water storage, if the selected reactor design for the ESP facility requires a

UHS. The UHS, if required, would be a safety-related structure and, thus, must be designed,

constructed, operated, and maintained as such. The submerged UHS pond would use new

intake structures to supply the makeup water required for the UHS for a period of 30 days. The

new ESP facility's UHS intake would be an integral part of the UHS and is, therefore, a safetyrelated structure.

2.4.1 Hydrologic Description

2.4.1.1 Technical Information in the Application

The construction of an earthen dam, 1200 feet (ft) downstream from the confluence of the North

Fork of Salt Creek with Salt Creek, formed Clinton Lake (see Figure 2.4-1 of this safety

evaluation report (SER)). Clinton Lake has two arms, one on Salt Creek and the other on the

North Fork of Salt Creek. These arms extend 14 miles and 8 miles, respectively, upstream from

the dam. The top elevation of the dam is 711.8 ft mean sea level (MSL), with a crest width of

22.8 ft. The surface area of the lake is 4895 acres (ac) at the normal level of 690 ft MSL. The

ESP site is located about 3.5 miles northeast of the dam between the two arms of Clinton Lake,

at a grade elevation of 735 ft MSL.

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2.5 5 10 15 20

- '~ km -.

iu 2.4-1 Clinton L I1AVI; - 4N 

i4:

The wae itkfo PUnt1iloaeonteNrhFrofSlCek.OtfofrmC' Figre .41 Cinon ak

Unit I is. discharged into the Salt Creek arm through a 3.4-mile-longi di'scharge flume. The hot

discharge then travels through Clinton Lake to the North Fork of the Salt Creek arm (see

Figure 2.4-2 of this SER). Excess heat, which causes the water temperature to rise above the

ambient equilibrium temperature, is primarily transferred from the lake's surface to the

atmosphere through sensible, long-wave radiation and latent heat flux of evaporation.

2-57
i.*'.

I- -j

. .. I

1 4

I.

I f

r*

- *tA

4 AJ X..,.i 

I j.J'j?'i4j'Il .. ;<

A .*t

*1

1

$Y1. '4. ,

.4)

,r..Z I r

Figure 2.4-2 CPS once-through discharge and subsequent mixing and cooling path

The submerged dam is located approximately 1 mile west of the CPS intake structure. The top

of the submerged dam is at elevation 675 ft MSL. A baffle dike divides the submerged UHS

pond in approximately equal halves (see Figure 2.4-3 of this SER). The top of the baffle dike is

at an elevation of 676 ft MSL. The UHS surface area at the design water surface elevation of

675 ft MSL is 158 ac with a total volume of 1067 acre-feet (ac-ft) or 46.62 million cubic feet (ft3).

The intake for CPS Unit 1 is located on the submerged UHS pond (see Figure 2.4-3 of this

SER). During emergency operation, CPS Unit 1 UHS discharges into the submerged UHS

pond downstream (i.e., south) of the baffle, allowing mixing and heat exchange to the

atmosphere to occur before the discharge reaches the intake. The ESP facility would have a

similar UHS intake structure (see Figure 2.4-3 of this SER). The ESP facility UHS blowdown

will be discharged to the discharge flume.

.. ...

. . i . 2.-58 . . . . .
Figure 2.4-3 Proposed locations of ESP facility UHS intake and discharge

In Request for Additional Information (RAI) 2.4.1-1, the staff asked the applicant to provide

survey coordinates (including elevations) for the bounding areas of all ESP facility safety-related

structures, including intake tunnels and piping corridors. The staff also requested that the

applicant provide coordinates of existing aquifers in bounding areas, particularly perched

aquifers;. In response to RAI 2.4.1-1, the applicant provided an updated figure to replace

Figure 1.2-4 in Chapter 1 of the site safety analysis report (SSAR). The applicant stated that

this figure shows the approximate location of safety-related structures, along with a grid system

overlaid on the figure.

The applicant indicated that the safety-related structures for the ESP facility are the intake

structures, the essential service water cooling towers, and some other structures that will be

located within the ESP facility powerblock area. The applicant stated that the final sizes and

locations of the safety-related structures will be determined after the selection of a reactor

during the combined license (COL) application and construction phase and that no survey

coordinates are established at the ESP stage.

The applicant stated that the location of the ESP facility's normal and UHS intake structures is

approximately 65 ft south of the existing CPS intake structures. The applicant selected this

location to route the ESP facility piping without disturbing the CPS shutdown cooling water

piping that runs from the CPS UHS. The CPS piping exits to the east of the intake structures.

The CPR nonsafety service water discharge and fire protection discharge exit near the north

end and then turn northeast. The circulating water discharge piping exits the intake structures

south of the service water pipe as a group of three pipes that combine into a single pipe, which

then turns northeast to the turbine building. The circulating water piping for the abandoned CPS

2-59
Unit 2 is located south of the CPS Unit 1 circulating water piping and follows the latter path.

The shutdown service water piping exits the CPS intake structure near its south end, then turns

southeast and continues for 250 ft before turning east and then north to the CPS diesel

generator and heating, ventilation, and air conditioning building. Two trains of shutdown service

water and a fire protection line follow this path. The shutdown service water return lines are

located above the supply lines, following the same path as the supply lines to about 175 ft,

where the supply lines turn east, then southwest, and finally slope downward to the discharge

location in the CPS submerged UHS pond at an elevation of 675 ft MSL.

The applicant stated that the piping for the ESP facility would be routed in a manner similar to

the existing CPS piping, with an expected horizontal distance of 50 ft maintained between the

two sets of piping. The applicant stated that the ESP facility piping would be located south of

the existing CPS piping and would be routed a sufficient distance south before it turned east in

order to provide adequate clearance and cover where it passed over the sloping CPS discharge

piping to the submerged UHS pond. The applicant stated that the ESP facility piping elevation

would be selected to provide a vertical clearance of 3 ft 9 inches (in.) between itself and the

existing CPS discharge piping. After crossing the existing CPS discharge piping, the ESP

facility piping would continue east to the two cooling towers to provide makeup water. The

applicant stated that the location and elevation of the ESP facility piping would not be

established until after the pipe diameters were determined based on the selection of the

reactor(s) for the ESP facility. The applicant stated that the ESP facility piping would include

pipes for the makeup water supply to the NHS tower, the fire protection supply, and two trains of

makeup water to the UHS cooling towers for the ESP facility.

The applicant stated that SSAR Section 2.4.13 discusses the regional and local ground water

systems. The applicant stated that the ground water beneath the ESP site occurs in upper

glacial deposits (Wisconsinan) and in the underlying Illinoian and Kansan tills. The applicant

stated that, since these deposits are regional and not limited to any specific area within the ESP

site, no specific coordinates delineate the aquifers underlying the ESP site. The applicant

provided measured water levels at the ESP site obtained from borings and piezorneters recently

installed at the ESP site.

In RAI 2.4.1-2, the staff requested that the applicant identify any limits on plant operation

resulting from either water supply or intake water temperature for the ESP facility (e.g., the need

to derate or shut down the reactors if intake temperature were to exceed a certain threshold).

The staff also requested that the applicant estimate the frequency and duration of these

operating limits. In response to RAI 2.4.1-2, the applicant stated that limits on plant operation

resulting from water level and temperature are usually based on the volume and temperature of

water in the UHS. The applicant noted that, since the design of the power station has not yet

been finalized and the related safe-shutdown analysis has not yet been performed, it has not

identified any operating limits resulting from water level and temperature. The applicant stated

that these analyses will be performed as part of the design certification of the power plant or

during COL application.

Section 2.4.11.5 of the SSAR stated that a plant shutdown would be initiated if the water

surface elevation in Clinton Lake were to fall to an elevation of 677 ft MSL. The applicant stated

that this shutdown water surface elevation is not based on any safety analysis or related to the

volume of water required in the submerged UHS pond. This water surface elevation is the

minimum required for continued supply of normal cooling water for power generation. The

2-60
applicant stated that this minimum water surface elevation is based on an as yet unfinished

design of the ESP facility intake structures. The applicant also noted that the intake structures

may be designed to operate with a lower water surface elevation in Clinton Lake. The applicant

carried out simulations of water surface elevations in Clinton Lake using 24 years of

meteorological records since the construction of Clinton Dam. The applicant found that water

surfacE elevations in Clinton Lake did not fall to an elevation of 677 ft MSL, even with both the

CPS LUnit 1 and the ESP facility operating at 1 00-percent power. SSAR Section 2.4.11.3

included the lake drawdown analysis under a 1 00-year drought, which indicates that the

minimum water surface elevation in Clinton Lake would be 681.4 ft MSL, 4.4 ft above the

shutdcwn level of 677 ft MSL.

The applicant stated that thermal modeling for the ESP facility indicates that essentially all

excess heat from the facility is dissipated to the atmosphere while the water is circulating back

to the plant intake. The applicant also noted that ambient weather conditions directly affect

intake temperatures more than plant operations. The water drawn directly from Clinton Lake for

the ESP facility would be a small fraction of the total circulating flow through the cooling tower(s)

and, thus, would have a minor impact on the temperature of water in the cooling tower basin.

The applicant also indicated that the ESP facility would be capable of adding cooling tower

makeup water to the inlet side of the cooling towers, thereby cooling the facility to the design

temperature. The applicant stated that for these reasons no unit derating or shutdown of the

ESP facility would occur because of elevated temperature of the makeup water. The applicant

also stated that, since a safety analysis for the safe shutdown of the ESP facility has not yet

been carried out, it has not made any assumptions regarding maximum water temperatures.

In RAI 2.4.1-3, the staff requested that the applicant provide references confirming that there

are no existing dams, and that none are proposed upstream of Clinton Lake, that might affect

the availability of water to the ESP site. In response to RAI 2.4.1-3, the applicant revised SSAR

Section 2.4.1.2 to add information regarding current dams upstream and downstream of Clinton

Lake to support its statement that these dams could not affect the availability of water at the

ESP site.

The applicant stated that, with respect to future dams, a representative of the Illinois

Department of Natural Resources (IDNR), Office of Water, Division of Water Resources

Management, Dam Safety Section, advised that there are no recent or pending permits for

recreational or water supply dams upstream of Clinton Lake.

The applicant revised SSAR Section 2.4.1.2 to state that no reservoirs or dams upstream or

downstream from Clinton Lake exist that could affect the availability of water to Clinton Lake.

The applicant identified four recreational dams, two on the North Fork of Salt Creek upstream of

Clinton Lake and two downstream of Clinton Lake. The applicant also stated that, because

these dams were constructed for recreational purposes and have only limited storage

capacities, water is not withdrawn from the watershed. The applicant also noted that the portion

of Salt C:reek downstream from Clinton Lake is not a likely candidate for changes that would

result in additional demand, since the flow in the creek is often low for long periods of time.

In RAI 2.4.1-4, the staff requested that the applicant provide information regarding proposed

land use changes that might result in increased bed load in the tributaries upstream of Clinton

Lake or sediment deposition in the submerged UHS pond. In response to RAI 2.4.1-4, the

applicant stated that it had no information regarding proposed land use changes upstream of

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Clinton Lake. The applicant further stated that the land upstream of Clinton Lake and the CPS

submerged UHS pond is currently used primarily for agriculture. The maximum expected

sediment load to the tributaries originates in early spring when soils are exposed and planting

has not yet begun. The applicant explained that future development will tend to increase the

impervious area within the watershed and decrease the amount of soil erosion and subsequent

delivery of sediment to tributaries.

In RAI 2.4.1 -5, the staff asked the applicant to provide copies of references for the estimates of

runoff and mean lake evaporation expressed as percentages of rainfall in SSAR Table 2.4-2. In

response to RAI 2.4.1 -5, the applicant included copies of data files for evaporation (1963 to

2002) and rainfall (1910 to 2002) obtained from the Midwest Regional Climate Center.

2.4.1.2 Regulatory Evaluation

Table 1.5-1 of the SSAR shows the applicant's conformance to U.S. Nuclear Regulatory

Commission (NRC) regulatory guides (RGs). In RAI 1.5-1, the staff asked the applicant to

provide a comprehensive listing of NRC regulations applicable to its ESP SSAR. In its

response to this RAI, the applicant indicated that Review Standard (RS)-002, Attachment 2,

"Processing Applications for Early Site Permits," identifies the NRC regulations applicable to its

ESP SSAR. Section 2.4 of RS-002, Attachment 2, describes the methods of review and the

applicable acceptance criteria that the staff uses to develop its findings and conclusions related

to the hydrologic aspects of site characterization for an ESP. Although the applicant did not

indicate how the individual sections of SSAR Section 2.4 address the hydrology-related site

suitability criteria in RS-002, Attachment 2, the staff reviewed this portion of the application for

conformance with the applicable regulations and considered the corresponding regulatory

guidance, as identified below.

Section 2.4.1 of RS-002, Attachment 2, provides the review guidance used by the staff to

evaluate this SSAR section. The SSAR should address Title 10 of the Code of Federal

Regulations, (10 CFR) Part 52, "Early Site Permits; Standard Design Certification; and

Combined Licenses for Nuclear Power Plants," and 10 CFR Part 100, "Reactor Site Criteria," as

they relate to identifying and evaluating the hydrologic features of the site. The regulations in

10 CFR 52.17(a) and 10 CFR 100.20(c) require the NRC to take into account the physical

characteristics of a site (including seismology, meteorology, geology, and hydrology) to

determine its acceptability for a nuclear power reactor. In addition, 10 CFR 100.20(c)

addresses the hydrologic characteristics of a proposed site that may affect the consequences of

radioactive material escaping from the facility. Factors important to hydrologic radionuclide

transport, described in 10 CFR 100.20(c)(3), should be obtained from onsite measurements.

The staff evaluated SSAR Section 2.4.1 in light of these requirements.

To satisfy the hydrologic requirements of 10 CFR Parts 52 and 100, the applicant's SSAR

should describe the surface and subsurface hydrologic characteristics of the site and region.

The applicant should describe in detail sufficient to assess the acceptability of the site and the

potential for those characteristics to influence the design of the structures, systems, and

components (SSCs) of a nuclear power plant(s) (or a facility falling within a plant parameter

envelope (PPE)) that might be constructed on the proposed site.

Meeting this guidance provides reasonable assurance that the hydrologic characteristics of the

site and potential hydrologic phenomena would pose no undue risk to the type of facility (or

2-62
facility falling within a PPE) proposed for the site. Further, it provides reasonable assurance

that such a facility would not pose an undue risk of radioactive contamination to surface or

subsurface water from either normal operations or as the result of a reactor accident.

To determine whether the applicant met the requirements of the hydrologic aspects of 10 C1-R

Parts !52 and 100, the staff used the following specific criteria.

Section 2.4.1 of the SSAR should form the basis for a hydrologic engineering analysis with

respect to subsequent sections of the ESP application. Therefore, completeness and clarity are

of paramount importance. Maps should be legible and adequate in coverage to substantiate

applicable data. Site topographic maps should be of good quality and of sufficient scale to callow

independent analysis of preconstruction drainage patterns. The SSAR should provide data on

surface water users, their location with respect to the site, type of use, and quantity of surface

water used. Inventories of surface water users should be consistent with regional hydrologic

inventories reported by applicable Federal and State agencies. The description of the

hydrologic characteristics of streams, lakes, and shore regions should correspond to those of

the U.S. Geological Survey (USGS), National Oceanic and Atmospheric Administration (NOAA),

Soil Conservation Service (SCS), U.S. Army Corps of Engineers (USACE), or appropriate Slate

and river basin agencies. The SSAR should describe all existing or proposed reservoirs and

dams (both upstream and downstream) that could influence conditions at the site. Applicants

may ottain such descriptions from reports of the USGS, U.S. Bureau of Reclamation (USBR),

USACE, and others. Generally, reservoir descriptions of a quality similar to those contained in

pertinent data sheets of a standard USACE hydrology design memorandum are adequate. The

SSAR should provide tabulations of drainage areas, types of structures, appurtenances,

ownership, seismic and spillway design criteria, elevation-storage relationships, and short- and

long-teim storage allocations.

2.4.1.3 Technical Evaluation

On May 11, 2004, the staff conducted a site visit in accordance with the guidance provided in

Section 2.4.1 of RS-002, Attachment 2. The staff used information from the site visit, digital

maps, and streamflow data from the USGS and independently verified the hydrologic

description provided in SSAR Section 2.4.1. The applicant provided information, including

maps, charts, and data from Federal, State, and regulatory bodies, describing the hydrologic

characteristics and water use in the vicinity of the ESP site.

The staif verified the surface area of Clinton Lake using the USACE major dams map layer.

This map layer dataset lists the surface area of Clinton Lake as 4895 ac.

In SSAR Section 2.4.1.2, the applicant stated that the catchment area of Salt Creek above

Clinton [)am is about 296 square miles (mi2). The staff manually delineated the watershed

draining into Clinton Lake using USGS topographic maps (Figure 2.4-4 of this SER). The staff

determined the area of the manually delineated watershed as 289.2 mi2. The staff estimated

the catchment area of Salt Creek above Clinton Dam to be approximately 2.4 percent less than

that reported by the applicant.

2-63
tj. . Ilk r- 7 ^'' . /

1 -r 

2-6

-am ^ t * ~ ~ - goLt q ; . , i , d 4rfr- f@-W--

\ f0 2.5 5 10 15 20

vet Bkm

Figure 2.4-4 The watershed draining into Clinton Lake, delineated manually using

topographic contours

2-64
The staff determined that the USGS has two streamflow gauges downstream of Clinton Darn

and that no gauges are located upstream of the dam. The longest streamf low record exists at

Salt Creek near USGS Gauge 05578500 near Rowell, Illinois, approximately 12 miles

downstream from the dam. The streamflow measured at this gauge includes the release from

Clinton Lake, as well as runoff from an additional 46-mi2 watershed downstream of Clinton D)am.

The sl:reamflow record at this gauge extends back to October 1942. Another streamflow gauge,

USGS. gauge 00579000 at Salt Creek near Kenney, Illinois, located approximately 18.6 miles

downstream from the dam, was recorded from April 1908 through September 1912.

The staff determined that the upstream tributary inflow data are too limited to allow estimation of

low-water conditions and historical flood frequency at the ESP site. Consequently, the staff

used an empirical approach to estimate these parameters, as more fully discussed in

Sections 2.4.2 and 2.4.11 of this SER.

In RAI 2.4.1-1, the staff requested that the applicant provide additional information on survey

coordinates (including elevations) for the bounding areas of all ESP facility safety-related

structures, including intake tunnels and piping corridors. The staff requested that the applicant

provide a layout of the intake tunnel and piping corridor from the lake to the ESP facility to

determine the extent to which the COL applicant should address the layout as an interface item.

The staff also asked for the locations of existing aquifers in the bounding areas, particularly

perched aquifers. Although the applicant provided adequate information regarding the areal

coordinates of the ESP site, it provided no information on the elevations required to define the

bounding volume of the disturbed subsurface material. Therefore, the staff determined that the

applicant needed to define the extent of the vertical disturbance and the bounding elevations; of

all SSC:s. Additionally, the staff determined that SSAR Figure 1.2-4 did not identify either the

elevations or the areal locations of the safety-related piping corridors. Since the intake pumps

for the ESP facility UHS makeup water are safety-related structures, the staff determined that

the applicant needed to state whether it covers these through the site grade specified in the

PPE or proposes separate criteria for these structures. This was Open Item 2.4-1 of the draft

safety evaluation report (DSER).

In response to DSER Open Item 2.4-1, dated April 26, 2005, the applicant stated that the

bounding foundation embedment is 140 ft below grade. The applicant also stated that the

specific vertical disturbance and elevations of each SSC depend on the chosen reactor design

and therefore have not yet been determined. The applicant explained that at 140 ft below

grade, the foundation basemat will rest in Illinoian glacial till, which is considered very good

foundation material. The applicant stated that any excavation below 140 ft from site grade will

not be significant and will only be required for purposes such as leveling.

The applicant stated that the bounding elevation for structures within the powerblock is 234 ft

above grade, and the tallest structure for the ESP facility would be a natural draft cooling tower

with a bounding elevation of 550 ft above grade, if such a tower were to be included in the

reactor design selected for the ESP site.

The applicant stated that the UHS piping has also not been designed at the ESP stage because

its need is dependent on whether the reactor design chosen for the facility requires a UHS. The

applicant stated that its response to RAI 2.4.1-1 provides a general description of the location of

UHS piping, which will be installed between the minimum elevation of the CPS shutdown

service piping (635 ft MSL) and the plant grade (735 ft MSL). The applicant explained that the

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separation between the existing CPS piping and the ESP facility piping will be determined by

the COL applicant and CPS management.

The applicant stated that if a UHS were to be required by the selected ESP facility reactor

design, a UHS makeup water structure would also be required and would be built at the edge of

Clinton Lake, approximately 65 ft south of the existing CPS intake facility structure. Therefore,

the site grade of 735 ft MSL is not pertinent for the ESP facility's UHS makeup water intake

structure. The applicant stated that it expects the bottom of the ESP facility UHS makeup water

intake structure to be located at an elevation of 657.5 ft MSL. The final elevation of the

basemat will also depend on the submergence requirement of selected intake pumps and the

elevation of the inlet, which is between 670 ft MSL and 697 ft MSL. The applicant stated that

the ESP facility UHS makeup water intake structure will be subject to probable maximum flood

(PMF) in Clinton Lake's watershed and will be designed to protect safety-related equipment

located within it.

Based on the applicant's response to DSER Open Item 2.4-1, the staff determined that the

applicant provided sufficient details regarding the vertical extent of the disturbance and the

bounding elevations of all SSCs that may be required and constructed for the ESP facility. The

applicant does not have a specific reactor design at the ESP stage. Therefore, further details

regarding safety-related piping for the ESP facility are not available. The staff will evaluate the

safety of the ESP facility piping corridors during the COL stage, in accordance with applicable

NRC regulations and regulatory guidance. The UHS makeup water intake structure, if the

selected ESP facility reactor design were to require one, would be designed to protect it from

PMF in the Clinton Lake watershed. The staff will also evaluate the safety of the ESP facility

UHS makeup water intake structure during the COL stage, in accordance with applicable NRC

regulations and regulatory guidance. Based on this review, the staff has determined that the

COL or construction permit (CP) applicant needs to ensure that the ESP facility intake piping is

installed with adequate clearance from the CPS facility piping. This is COL Action Item 2.4-1.

On the basis of COL Action Item 2.4-1, the staff considers Open Item 2.4-1 to be resolved.

In response to RAI 2.4.1-1, the applicant stated that it expects the horizontal clearance between

the existing CPS piping and the new ESP facility piping to be 50 ft. The staff determined that

this proposed horizontal clearance is acceptable. The staff had planned to include this

proposed horizontal clearance of 50 ft as DSER Permit Condition 2.4-1. The staff had also

planned to include a minimum vertical clearance equal to the larger of 6.6 ft or three times the

diameter of the pipes as DSER Permit Condition 2.4-2. However, based on a review of the

applicant's response to DSER Open Item 2.4-1 above, the staff determined that DSER Permit

Conditions 2.4-1 and 2.4-2 are not necessary because COL Action Item 2.4-1 is sufficient to

ensure that the ESP facility intake piping will be installed with adequate clearance from the CPS

facility piping.

In RAI 2.4.1-2, the staff asked the applicant to identify any limits on plant operation for the ESP

facility resulting from either water supply or intake water temperature. The staff requested that

the applicant indicate the total service flow rate needed for the existing unit with once-through

cooling systems and the integrated cooling flow demand for all units to determine whether

sufficient margin exists in the available water flow from the lake, accounting for any

uncertainties associated with water and land use changes in the vicinity of the plant. It might

become necessary to derate or shut down the reactors if the intake temperature were to exceed

a certain threshold. The staff also requested the applicant to estimate the frequency and

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duration of these operating limits. The staff determined that the applicant's description of the

ESP facility UHS system was insufficient. Therefore, the staff requested that the applicant

provide a schematic representation of the complete ESP facility UHS system, including the

intake, piping, any potential storage basins, the UHS cooling loop, and the cooling tower(s),

clearly showing all components and water flow, including discharges through these

components.

In response to the RAI, the applicant stated that the ESP facility UHS system will have the

capability to add makeup water to the inlet side of the cooling tower(s). It was not clear to the

staff whether the PPE makeup flow rate, an average of 1.24 cubic feet per second (cfs) or

555 gallons per minute (gpm) and a maximum of 3.11 cfs or 1400 gpm, at the maximum inlet

temperature of 95 0F, would be sufficient to remove all waste heat from the UHS cooling

tower(s). Therefore, the staff determined that the applicant needed to provide a schematic

representation of the complete UHS system for any future facility on the ESP site, including the

intake, piping, any potential storage basins, the UHS cooling loop, and the cooling tower(s),

clearly showing all components and water flow, including discharges through these

components. In addition, the staff determined that the applicant needed to demonstrate that the

PPE makeup flow rate, an average of 555 gpm and a maximum of 1400 gpm, at the maximum

inlet temperature of 95 0F, would be sufficient to remove all waste heat from the UHS cooling

tower(sl. In addition, the applicant needed to demonstrate that there would be no limits on plant

operation caused by limited water supply or elevated water temperatures at the UHS intake for

any facility constructed on the ESP site. This was DSER Open Item 2.4-2.

In respcnse to DSER Open Item 2.4-2, in its submission to the NRC dated April 26, 2005, the

applicant stated that SSAR Figure 3.2-1 shows a schematic representation of the complete UHS

system, if one were to be required for the ESP facility, with its major components and the

direction of water flow in the system, with the exception of the blowdown. The applicant stated

that the design of the UHS depends on the reactor design yet to be chosen for the ESP facility,

and the purpose of the conceptual design provided in the SSAR is to provide a bounding value

for possible UHS makeup water needs. The applicant stated that each mechanical draft cooling

tower that is part of a UHS will have a basin to provide makeup water to the emergency service

water (ESW) pumps. The depth of the basin will depend on the requirements of the selected

ESW pumps. The applicant stated that the normal ESW flow is 26,125 gpm, with a maximum of

52,250 gpm. The normal blowdown from the cooling tower will be 144 gpm, with a maximum of

700 gpm. The applicant stated that the total normal makeup flow including the blowdown is

555 gprn, with a maximum of 1400 gpm.

The applicant explained that the reactor suppliers provide makeup flow and evaporation rates

from the cooling tower. The PPE table (SSAR Table 1.4-1) provides the bounding values.

Blowdown is used to correct the concentration of impurities in the water. The applicant stated

that the CPS UHS maximum temperature is 95 OF. Therefore, makeup to the ESP facility UH S

cooling tDwer will not exceed the required UHS cold water temperature. The applicant stated

that the capability of the flow rate to remove all waste heat is a design issue and will be

reviewed at the COL stage. The applicant revised SSAR Sections 2.4.11.5 and 2.4.11.6 to

address issues raised by DSER Open Item 2.4-2.

Based on the applicant's response to DSER Open Item 2.4-2, the staff determined that the

detailed design of the ESP facility's UHS system is not yet completed because it depends on

the type Df reactor selected for the ESP facility. Therefore, issues raised in DSER Open

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Item 2.4-2 cannot be addressed until the COL stage when a detailed design of the UHS system

is performed, if the selected reactor design type requires one. The staff will review the design of'

the ESP facility's UHS, if one were tobe required by the selected reactor type, including its

capacity to remove all waste heat under the most critical scenario in accordance with applicable

NRC regulations and regulatory guidance at the COL stage. The staff determined that PPE

values of makeup flow rate (555 gpm; item 3.3.9 in Table 1.4-1 of the SSAR) and maximum inlet

temperature to the CCW heat exchanger (95 OF; item 3.2.1 in Table 1.4-1 of the SSAR), along

with the site characteristic values provided in Table 2.3.1-6 of this SER, relate to maximum air

temperature and maximum humidity and are important parameters that should be used in the

design of the UHS cooling towers, if the selected reactor type for the ESP facility were to require

a UHS. This is COL Action Item 2.4-2. On the basis of COL Action Item 2.4-2, the staff

considers DSER Open Item 2.4-2 resolved.

In RAI 2.4.1-3, the staff requested that the applicant provide references confirming that no dams

exist and that none are proposed upstream of Clinton Lake that might affect the availability of

water for the ESP site. In response to RAI 2.4.1-3, the applicant stated that it will revise its

application to mention the existence of four recreational dams, two on the North Fork of Salt

Creek upstream of Clinton Lake and two downstream of Clinton Lake. The applicant provided

information related to the construction date, dam height, and reservoir storage capacities of

these dams. The applicant also stated that, because of the limited storage capacities of these

reservoirs, water is not withdrawn from the watershed. The staff disagrees with the applicant

in this assessment. Based on information provided by the applicant, the volumes of

impoundments upstream of the Clinton lake are small enough to be negligible. Runoff from the

Clinton Lake watershed feeds the reservoirs behind these dams and provides the water stored

in these reservoirs.

However, the staff determined that the two reservoirs upstream of Clinton Lake have a

maximum combined storage capacity of 194.1 million ft3 or 4446 ac-ft. This volume is small

compared to the volume of Clinton Lake (at a normal water surface elevation of 690 ft MSL,

Clinton Lake has a volume of 74,200 ac-ft), and the effect of a flood wave resulting from abreach of these two dams coincident with a PMF event in the Clinton Lake watershed is not

significant. Section 2.4.4 of this SER presents an analysis and evaluation of the effects of a

failure of the two upstream dams. Based on this evaluation, the staff determined that the

applicant's response to RAI 2.4.1-3 is satisfactory.

In RAI 2.4.1-4, the staff requested that the applicant provide information regarding proposed

land use changes in the watershed upstream of Clinton Lake. These changes might result in

increased bed load in the tributaries upstream of Clinton Lake and increased sediment

deposition in the submerged UHS pond. In response to RAI 2.4.1-4, the applicant stated that it

did not have any information regarding proposed land use changes upstream of Clinton Lake.

The staff determined that, for a site suitability evaluation, the applicant needed to provide an

authoritative source that could include State or county planning officials who can either provide

details of a development plan in the Clinton Lake watershed or verify the absence of such a

plan. This was DSER Open Item 2.4-3.

In response to DSER Open Item 2.4-3, the applicant stated, in its submission to the NRC dated

April 4, 2005, that it contacted the DeWitt County Planning and Zoning Office to obtain

information regarding development plans in the Clinton Lake watershed. The applicant stated

that the administrator of the DeWitt County Planning and Zoning Office referred to a

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Comprehensive Land Use Plan dated 1992 that is out of date and out of print. The

administrator also indicated that no current plans exist to update this land use plan. According

to the administrator, the county experienced a 7-percent decline in population from 1980 to

2000. Over the latter half of this period, though, there was a 1.2-percent increase in population.

The administrator also provided the applicant with information related to a 40-ac residential

development in Farmer City, with a 20-year plan for additional development of up to 217 ac.

The applicant also contacted the acting administrator of Farmer City and confirmed the

existence of an ongoing 40-ac development and another planning concept for a 200-ac

commercial-industrial development project north of Farmer City.

Based on the applicant's response to DSER Open Item 2.4-3, the staff determined that the

applicant provided sufficient information from authoritative sources to resolve its concerns

expressed in DSER Open Item 2.4-3. Therefore, the staff considers DSER Open Item 2.4-3

resolved.

In response to RAI 2.4.1-4, the applicant also stated that increased impervious area within the

Clinton Lake watershed associated with future development will reduce soil erosion and

sediment discharge to tributaries. The staff disagreed with the applicant in this assessment. An

increase in impervious area is likely to increase the volume of surface runoff, as well as

decrease the time required to reach peak runoff in the watershed. Because of quicker and

greater runoff, it is more likely that soil erosion will increase, not decrease. Should the resulting

increasa in soil erosion decrease the volume of stored water in the submerged UHS pond, th9

staff wculd have to examine the adequacy of the submerged UHS pond capacity. Therefore,

the staff determined that the applicant needed to provide additional justification for its

conclusion that an increase in impervious area will not increase soil erosion. This was

DSER Open Item 2.4-4.

In response to DSER Open Item 2.4-4, the applicant stated, in its submission to the NRC datod

April 4, :2005, that sediment delivery rates from agricultural land are extremely variable and tend

to be high in areas with fine-grained soil on sloping land, which are exposed to the direct impact

of precipitation. The applicant stated that sediment delivery from urban land is also variable.

Sources of sediment in urban lands may be fewer because of land cover, but urban drainage

systems may be more efficient at delivering sediment to natural drainages (streams). The

applicarnt stated that sediment delivery rates from both agricultural, as well as urban lands,

depend on erosion control practices.

The applicant stated that stream bank erosion increases with a rise in peak flow rates and

volumes. Since both agricultural and urbanization changes may increase runoff volume over

native conditions, the applicant concluded that there may be some increase in sediment

production. In its conversation with the applicant, the DeWitt County Administrator for Planning

and Zoning indicated that new urban development incorporates storm water best management

practices, including storm water detention, vegetated buffers, and construction erosion control.

The applicant concluded that it is difficult to definitively establish whether an increase in urban

land use will lead to an increase or decrease in soil erosion. The applicant stated that in either

case, the impact would be small because the long-term potential development in the watershed

amounts to less than 0.5 percent of the watershed area.

The staff reviewed the additional information provided by the applicant in its response to Open

Item 2.4-4 and concluded that, based on the authoritative information included in the applicant's

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response, new development in the watershed for the foreseeable future is approximately

250 ac, or about 0.14 percent of the area of the Clinton Lake watershed (289.2 mi2 or

185,092 ac). In addition, the staff concluded that since new development projects use storm

water best management practices, the likely increase in sediment delivery to natural drainages

in the watershed is small because of the relatively small size of the areas affected by

development as compared to the overall size of the watershed. Therefore, the staff considers

DSER Open Item 2.4-4 resolved.

In RAI 2.4.1-5, the staff requested that the applicant provide copies of references for the

estimates of runoff and mean lake evaporation expressed as percentages of rainfall in SSAR

Table 2.4-2. In response to RAI 2.4.1-5, the applicant provided evaporation and rainfall data

obtained from the Midwest Regional Climate Center. The staff determined that the applicant's

response is satisfactory.

2.4.1.4 Conclusions

As discussed above, the applicant provided sufficient information pertaining to the identification

and evaluation of the general hydrologic characteristics of the site, including descriptions of

rivers, streams, lakes, water-control structures, and users of these waters. SSAR Section 2.4.1

conforms to Section 2.4.1 of RS-002, Attachment 2, with regard to this objective.

The review guidance in Section 2.4.1 of RS-002, Attachment 2, provides that the SSAR should

address the requirements of 10 CFR Part 52 and 10 CFR Part 100 as they relate to identifying

and evaluating the hydrologic features of the site. Although the applicant did not specifically

address the above regulations in SSAR Section 2.4.1, the staff concludes that, by conforming to

Section 2.4.1 of RS-002, Attachment 2, the applicant has met the requirements for general

hydrologic descriptions with respect to 10 CFR 52.17(a) and 10 CFR 100.20(c).

2.4.2 Floods

Clinton Lake was created to provide a reliable supply of cooling water for CPS. The watershed

that drains into Clinton Lake has an area of approximately 289.2 mi2. Clinton Dam is located

about 1200 ft downstream from the confluence of the North Fork of Salt Creek with Salt Creek.

Clinton Lake has two arms. These arms extend approximately 14 miles on the North Fork of

Salt Creek and approximately 8 miles on Salt Creek, respectively.

2.4.2.1 Technical Information in the Application

SSAR Section 2.4.1.1 states that Clinton Lake significantly attenuates floodflow downstream

from the dam and that no flows exceeding 10,000 cfs have been recorded at the Rowell

streamflow gauge since the construction of the dam.

The applicant analyzed 22 years of flood data (January 1978 to September 2000) recorded at

the Rowell gauge. SSAR Figure 2.4-5 shows the applicant-estimated peak flood frequency

curve, and SSAR Table 2.4-4 presents peak flows at the gauge and Clinton Dam for various

recurrence intervals. The applicant estimated peak flows at Clinton Dam by prorating peak

flows at the gauge using the ratio of drainage area at the dam to that at the gauge. In SSAR

Section 2.4.1.2, EGC stated that the catchment area of Salt Creek above Clinton Dam is

296 mi2, and the drainage area at the Rowell gauge is 335 mi2. The applicant estimated a mean

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annua! flood of 3600 cfs at the gauge, corresponding to a recurrence interval of 2.33 years. The

applicant also estimated that the maximum discharge of 7810 cfs recorded on April 13, 1994,

had a recurrence interval of 25 years. The applicant further stated that, because of the

presence of Clinton Dam, the 10-year recurrence interval floodflow at the Rowell gauge is

reduced from 11,400 cfs to 6,200 cfs, and the 100-year recurrence interval floodf low is reduced

from 29,900 cfs to 10,400 cfs.

In SSAR Section 2.4.2.2, the applicant stated that the hydraulic design of the dam and the lake

is based on a PMF with a standard project flood (SPF) as its antecedent condition. The

applicant used an SPF equal to 50 percent of the PMF. The SPF occurred 3 days before the

PMF. This flood sequence was routed through Clinton Lake using the USACE Spillway Rating

and Flood Routing (SPRAT) computer program. The applicant estimated the PMF water

surface elevation in the lake to be 708.8 ft MSL. The applicant provided a freeboard of 3 ft to

determine a top elevation of Clinton Dam of 711.8 ft MSL.

SSAR Section 2.4.2 states that the applicant obtained the probable maximum precipitation

(PMP) using Hydrometeorological Report (HMR) 33, "Seasonal Variation of the Probable

Maximum Precipitation East of the 1 0 5 th Meridian for Areas from 10 to 1,000 Square Miles and

Durations of 6, 12, 24, and 48 Hours," issued 1956. The current standards, however, are

American National Standards Institute (ANSI)/American Nuclear Society (ANS)-2.8-1992,

"American National Standard for Determining Design Basis Flooding at Power Reactor Sites,"

issued July 1992; HMR 51, "Probable Maximum Precipitation Estimates, United States East of

the 105th Meridian," issued June 1978; and HMR 52, "Application of Probable Maximum

Precipitation Estimates, United States East of the 1 05th Meridian," issued August 1982. In

RAI 2.4.2-1, the staff requested that the applicant explain why it did not use the current

standards. The staff also requested that the applicant explain why an estimate based on

HMR 33 is conservative relative to an estimate based on HMRs 51 and 52. In response to

RAI 2.4.2-1, the applicant stated that it took the 48-hour PMP directly from the CPS updated

safety analysis report (USAR). The applicant further stated that it originally obtained or derived

the PMP information in the CPS USAR from HMR 33. The applicant conceded that more recent

procedures than those provided in HMR 33 are available for determining the PMP. The

applicant stated that it updated the PMP information in the SSAR using four reports directly

relating to estimating the PMP at a given location. The applicant provided brief descriptions of

HMRs 33, 51, 52, and 53, "Seasonal Variation of 10-Square-Mile Probable Maximum

Precipitation Estimates," issued April 1980.

The applicant stated that the 48-hour, all-season PMP based on HMR 33, and estimated for the

296 mi2, drainage area is 25.2 in. The corresponding 24-hour, all-season PMP, also obtained

from HMVIR 33, is 22.6 in. The applicant used the procedure outlined in HMR 33 to estimate the

24- and 48-hour all-season PMP for a drainage area of 200 mi2 and then adjusted it by a scal ng

factor of 0.94 for the Clinton Lake drainage area of 296 mi2.

The applicant obtained 24- and 48-hour all-season PMP values for a drainage area of 200 mil

from HMR 51. It reported the all-season PMP values corresponding to these two durations as

25 in. and 28 in., respectively. The applicant then applied the same scaling factor

recommended by HMR 33 to the PMP values derived from HMR 51 and reported these areaadjusted values as 23.5 in. for the 24-hour all-season PMP and 26.3 in. for the 48-hour PMP.

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In RAI 2.4.2-2, the staff requested that the applicant describe likely changes to both upstream

land use and downstream water demand that could alter either the intensity or frequency of

flood and loW-flow conditions. In response to RAI 2.4.2-2, the applicant stated that a shift in

upstream land use to a more impervious watershed would tend to generate more runoff from the

same amount of precipitation and decrease the duration of low flows because more water would

be available to the lake. The applicant stated that no change in the 1 00-year flood level is

expected because of the lake's large flow attenuation capacity. The applicant also stated that

water demand in Salt Creek is not likely to increase since the flow in the creek is low for long

periods of time.

In RAI 2.4.2-3, the staff requested that the applicant document any historical hillslope failures in

the watershed. The staff also requested the applicant analyze the ability of a hypothetical

hillslope failure to impact the ESP facility. Hillslope failure could result in a water wave that

might run up the bank near the ESP site and potentially affect its safety. The staff requested

that the applicant estimate the maximum terminal height of such a hypothetical wave. In

response to RAI 2.4.2-3, the applicant stated that, as discussed in Appendix A to SSAR

Section 5.1.3.5, no landslides are documented for DeWitt County. The applicant also noted

that, according to the Illinois State Geological Survey map of classified known landslides in

Illinois, landslide potential at the ESP site is low and hillslopes near the ESP site on Clinton

Lake have been very stable for the past 30 years. If a landslide were to occur on these slopes,

the applicant estimated that such a hypothetical hillslope failure would generate a maximum

wave height of 0.4 ft.

In RAI 2.4.2-4, the staff requested that the applicant document any seismically induced seiches

in Clinton Lake. In response to RAI 2.4.2-4, the applicant stated that it performed a literature

search to determine whether any seismically induced seiches had occurred in Clinton Lake or

other lakes in the area. The applicant found that the occurrence of seiches and other seismic

activity is extremely rare in the noncoastal Midwest, and it did not identify any seismically

induced seiches in Clinton Lake. The applicant also stated that CPS personnel did not report

any seiches in Clinton Lake during the 4.5-magnitude earthquake in June 2004.

In RAI 2.4.2-5, the staff requested that the applicant demonstrate that drainage capacity at the

existing grade is sufficient to accommodate local intense precipitation. If the capacity is not

sufficient, the staff asked the applicant to describe any active safety-related drainage systems

that it would install for the ESP facility. In response to RAI 2.4.2-5, the applicant stated that the

proposed plant site drains to the southeast, and there are no significant internally drained areas

that might result in accumulation of stormwater during local intense precipitation. The applicant

stated that the proposed ESP buildings and site drainage components would also direct

drainage in the southeast direction. The applicant would design the ESP facility so that local

intense precipitation would not inundate any building or critical plant facility. The applicant

stated that the ESP facility design might incorporate drainage features such as raised building

entrance points, surface drains, subsurface drainage pipes, and surface drainage channels to

Clinton Lake.

The applicant has not designed site drainage at the ESP facility because portions of this system

will depend upon the reactor(s) design selected for the ESP facility. The nominal grade

elevation of 735 ft MSL provides more than 20 ft of elevation difference for drainage between

the site grade and maximum flood water elevation in Clinton Lake. The applicant stated that

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this elevation difference is large enough to allow the design of a drainage system to handle

maximum site precipitation without requiring any active components.

In Revision 4 of the SSAR, the applicant revised the maximum rainfall rate site characteristic to

reflect information contained in HMR 52. The revised maximum rate for the 1-hr PMP is

18.15 in. and for the 5-minute PMP is 6.08 in. The applicant stated that these local PMP values

will be used to mitigate impacts of local site flooding based on grading and drainage design at

the CCL stage.

The applicant stated in Revision 4 of SSAR Section 2.4.2.2 that the maximum water surface

elevation (excluding the effects of coincident wind, storm surge, and seiche activity) that could

be expected for Clinton Lake is 709.8 ft MSL. This elevation is based on flood calculations

using a cumulative PMP depth of 27.8 in. The postulated PMP was preceded by a standard

project storm (SPS) equal to 40 percent of the PMP depth. Methods for computing the

maximLIm water elevation are discussed more fully in Section 2.4.3 of this SER and references

to previDus application of the USACE SPRAT computer program have been removed. The

applicant stated that all safety related structures at the ESP facility will either be above the

maximLm combined effects Clinton Lake water surface elevation (716.5 ft MSL) or be designed

to withstand the effects of inundation.

2.4.2.2 Regulatory Evaluation

SSAR Table 1.5-1 describes the applicant's conformance to the NRC RGs. In RAI 1.5-1, the

staff requested that the applicant provide a comprehensive listing of the NRC regulations

applicable to its ESP SSAR. In its response to this RAI, the applicant indicated that RS-002,

Attachment 2, identifies the applicable NRC regulations. Section 2.4 of RS-002, Attachment 2,

describes the methods of review and the applicable acceptance criteria that the staff uses to

develop its findings and conclusions related to the hydrologic aspects of site characterization -For

an ESP. Although the applicant did not indicate how the individual sections of SSAR

Section :2.4 address the hydrology-related site suitability criteria in RS-002, Attachment 2, the

staff reviewed this portion of the application for conformance with the applicable regulations and

considered the corresponding regulatory guidance, as identified below.

Section' 2.4.2 of RS-002, Attachment 2, provides the review guidance used by the staff in

evaluating this SSAR section. The acceptance criteria address 10 CFR Parts 52 and 100 as

they relate to identifying and evaluating the hydrologic features of the site. The regulations at

10 CFR 52.17(a) and 10 CFR 100.20(c) require the NRC to take into account the site's physical

characteristics (including seismology, meteorology, geology, and hydrology) when determining

its accept:ability to host a nuclear reactor(s).

To satisfy the hydrologic requirements of 10 CFR Parts 52 and 100, the applicant's safety

assessment should describe the surface and subsurface hydrologic characteristics of the site

and region and contain an analysis of the PMF. The applicant should describe in detail

sufficient to assess the acceptability of the site and to assess the potential for those

characteristics to influence the design of plant SSCs important to safety. Meeting this

requirement provides reasonable assurance that the hydrologic characteristics of the site and

potential hydrologic phenomena would pose no undue risk to the type of facility proposed for the

site.

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In those cases for which a reactor design is not specified, the ESP applicant may instead

provide a PPE to characterize a facility(s) for comparison with the hydrologic characteristics of

the site. A PPE can be developed for a single type of facility or a group of candidate facilities by

selecting the limiting parameters from among the group. Important PPE parameters for safety

assessment include, but are not limited to, precipitation (e.g., maximum design rainfall rate and

snow load) and the allowable site water level (e.g., maximum allowable flood or tsunami and

maximum allowable ground water level).

To determine whether the applicant met the requirements related to the hydrologic aspects of

10 CFR Parts 52 and 100, the staff used the following specific criteria in RS-002, Attachment 2:

For SSAR Section 2.4.2.1, the potential flood sources and flood response characteristics

of the region and site identified by the staff's review (described in the review procedures)

are compared to those of the applicant. If similar, the applicant's conclusions are

accepted. If, in the staff's opinion, significant discrepancies exist, the staff will request

that the applicant provide additional data, reestimate the effects on a nuclear power

plant(s) of specified type (or falling within a PPE) that might be constructed on the

proposed site, or revise the applicable flood design bases, as appropriate.

* For SSAR Section 2.4.2.2, the applicant's estimate of controlling flood levels is

acceptable if it is no more than 5 percent less conservative than the staff's

independently determined (or verified) estimate. If the applicant's safety assessment

estimate is more than 5 percent less conservative, the applicant should fully document

and justify its estimate of the controlling level, or the applicant may accept the staff's

estimate.

* For SSAR Section 2.4.2.3, the applicant's estimates of local PMP and the capacity of

site drainage facilities (including drainage from the roofs of buildings and site ponding)

are acceptable if the estimates are no more than 5 percent less conservative than the

corresponding staff's assessment. Similarly, the applicant should base its conclusions

upon conservative assumptions of storm and vegetation conditions likely to exist during

storm periods when relating to the potential for any adverse effects of blockage of site

drainage facilities by debris, ice, or snow. If a potential hazard does exist (e.g., the

elevation of ponding exceeds the elevation of plant access openings), the applicant

should document and justify the local PMP basis.

The staff uses appropriate sections of the following documents to determine the acceptability of

the applicant's data and analyses in meeting the requirements of 10 CFR Parts 52 and 100.

RG 1.59, Revision 2, "Design Basis Floods for Nuclear Power Plants," issued August 1977,

provides guidance for estimating the design-basis flooding considering the worst single

phenomenon and combinations of less severe phenomena. The staff uses publications by

USGS, NOAA, SCS, USACE, applicable State and river basin authorities, and other similar

agencies to verify the applicant's data relating to hydrologic characteristics and extreme events

in the region. Sections 2.4.3 through 2.4.7 of RS-002, Attachment 2, discuss methods of

analysis to determine the individual flood-producing phenomena.

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2.4.2.3 Technical Evaluation

The staff obtained historical flows from USGS streamflow records for the Rowell gauge. The

streamf ow record at this gauge extends back to May 1908. The maximum observed peak

discharne at Rowell before the construction of Clinton Dam was 24,500 cfs, recorded on

May 16, 1968. The maximum observed peak discharge at Rowell after the construction of

Clinton Dam was 7810 cfs, recorded on April 13,1994.

Using historical data, the staff estimated peak annual discharge corresponding to several return

periods at the Rowell gauge. The staff estimated pre-dam floods using peak annual discharge

data from 1943 to 1977 and post-dam floods using data from 1977 to 2000. The staff used the

procedure, "Guidelines for Determining Flood Flow Frequency," issued in 1981, recommended

by the Water Resources Council (WRC), to determine the floods corresponding to recurrence,

intervals of 2.33, 10, 25, 50, and 100 years. The staff estimated the pre-dam and post-dam

floods, which are included in Table 2.4-1 of this SER. The staff obtained information regarding

the floods at the Clinton Dam corresponding to the same recurrence intervals by prorating the

estimated floods at the Rowell gauge by the ratio of drainage area at the dam to that at the

gauge (748.9 square kilometers (km2)/867.6 km2 = 0.8632).

Table 2.4-1 Pre-Dam and Post-Dam Floods Corresponding to Several Return Periods

Estimated According to NRC Guidelines

Pre-Dam Floods Post-Dam Floods

Recurrence

Interval Rowell Gauge Clinton Dam Rowell Gauge Clinton Dam

(year) cfs cfs cfs cfs

2.33 4,250 3,669 3,456 2,983

10 11,016 9,509 6,247 5,392

25 17,447 15,060 7,920 6,836

50 22,503 19,424 8,960 7,734

100 29,151 25,162 10,065 8,688

The staff estimated a post-dam mean annual flood of 2983 cfs and 25-year and 100-year floods

of 6836 cfs and 8688 cfs, respectively. The 10-year and 100-year floods at the dam decreased

from 9,51)9 cfs and 25,151 cfs, respectively, to 5,392 cfs and 8,688 cfs, respectively, after the

construction of Clinton Dam.

According to HMR 52, local intense precipitation at the ESP site is equivalent to short-duration,

1-mi 2 PMIP. The staff used HMR 52 guidelines to estimate 1-hour,1 _mi 2 PMP depth for the ESP

site. Table 2.4-2 of this SER, Column 2, lists the multiplication factors recommended in HMR 52

that are applied to 1-hour, 1-minute2 PMP depth to estimate the PMP depths for other durations.

Column :3 lists the staff's estimated PMP depths corresponding to these durations.

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Table 2.4-2 Local Intense Precipitation (1-mi 2 PMP) at the Early Site Permit Site

Multiplier to 1-hour

Duration PMP depth PMP depth in inches

5 min 0.335 6.08

15 min 0.528 9.58

30 min 0.759 13.78

1 hour 1.000 18.15

6 hours 1.493 27.10

The applicant used HMR 33 to estimate the PMP for watershed drainage into Clinton Lake;

however, the current standards are HMRs 51 and 52. Section 2.4.3 of this SER describes the

staff's independent PMP estimation for the watershed draining into Clinton Lake. In RAI 2.4.2-1,

the staff requested that the applicant explain why it did not use these current standards and why

an estimate based on HMR 33 is conservative relative to an estimate based on HMRs 51

and 52. In its response to RAI 2.4.2-1, the applicant described its method for estimating PMP

values for Clinton Lake's drainage using HMR 51. The staff found that the applicant's

procedure is inconsistent with the recommendations in HMR 51, which outline a detailed

method for estimating PMP values for different durations for a desired drainage area.

The staff's independent estimates of 24-hour and 48-hour PMP values for the Clinton Lake

watershed are 4.9 percent and 6.3 percent higher, respectively, than the applicant's PMP

values derived using HMR 33 for the same durations, as reported in the SSAR. The staff

concluded that the applicant did not show that PMP values estimated using HMR 33 are

conservative when compared to PMP values estimated using HMR 51. Therefore, the applicant

needed to provide a revised PMP estimate using the current criteria of HMR 51. This was

DSER Open Item 2.4-5.

In response to DSER Open Item 2.4-5, the applicant stated, in its submission to the NRC dated

April 4, 2005, that it agreed with the staff's independent estimate of PMP values obtained using

the recommendations of HMR 51. The applicant noted that the PMF water surface elevations

updated for HMR 51 PMP values would not change the ESP site from being considered a 'dry

site." However, the applicant conceded that the updated PMP values may be useful for

assessing the impacts on site drainage during significant storm events. The applicant revised

the SSAR to reflect its acceptance of the staff-estimated PMP values for the ESP site. The

staff, therefore, considers Open Item 2.4-5 resolved.

In RAI 2.4.2-2, the staff requested that the applicant describe likely changes to both upstream

land use and downstream water demand. Upstream land use change may lead to increased

intensity and frequency of flood risk to the ESP site. An increase in downstream water demand

may affect low-flow conditions.

In response to RAI 2.4.2-2, the applicant stated that likely changes in upstream land use will not

appreciably alter the flood risk at the site. Since the antecedent conditions used in PMF

calculations will result in saturated soil conditions, any increases in impervious surface in the

basin will not have a detectable impact on the PMF flood height. However, the staff concludes

that the applicant's assertion that an increase in area with impervious surface will decrease the

duration of low-flow events is not adequate. Increases in impervious surface also result in a

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reduction in recharge and the resulting ground-water-derived baseflow. While the applicant's

assertion of increased flow is correct for the long-term average flow, an increase in impervious

surface area could result in a decrease in baseflow during dry periods. Therefore, the applicant

needed to provide additional justification for why an increase in the area with impervious surface

will decrease the duration of low-flow events. This was DSER Open Item 2.4-6.

In response to DSER Open Item 2.4-6, the applicant stated, in its submission to the NRC dated

April 4, 2005, that the Clinton Lake watershed is not changing significantly. The applicant

stated that the trend in long-term population is decreasing, and the trend in short-term

population is flat. The applicant also stated that there is no information to support significant

future changes in land use or increase in water demand upstream or downstream of the lake.

The applicant stated that the long-term potential of development in land use is less than

0.5 percent of the Clinton Lake watershed.

The applicant stated that, in general, development of land use will reduce the amount of

infiltration, thereby reducing the volume of water in the ground that produces baseflow during

low-flow periods. Therefore, the applicant argued, the rate of flow during low-flow periods, as

well as the duration of low-flow for those streams that will dry up, will be reduced. The applicant

further stated that given the low rate of development in the Clinton Lake watershed and the

required stormwater control practices for new development, it is reasonable to assume that no

significant change in stream low-flows will occur.

The applicant explained that the State requires a minimum discharge of 5 cfs from the dam to

Salt Creek downstream of Clinton Lake. To maintain this minimum discharge during dry

periods, water is drawn from the large storage capacity in Clinton Lake. The applicant stated

that the potential change in infiltration caused by future development is small and is not

expected to significantly change the total volume of inflow to the lake. Therefore, the applicant

reasoned, no significant change will occur in the ability of Clinton Lake to deliver the minimum

required flow to Salt Creek downstream of the lake.

Based on the applicant's response to DSER Open Item 2.4-6, the staff determined that the

change in the Clinton Lake watershed for the foreseeable future is so small (0.14 percent of the

watershed area; see the staff's review of the applicant's response to DSER Open Item 2.4-4 in

Section 2.4.1.3 of this SER) as compared to the overall size of the watershed, it would not result

in significant changes in the duration of low-flows in the watershed. Based on the above review,

the staff considers DSER Open Item 2.4-6 resolved.

In response to RAI 2.4.2-2, the applicant stated that the portion of Salt Creek downstream of

Clinton Lake is not a candidate for an increase in demand. The applicant stated that Salt Creek

is not a likely candidate for any diversion development because it historically has experienced

extended periods of low flow. However, the staff concluded that the applicant did not provide an

adequate basis for this statement. Since an increase in additional storage capacity could

mitigate these low-flow periods, the staff found the applicant's response incomplete. The staff

asked the applicant to provide references for projections from State or local authorities

responsible for development plans in the area of concern to substantiate any prediction of future

development. This was DSER Open Item 2.4-7.

In response to DSER Open Item 2.4-7, the applicant stated, in its submission to the NRC dated

April 4, 2005, that it provided information on planned development for DeWitt County and

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Farmer City in its responses to DSER Open Items 2.4-3 and 2.4-6. The applicant stated that no

significant development is planned within the Clinton Lake watershed. The limited development

currently planned will use a ground water source for its water supply.

The applicant stated that Salt Creek downstream of Clinton Lake is not a good candidate for

water withdrawal since flows released from the lake can be at the minimum required rate of

5 cfs for extended periods of time and would generally not be considered sufficient to support

additional development.

Based on the applicant's responses to DSER Open Items 2.4-3, 2.4-6, and 2.4-7, the staff

determined that the applicant provided sufficient information to conclude that there is only

limited development planned within the Clinton Lake watershed. This limited development is

not likely to increase significantly the water demand on Salt Creek. Based on the above review,

the staff considers DSER Open Item 2.4-7 resolved.

SSAR Section 2.4.2 did not provide sufficient information for the staff to determine the safety of

the ESP site from seismically generated water waves. In RAI 2.4.2-3, the staff requested that

the applicant document any historical hillslope failures in the watershed and analyze the ability

of a hypothetical hillslope failure to impact the ESP facility. A hillslope failure could result in a

water wave that might run up the bank near the ESP site, potentially affecting its safety. The

staff requested an estimate of the maximum height of such a hypothetical wave to address

these safety concerns. In response to RAI 2.4.2-3, the applicant estimated that such a wave

would be less than 1 ft, although it did not explain the basis for this estimated value. The staff

examined the potential for hillslope failure to induce waves in Clinton Lake in Section 2.4.6 of

this SER. Except for the ESP intake structures, the staff concluded that, based on the elevation

of the ESP site relative to the lake and the distance of the ESP safety facilities from the

shoreline (see revised SSAR Figure 1.2-4 in the attachment to RAI 2.4.1-1), water waves

induced by hillslope failure would not pose a risk to the ESP site. The inlet to the CPS

screenhouse is at an elevation of 670 ft MSL, and the new ESP intake would draw water from

the same bottom elevation as that of the CPS intake structures. The staff determined that the

ESP intake structures would be exposed to PMF water surface elevations, although the rest of

the ESP site would be dry. The CP or COL applicant should design the ESP intake structures

to withstand the combined effects of PMF, coincident wind wave activity, and wind setup, as

discussed further in Section 2.4.3 of this SER. This is COL Action Item 2.4-3.

The staff had planned to include the requirement that the COL applicant design the ESP intake

structures to withstand the combined effects of PMF, coincident wind wave activity, and wind

setup in DSER Permit Condition 2.4-3. However, based on the applicant's responses to DSER

Open Items 2.4-1 and 2.4-2, the staff determined that the requirement of a UHS, and

consequently the necessity of protecting its intake structures from flooding, is dependent on

reactor design, which has not been selected at the ESP stage. Therefore, the staff determined

that COL Action Item 2.4-3 is sufficient to ensure flood protection of the ESP facility's UHS

intake structures, if the selected reactor design were to require one. Thus, it is not necessary to

impose DSER Permit Condition 2.4-3.

SSAR Section 2.4.2 did not provide sufficient information on seismically generated seiches. In

RAI 2.4.2-4, the staff requested that the applicant document any seismically induced seiches in

Clinton Lake to determine whether such waves could affect the safety of the ESP site. In

response to RAI 2.4.2-4, the applicant stated that it performed a search of existing literature to

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determine whether any seismically induced seiches had occurred in Clinton Lake or other lakes

in the area. The applicant reported that seismic wave activity is extremely rare, and it did not

identify any seismically induced seiche information. As an anecdotal note, the applicant stated

that CFOS personnel did not report any seiche activity in Clinton Lake during the magnitude

4.5 earthquake of June 2004. The staff examined the potential for seiches in Section 2.4.5 of

this SER. Except for the ESP intake structures, the staff concluded that, based on the elevation

of the EESP site relative to the lake and the distance of the ESP safety facilities from the

shoreline (see revised SSAR Figure 1.2-4 in the attachment to RAI 2.4.1-1), seismically induced

seiches; did not pose a risk to the ESP site.

SSAR Section 2.4.2 did not provide sufficient information for the staff to determine whether

drainage capacity at the existing grade can accommodate local intense precipitation without

affecting any safety-related structures for the ESP facility. In RAI 2.4.2-5, the staff requested

that the applicant demonstrate that drainage capacity at the existing grade is sufficient to

accommodate local intense precipitation, or describe any active safety-related drainage

systems that would be installed for the ESP facility. In response to RAI 2.4.2-5, the applicant

stated that it has not yet designed site drainage at the ESP facility, since portions of this system

will depend upon the reactor design selected for the ESP facility.

The applicant estimated local intense precipitation at the ESP site for a 1-hour duration to be

13.5 in. and for a 5-minute (min) duration to be 4.3 in. Table 2.4-2 of this SER shows the staff's

independent estimation of local intense precipitation, which is 2 percent higher than the

applicant's estimate for a 1-hour duration and 41 percent higher than its estimate for a 5-minute

duration. Because of these differences, the site characteristic of local intense precipitation at

the ESP site remained open. Therefore, the staff asked the applicant to address the differences

between the two estimates of local intense precipitation at the ESP site for a 1-hour duration

and for a 5-minute duration. This was DSER Open Item 2.4-8.

In response to DSER Open Item 2.4-8, the applicant stated, in its submission to the NRC dated

April 4, 2005, that the SSAR characterizes short-term intense precipitation at the site for 1-hour

and 5-minute durations on the basis of information available from the CPS USAR. The

information in the CPS USAR is based on recommended procedures found in the older

HMR 33. The applicant reviewed the staff's estimates of local intense precipitation for 1-hour

and 5-minute durations based on the currently applicable HMR 52 and agreed with them. The

applicant agreed with the staff's estimates and revised the text in SSAR Section 2.4.2.3

accordingly. The staff determined that applicant's response to DSER Open Item 2.4-8 is

satisfactory, and therefore, considers DSER Open Item 2.4-8 to be resolved. The staffestimated local intense precipitation presented in Table 2.4-2 of this SER will be included as El

site characteristic for the ESP site (see Table 2.4.14-1 of this SER).

The applicant stated that a drainage system at the ESP site can be designed to handle

maximum site precipitation without requiring any active components. The CP or COL applicant

should demonstrate that the flooding from local intense precipitation at the ESP site can be

discharged to Clinton Lake without relying on any active drainage systems that may be blocked

during such an event. This is COL Action Item 2.4-4. The staff had planned to include this

requirement as DSER Permit Condition 2.4-4. However, the staff determined that the ESP

facility siue grading will partially depend on the chosen reactor type, which has not been

designed at the ESP stage. The staff concluded that COL Action Item 2.4-4 is sufficient to

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ensure the safety of the ESP facility from flooding generated by local intense precipitation.

Therefore, it is not necessary to impose DSER Permit Condition 2.4-4.

2.4.2.4 Conclusions

As set forth above, the applicant provided sufficient information pertaining to identifying and

evaluating floods at the site. SSAR Section 2.4.2 conforms to Section 2.4.2 of RS-002,

Attachment 2, as it relates to identifying and evaluating floods at the site.

The review guidance in Section 2.4.2 of RS-002, Attachment 2, provides that the SSAR should

address the requirements of 10 CFR Parts 52 and 100. Although the applicant did not

specifically address the above regulations in SSAR Section 2.4.2, the staff concludes that, by

conforming to Section 2.4.2 of RS-002, Attachment 2, the applicant has met the requirements

concerning floods at the site with respect to 10 CFR 52.17(a) and 10 CFR 100.20(c). Further,

the staff finds that the applicant appropriately considered the most severe flooding that has

been historically reported for the site and surrounding area, with sufficient margin for the limited

accuracy, quantity, and period of time in which the historical data have been accumulated.

2.4.3 Probable Maximum Flood on Streams and Rivers

The ESP site is approximately 40.20 N latitude and 88.80 W longitude. The watershed draining

into Clinton Lake is approximately 281.5 mi2 . The area of Clinton Lake is approximately 7.6 mi2 .

Flooding in the watershed will lead to increased water surface elevation in Clinton Lake.

2.4.3.1 Technical Information in the Application

In SSAR Section 2.4.3.1, the applicant stated that the watershed drainage area is 296 mi2. It

developed the PMP according to procedures outlined in HMR 33. The applicant estimated a

total precipitation of 25.2 in. during the 48-hour PMP storm. The 48-hour PMP storm was

temporarily distributed according to guidelines in USACE, EM 1110-2-1411, "Standard Project

Flood Determinations," issued March 1965. For the PMF runoff analysis, the applicant used an

antecedent 48-hour SPS equivalent to 50 percent of the PMP, followed by 3 dry days, followed

by the full 48-hour PMP storm. The applicant considered the precipitation to be uniformly

distributed over the entire area of the watershed.

SSAR Section 2.4.3.2 stated that soils in approximately 90 percent of the drainage area of the

Clinton Lake watershed belong to Flanagan silt loam, Drummer clay loam, and Huntsville loam,

which are classified in SCS soil group B. The rest belong to Sawmill clay loam. The applicant

estimated an initial precipitation loss during the SPS of 1.5 in. and no initial precipitation loss

during the PMP, based on communications with USACE on November 2, 1970. The applicant

estimated an infiltration loss during SPS, as well as during PMP, of 0.1 inches per hour (in.h).

Initial precipitation loss is the part of precipitation that is consumed by soil infiltration before

runoff begins, and infiltration loss is part of the precipitation that is consumed by soil infiltration

during the rest of the storm.

SSAR Section 2.4.3.3 states that the applicant estimated a synthetic unit hydrograph for Salt

Creek at the Rowell gauge, as described by the Illinois Division of Waterways (IDOW) in "Unit

Hydrographs in Illinois," issued in 1948 in conjunction with the USGS. The applicant estimated

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the unit hydrograph at Clinton Dam by prorating the unit hydrograph values at the Rowell gauge

by the ratio of drainage area at the dam to that at the gauge (see SSAR Figure 2.4-10).

The applicant also estimated unit hydrographs for five subareas of the watershed draining into

Clinton Lake (see SSAR Figure 2.4-11) following the same synthetic method. The applicant

computed lag times for each subarea according to the method proposed by IDOW. The

applicant estimated flood hydrographs corresponding to the PMP for each subarea and

combined these individual flood hydrographs, considering their previously estimated lag times

for their corresponding subareas, to obtain the PMF into Clinton Lake.

The applicant routed the PMF through Clinton Lake using the USACE SPRAT computer

program. SSAR Figure 2.4-12 provides the spillway discharge corresponding to water surface

elevatiDn in Clinton Lake. The applicant assumed an initial water surface elevation for Clinton

Lake of 690 ft MSL, which is the normal water surface elevation of the lake before arrival of the

PMF. 'The applicant also estimated the peak PMF discharge of 112,927 cfs under natural flow

conditions in Salt Creek and a peak PMF inflow into the lake of 175,615 cfs.

The applicant estimated a water surface elevation corresponding to the PMF of 708.8 ft MSI.

and an elevation of 711 MSL caused by a 40-mile per hour (mph) wind wave runup. The

applicant used the USACE Water Surface Profiles computer program to determine a water

surface elevation at the ESP site resulting from backwater effects of 708.9 ft MSL.

The applicant estimated wind wave runup at the ESP site caused by significant (33-percent

exceedance) and maximum (1-percent exceedance) winds. The applicant used a fetch of

0.8 mile, a water depth of 40.5 ft, and smooth ground with a slope of 3:1 (horizontal:vertical).

The applicant estimated wind wave runups of 2.95 ft and 4.85 ft for significant and maximum

wind speeds, respectively. The corresponding water surface elevations at the ESP site caused

by wind action coincident with the PMF are 711.95 ft MSL and 713.8 ft MSL, respectively.

The applicant estimated a significant wave height of 2.2 ft at the dam site using a maximum

wind speed of 40 mph, a water depth of 58 ft, and an upstream dam slope of 3:1

(horizorital:vertical). The water surface elevation corresponding to this wind wave runup

coincident with the PMF is 711 ft MSL.

In RAI 2.4.3-1, the staff requested that the applicant describe the status of the USACE SPRAT

computer program referenced in SSAR Section 2.4.3.3 and any software quality assurance

measures that it employed to augment use of this software in support of the ESP application. In

response to RAI 2.4.3-1, the applicant stated that a significant portion of CPS dam design

included preparation of a discharge rating curve. It used the SPRAT model to prepare the

current discharge rating curve for the dam. The applicant stated that the presence of the ESP

facility does not require revision of the discharge rating curve for the dam and, therefore, doe:s

not require use of the SPRAT model. The applicant proposed to revise the ESP application tD

indicate that the hydraulic modeling, including SPRAT runs and water surface profile

estimations, were performed as part of the dam design and not as part of the ESP application.

In RAI 2.4.3-2, the staff asked the applicant to explain the bounding of the wave runup

calculations through the examination of the combined events criteria indicated in

ANSI/ANS-2.8-1992. The staff also requested that the applicant discuss coincident wave

calculation and the basis for applying a 40-mph design wind. In response to RAI 2.4.3-2, the

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applicant stated that it had previously estimated a maximum wave runup elevation, caused by a

sustained 40-mph overland wind speed acting on the PMF water surface elevation, at the dam

and at the CPS site of 711 ft MSL and reported it in CPS USAR Section 2.4.2.2. Section 2.4.10

of the CPS USAR uses a 48-mph overland wind speed coincident with the PMF for design of

the CPS circulating-water screenhouse. The applicant stated that use of these wind speeds did

not result in any safety-related issues for CPS Unit 1, since it determined that the site grade is

22.2 ft above the wave runup water surface elevation and 27.1 ft above the PMF water surface

elevation. Therefore, the applicant concluded that the CPS plant facility will not flood under any

circumstances.

The applicant stated that the ESP facility site is considered to be a dry site, consistent with

Condition 3 to Section 2.4.3 of RS-002, Attachment 2, and it will not be subject to flooding under

any circumstances. The applicant also indicated that the operation of the ESP facility would not

impact the potential for flooding at the existing dam or at the plant site. The applicant

suggested that the use of any wind speed for the purpose of estimating wave runup effects on

PMF water surface elevation would be inconsequential. The applicant stated that it retained the

use of the 40-mph wind speed in the ESP SSAR analysis to be consistent with the CPS USAR.

The applicant's review of more recent information published in ANSI/ANS-2.8-1992 indicates

that a greater wind speed than that used previously in the USAR and SSAR might be

appropriate. Using ANSI/ANS-2.8-1992, the applicant determined that a wind speed of 52 mph

should be used to estimate wave runup coincident with the PMF water surface elevation.

The applicant stated that it performed screening analyses to conservatively estimate the impact

of a 52-mph wind speed on wave runup. The applicant estimated new wave heights of 3.81 ft

for significant (33-percent probability) waves and 6.39 ft for maximum (1-percent probability)

waves. These new wave heights are 0.94 ft and 1.58 ft greater than those estimated in the

SSAR, which were based on a 40-mph wind speed. The applicant concluded that these

increases are not significant because of a more than 20-ft difference in ESP site grade and the

PMF water surface elevation in Clinton Lake.

In response to RAI 2.4.3-2, the applicant revised SSAR Sections 2.4.3.6 and 2.4.10 to include

this updated estimation for wave runup.

After reviewing the conclusions of the staff's initial independent bounding analysis, the applicant

elected to revise its application in order to provide the staff additional information to provide a

basis for the staff's conclusions as documented in this report. In Revision 4 of the application,

the applicant described its revised analysis. This new analysis did not rely on the applicant's

earlier baseline calculation from the CPS USAR. The staff did not accept the applicant's initial

approach as the applicant was unable to find adequate documentation of this earlier analysis.

In Revision 4 of the application, the applicant described an assessment of the PMF static flood

elevation height based on a unit hydrograph analysis of the 72-hour PMP. The PMP was

estimated using current National Weather Service guidance for deriving a PMP for the Clinton

watershed (HMRs 51, 52, and 53). The applicant presented PMF calculations using two

different synthetic unit hydrograph methods with two different conceptual watershed layouts.

One conceptual layout included the lake and the two drainages associated with the Salt Creek

and North Fork drainages as they enter Lake Clinton. The second conceptual layout further

refined the two drainages into a total of seven sub-drainages. The applicant used the USACE

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Hydrologic Engineering Center (HEC) model HEC-HMS 3.0.0 computer code to estimate the!

variation of the lake level in response to the PMP.

The synthetic unit hydrograph method relies on estimates of lag time and precipitation losses.

The applicant estimated time to peak using a relationship between drainage area and lag time

developed for Illinois by the USGS (Mitchell, 1948). The applicant estimated the precipitation

losses based on soil and land use data for the watershed. The most conservative estimate of

hydrostatic flood elevation, due to the PMF based on results of the applicant's HEC-HMS

analysis for the different synthetic unit hydrographs and conceptual layouts considered, was

709.8 f: MSL.

In Revision 4 of the application, the applicant estimated a maximum coincident wave runup of

6.4 ft based on calculations using the USACE's ACES version 1.07 code with a wind velocity of

52 mph. The applicant also estimated a probable maximum surge of 0.3 ft based on a wind

velocity of 100 mph.

2.4.3.2 Regulatory Evaluation

SSAR Table 1.5-1 shows the applicant's conformance to the NRC RGs. In RAI 1.5-1, the staff

asked tie applicant to provide a comprehensive listing of NRC regulations applicable to its ESP

SSAR. In its response to this RAI, the applicant indicated that RS-002, Attachment 2, identifies

the NRC, regulations applicable to its ESP SSAR. Section 2.4 of RS-002, Attachment 2,

describes the methods of review and the applicable acceptance criteria that the staff uses to

develop its findings and conclusions related to the hydrologic aspects of site characterization for

an ESP. Although the applicant did not indicate how the individual sections of SSAR

Section 2.4 address the hydrology-related site suitability criteria in RS-002, Attachment 2, the

staff reviewed this portion of the application for conformance with the applicable regulations and

considered the corresponding regulatory guidance, as identified below.

Section 2.4.3 of RS-002, Attachment 2, provides the review guidance used by the staff in

evaluating this SSAR section. The acceptance criteria address the requirements of 10 CFR

Parts 52 and 100 as they relate to identifying and evaluating the hydrologic features of the site.

The regulations in 10 CFR Parts 52 and 100 require the NRC to take into account a site's

physical characteristics (including seismology, meteorology, geology, and hydrology) when

determining the site's acceptability for a nuclear reactor(s).

To satisly the hydrologic requirements of 10 CFR Parts 52 and 100, the SSAR should describe

the hydrologic characteristics of the site and region and contain a PMF analysis. The applicant

should describe in detail sufficient to assess the site's acceptability and the potential for those

characteristics to influence the design of SSCs important to safety for a nuclear power plant(s)

of a specified type (or falling within a PPE) that might be constructed on the proposed site.

Meeting this guidance provides reasonable assurance that any hydrologic phenomena of

severity, up to and including the PMF, would pose no undue risk to the type of facility proposed

for the site.

In those cases for which a reactor design is not specified, the ESP applicant may instead

provide a PPE to characterize a facility or facilities for comparison with the hydrologic

characteristics of the site. A PPE can be developed for a single type of facility or a group of

candidate facilities by selecting limiting values of the relevant parameters.

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Specific criteria apply to the requirements regarding the hydrologic aspects of 10 CFR Parts 52

and 1 00.

The PMF, as defined in RG 1.59, has been adopted as one of the conditions to be evaluated in

establishing the applicable stream and river flooding design basis referenced in General Design

Criteria (GDC) 2, 'Design Bases for Protection against Natural Phenomena," of Appendix A,

"General Design Criteria for Nuclear Power Plants, to 10 CFR Part 50, "Domestic Licensing of

Production and Utilization Facilities." PMF estimates are needed for all adjacent streams or

rivers and site drainage (including the consideration of PMP on the roofs of safety-related

structures). The staff uses one of the following three conditions as criterion for accepting the

applicant's PMF-related design basis:

(1) The elevation attained by the PMF (with coincident wind waves) establishes a necessary

protection level to be used in the design of the facility.

(2) The elevation attained by the PMF (with coincident wind waves) is not controlling; the

design-basis flood protection level is established by another flood phenomenon (e.g., the

probable maximum hurricane).

(3) The site is "dry"; that is, the site is well above the elevation attained by a PMF (with

coincident wind waves).

When Condition 1 is applicable, the staff assesses the flood level. It may make the assessment

independently from basic data by detailed review of the applicant's analyses or by comparison

with estimates made by others that have been reviewed in detail. The applicant's estimates of

the PMF level and the coincident wave action are acceptable if the estimates are no more than

5 percent less conservative than the staff estimates. If the applicant's estimates of discharge

are more than 5 percent less conservative than the staff's, it should fully document and justify its

estimates or accept the staff estimates.

When either Condition 2 or 3 applies, the staff analyses may be less rigorous. For Condition 2,

acceptance is based on the protection level estimated for another flood-producing phenomenon

exceeding the staff estimate of PMF water levels. For Condition 3, the staff expects that the site

grade should be well above the staff-assessed PMF water levels. The evaluation of the

adequacy of the margin (difference in flood and site elevations) is generally a matter of

engineering judgment based on the confidence in the flood-level estimate and the degree of

conservatism in each parameter used in the estimate.

The staff used the appropriate sections of several documents to determine the acceptability of

the applicant's data and analyses. RG 1.59 provides guidance for estimating the PMF design

basis. The staff also used publications by NOAA and USACE to estimate PMF discharge and

water level condition at the site, as well as coincident wind-generated wave activity.

2.4.3.3 Technical Evaluation

In its evaluation, the staff performed an independent analysis to verify the applicant's PMF

analysis. The staff determined the PMP using HMRs 51 and 52 and ANSI/ANS-2.8-1992.

HMR 51 gives a set of charts showing the PMP depths for durations of 6, 12, 24, 48, and

72 hours corresponding to drainage areas of 10, 200, 1,000, 5,000, 10,000, and 20,000 mi2.

2-84
Using ihese charts, the staff determined PMP depths for drainage areas of 10, 200, 1000, and

5000 mi2 for all durations given in Table 2.4-3 of this SER.

Using ihe values in Table 2.4-3, the staff prepared depth-area-duration curves following the

guidelines of HMR 51 to bracket the drainage area of the Clinton Lake watershed. Figure 2.4-5

of this SER shows these depth-area-duration curves. Using Figure 2.4-5 of this SER to

determine the PMP depth values corresponding to a Clinton Dam drainage area of 289.2 mi2,

the staff constructed Table 2.4-4 of this SER.

Table 2.4-3 PMP Values in Inches near the Clinton Dam Drainage Area

Duration (hour) I

Area (mi2) 6 12 24 48 72 l

10 27.2 31.7 33.5 37.0 38.8 l

200 19.4 23.5 *25.0 28.2 29.9

1000 14.0 17.5 19.5 22.3 24.3

5000 8.9 11.9 13.6 16.6 18.1

Depth-Area-Duration Curves

10000 - -- .-.... .

E 1000I * _ -- 6-hoair

12-hour

gu 24-hour

, 10 X48-hour .

tM 72-hour _S. J--Look-up

10 --

0.0 5.0 10.0 15.0 20.0 25.0 30.0 35.0 40.0 45.0

PMP Depth (in.)

Figure 2.4-5 Depth-area-duration curves prepared for bracketing Clinton Dam drainage.

The dotted horizontal line corresponds to a drainage area of 289.2 mi2, equal to that cf

the Clinton Dam drainage area.

2-85
Table 2.4-4 PMP Depth-Duration Values in Inches for the Clinton Dam Drainage Area

I . Duration (hour)

Clinton Lake PMP 6 112 124 148 172

289.2 rmiF 18.2 22.1 23.7 26.8 28.7

The staff used HMR 52 and ANSI/ANS-2.8-1992 to provide guidelines for distributing the PMP

depths in time to create storm sequences during the PMP event. According to these guidelines,

the staff computed incremental PMP depths corresponding to all 6-hour durations during the

72-hour PMP (column 2 of Table 2.4-5 of this SER). The staff grouped the incremental depths

into three 24-hour periods in descending order (column 3 of Table 2.4-5 of this SER). The staff

rearranged the PMP depths within each 24-hour group according to guidelines given by

ANSI/ANS-2.8-1992 (column 4 of Table 2.4-5 of this SER). Finally, the staff rearranged column

4 according to the guidelines in ANSI/ANS-2.8-1992 to create the time distribution of the PMP

storm over the Clinton Dam drainage area (column 5 of Table 2.4-5 of this SER).

Table 2.4-5 Time Distribution of PMP for the Clinton Dam Drainage Area

6-hour Depth Group ANSI/ANS-2.8-1992 Time Distribution Time

Period (in.) No. Rearrange for PMP (in.) (h)

1 18.16 0.79 0.79 6

2 3.95 3.95 0.79 12

3 0.79 18.16 0.79 18

4 0.79 0.79 0.79 24

5 0.79 0.79 0.79 30

6 0.79 2 0.79 3.95 36

7 0.79 0.79 18.16 42

8 0.79 0.79 0.79 48

9 0.46 0.46 0.46 54

10 0.46 3 0.46 0.46 60

11 0.46 0.46 0.46 66

12 0.46 0.46 0.46 72

The staff independently verified the maximum hydrostatic (stillwater) elevation associated with a

PMF at the ESP site. Since certain historical data (e.g., gauged inflows, observed lake

elevations, etc.) were not available, multiple approaches were employed to provide a

conservative basis.

The staff performed three analyses to estimate the water surface elevation of Clinton Lake near

the ESP site during the PMF event. The first analysis bounded the water surface elevation by

conservatively assuming no loss and instantaneous translation of the PMP into the lake. This

bounding analysis was used to clearly establish that the site would remain dry. The second and

third analyses refined the maximum water surface elevation estimate by relaxing some of the

conservatism in the bounding analysis. These analyses were used to establish the site

characteristic for the proposed ESP site intake structure and associated systems that may be

placed below site grade.

2-86
The initial bounding analysis performed by staff conservatively estimated runoff by assuming

that all watershed runoff instantaneously entered Clinton Lake. In this analysis, the runoff for

each 6 hour duration during the PMP (Table 2.4-5) was computed by multiplying the PMP depth

by the area of Clinton Dam's drainage. An infiltration loss rate of 0.0 in/hr was assumed to

maximize the flood generated byathe PMP storm. Based on these assumptions, runoff entering

Clinton Lake had a peak discharge of 571,314 cfs.

The staff assumed instantaneous translation of the inflow wave through Clinton Lake using level

pool routing and the stage-storage curve provided by the applicant (SSAR Figure 2.4 12). The

stage-storage relationship was extended beyond elevation 708 ft MSL by extrapolation using

the slcpe of the stage-storage curve.

The applicant provided the spillway rating curve for the Clinton Dam (SSAR Figure 2.4 12) that

listed total combined discharge from service and auxiliary spillways corresponding to water

surface elevations ranging from 690 ft MSL to 710 ft MSL. The staff extended this stagedischarge relationship above elevation 710 ft MSL by extrapolation using the slope of the stagedischarge relationship at elevation of 710 ft MSL. At elevations above the top of the dam, the

staff assumed that water would spill along the entire dam face; the staff used a weir equation to

compute the resulting discharge.

Results, generated from the conservative, instantaneous translation, level pool routing method

produced the reservoir inflow-outflow sequence shown in Figure 2.4-6 of this SER. Figure 2.4-7

of this SER shows the corresponding reservoir-water surface elevations. The staff estimated

the maximum hydrostatic (stillwater) water surface elevation using this extremely conservative

and bounding approach to be 712.2 ft MSL.

2-87
Level Pool Routing of PMF through the Clinton Lake

- - Inflow -Outflow

600,000-

500,000 -

400S000 - 0 go2O 300,000 - ----

0 50 100 150 200 250 300 350 400- 450

Time (hours)

* Figure 2.4-6 Inflow and outflow from Clinton Lake during the PMF event calculated using

the instantaneous-translation level-pool routing method

2-88
Water Surface Elevation in Clinton Lake during the PMF Event

|-Water Surface Elevation

-J

co8

0

.0

0

M

V(U

uJ

Uf

L.

V

;'15s

710

705

-- n

-- = I = I- =

/UU ~. I- - ____ _ ____

Iz __ _71-\{_ ___

6!90

6t15615.

/

__ __ __ __I__ __ __ __ __

50 

50

0 50 100 I50 200 250 300 350 400 .1 ;0

Time (hours)

Figure 2.4-7 Water surface elevation in Clinton Lake during the PMF event calculated

using the instantaneous-translation level-pool routing method

A second analysis was performed by staff using the HEC-HMS Version 3.0.0 computer code.

The watershed was divided into eight sub-areas (Clinton Lake plus seven sub-basins) in the

same manner as Revision 4 of the SSAR and with the following sub-areas: 1) Salt Creek

headwater = 126.8 mi2, 2) Salt Creek local area northeast = 5 mi2, 3) Salt Creek local area

northwest = 16.3 mi2, 4) Salt Creek local area southeast = 6.2 mi2, 5) Salt Creek local area

southwest =8.2 mi2, 6) North Fork headwater = 111 mi2, 7) North Fork local area = 15 mi2, and

8) Clinton Lake area = 7.6 mi2. The basins were connected together in the model so that

outflow from the basins immediately entered the lake. This is a conservative assumption since

the flow is not routed.

The Clinton Lake inflow hydrograph was estimated using the unit hydrograph approach.

Synthetic unit hydrographs were developed to determine the runoff from each sub-basin area..

The storm hydrograph entering Clinton Lake was computed based on two-hour unit

hydrographs for each sub-basin. An antecedent storm equal in volume to 50% of the PMP,

followed by three days of no rainfall, and followed by the full PMP volume (Table 2.4-5) was

applied to the Clinton Lake watershed. In addition, the PMP used in the staff's analysis had a

total volume of 28.7 in., which is more conservative compared to the applicant's value of 27.8 in.

One of the key parameters in the synthetic unit hydrograph method is the lag time. Values of

lag times; used by the applicant were based on limited published watershed data. The lag times

2-89
-

used by the applicant and the staff ('standard lag' Table 2.4-6) in the HEC-HMS model were as

follows: 1) Salt Creek headwater = 12.3 hrs, 2) Salt Creek local area northeast = 1.1 hrs, 3) Salt

Creek local area northwest = 2.6 hrs, 4) Salt Creek local area southeast = 1.4 hrs, 5) Salt Creek

local area southwest = 1.7 hrs, 6) North Fork headwater = 11.3 hrs, and 7) North Fork local area

= 2.5 hrs. The selected lag values approximate those developed in Mitchell (1948) and the CPS

USAR, although for the present analysis seven watershed sub-areas were used so

corresponding values are not directly comparable. Since recent direct field data are not

available, the lag time values are subjective. The staff appreciates the empirical nature of these

coefficients and of the SCS method in general, which is generally not advised for use for areas

larger than 2,000 ac (NOAA, 2006). To test the overall range of Clinton Lake PMF water

surface elevations, the staff varied the lag time by shortening and increasing the lag time by

10 percent. Maximum Clinton Lake PMF water surface elevations are shown in Table 2.4-6 for

these scenarios.

A second key parameter in the PMF computation method is the infiltration loss. The staff

evaluated model sensitivity by reducing the constant loss parameter used by the applicant (0.1

in/hr) first by half (0.05 in/hr) and then eliminating infiltration altogether (0.0 in/hr loss).

Computed time series of Clinton Dam outflow and Clinton Lake water surface elevation during

the storm event are shown in Figure 2.4-8 and Figure 2.4-9, respectively. The maximum Clinton

Lake PMF water surface elevations for this range of infiltration loss parameter values are shown

in Table 2.4-6.

2-90
20C,000

120.000 - Loss =0.0 in/hr |

4I 120,000-

U A

80,000 A_ __ 

0 0

60,000 . N 

a 0

a~h

40,000 -eon A

20,2000 OA

0?

0 50 100 150 200 250 300 350 400

Time (hours)

Figure 2.4-8 Inflow and outflow Hydrographs for Clinton Lake during the PMF event

using the HEC-HMS model and the seven sub-basins + lake method

2-91
712

710

_ 708 !AP -ID

706 - lMP a Loss =0.1 inthr

n 704 afW A Loss = 0.05 in/hr

.0 706

05

r 704 o Loss = 0.0 in/hr

o on

co 7 0 0 ° _ _ _ _ _ _ _ _ _ . . __

e 698 -

co

CA 696 O b °

I.-

e) 694 a

692 -~-

690

688!

0 50 100 150 200 250 300 350 400

Time (hours)

Figure 2.4-9 Water surface elevation of Clinton Lake during the PMF event using the

HEC-HMS model and the seven sub-basins + lake method

The third analysis examined by staff also utilized HEC-HMS; however the watershed was

divided into five sub-basins. Unit hydrographs following Mitchell (1948) and discussed in the

CPS USAR were used. These unit hydrographs were made more conservative by shortening

the time to peak by 33% and increasing the peak discharge by 20%. The Clinton Lake

watershed was subjected to the same 50 percent PMP volume antecedent storm followed by

the full PMP volume (Table 2.4-5) as the second analysis. For this analysis, the initial loss and

constant loss rate were both set to zero. As in the second analysis, the routing from the five

sub-basins to the Clinton Lake was instantaneous (no routing) and the PMP volume was

28.7 in.; both of which are conservative assumptions. The resulting maximum water surface

elevation of Clinton Lake during the PMF was 710.6 ft MSL.

Results from the three analyses performed by staff are summarized in Table 2.4-6. Results

from the initial bounding analysis clearly establish that the site would remain dry during the PMF

event. The second and third analyses were used to establish the site characteristic for the

intake structures and associated safety related systems located below site grade that might be

inundated. Water surface elevation results from these analysis fell within 4% of the applicant's

water surface elevation value. Based upon the consistency of the results of the various

analyses, the staff finds that the applicant's value of 709.8 ft MSL for the maximum hydrostatic

(stillwater) water surface elevation is reasonably conservative.

2-92
Table 2.4-6 Summary of Maximum PMF Water Surface Elevations (ft MSL) at the ESP Site

Constant Infiltration Loss Rates (in/hr)

Method 0.0 0.05 1 0.1

Instantaneous Translation 712.2 I

SCS with Standard Lag 710.6 710.0 709.4

Mitchell Unit Hydrograph 710.6 @ _

_ _ _Method _ Lag -10% | Standard Lag J Lag + 10%

L SCS with Loss = 0.1 1 709.9 | 709.4 1 709.0

The influence of coincident wind wave activity would cause an increase in the PMF water

surface elevation. The staff conservatively estimated the probable maximum windstorm

(PMWS ), as defined by ANSI/ANS 2.8-1992, to be equivalent to 100 mph. This conservative

wind velocity is based upon the location of the site, which is within 150 mi of the Great Lakes.

The staff estimated wave heights using the method outlined in the Coastal Engineering Manual

with a site-specific fetch of 1.2 mi. The resulting significant (average height of the one-third

highest waves) wave height is 3.9 ft, and the 1-percent maximum (average height of the largest

1 percent of all waves) wave height is 6.6 ft. Therefore, staff find that the applicant's value of

6.4 ft is reasonable.

A further increase of water surface elevation may result from storm surge, as discussed more

fully in section 2.4.5 of this SER. Storm surge would result in an additional increase in water

surface elevation of 0.3 ft. Combining the effects of PMF (elevation 709.8 ft MSL), coincident

wind wave activity (6.4 ft), and storm surge (0.3 ft), the staff estimated a resulting maximum

water surface elevation at the ESP site of 716.5 ft MSL. The staff, therefore, determined that

the ESP site, excluding the ESP intake structures, is safe from flooding during a PMF event.

For the ESP intake structure, the COL applicant needs to design the intake structures to

withstand the combined effects of PMF, coincident wind wave activity, and wind setup of a

water surface elevation of 716.5 ft MSL. COL Action Item 2.4-3, discussed in Section 2.4.2.3; of

this SER, states this.

In response to RAI 2.4.3-1, the applicant stated that the presence of the ESP facility does no:

require hat the discharge rating curve for the dam be revised and, therefore, does not require

use of the SPRAT model. The applicant revised the ESP application to remove reference to the

hydraulic modeling. The staff determined that the applicant's response to RAI 2.4.3-1 is

satisfactory.

With respect to the effects of wind speed on PMF water level elevation, the applicant stated in

response to RAI 2.4.3-2 that use of these wind speeds did not result in any safety-related issues

for CPS Unit 1 since the site grade was determined to be 22.2 ft above the wave run-up water

surface elevation and 27.1 ft above the PMF water surface elevation. As such, the applicant

determined that the CPS plant facility could not flood under any circumstances. The staff

determined that the applicant's response to RAI 2.4.3-2 is satisfactory.

2-93
2.4.3.4 Conclusions

As set forth above, the applicant provided sufficient information pertaining to the identification

and evaluation of PMFs on streams and rivers at the site. SSAR Section 2.4.3 conforms to

Section 2.4.3 of RS-002, Attachment 2, with regard to this objective.

Section 2.4.3 of RS-002, Attachment 2, provides that the SSAR should address the

requirements of 10 CFR Parts 52 and 100 as they relate to identifying and evaluating PMFs on

streams and rivers at the site. Although the applicant did not specifically address the above

regulations in SSAR Section 2.4.3, the staff concludes that, by conforming to Section 2.4.3 of

RS-002, Attachment 2, it has met the requirements to identify and evaluate PMFs on streams

and rivers at the site with respect to 10 CFR 52.17(a) and 10 CFR 100.20(c). Further, the staff

finds that the applicant considered the most severe natural phenomena that have been

historically reported for the site and surrounding area in establishing the stream and river

design-basis flood, with sufficient margin for the limited accuracy, quantity, and period of time in

which the historical data have been accumulated.

2.4.4 Potential Dam Failures

2.4.4.1 Technical Information in the Application

In SSAR Section 2.2.4, the applicant stated that no other dams exist either upstream or

downstream of Clinton Dam. The applicant also indicated that failure of Clinton Dam will not

result in a loss of water from the submerged UHS pond.

2.4.4.2 Regulatory Evaluation

SSAR Table 1.5-1 shows the applicant's conformance to the NRC RGs. In RAI 1.5-1, the staff

requested that the applicant provide a comprehensive listing of the NRC regulations applicable

to its ESP SSAR. In its response to this RAI, the applicant indicated that RS-002, Attachment 2,

identifies the NRC regulations applicable to its ESP SSAR. Section 2.4 of RS-002,

Attachment 2, describes the methods of review and the applicable acceptance criteria that the

staff uses to develop its findings and conclusions related to the hydrologic aspects of site

characterization for an ESP. Although the applicant did not indicate how the individual sections

of SSAR Section 2.4 address the hydrology-related site suitability criteria in RS-002,

Attachment 2, the staff reviewed this portion of the application for conformance with the

applicable regulations and considered the corresponding regulatory guidance, as identified

below.

Section 2.4.4 of RS-002, Attachment 2, provides the review guidance used by the staff in

evaluating this SSAR section. The acceptance criteria are based on meeting the requirements

of the following regulations:

* 10 CFR Parts 52 and 10 100 as they relate to evaluating the hydrologic features of the

site

* 10 CFR 100.23 as it relates to establishing the design-basis flood caused by a seismic

dam failure

2-94
The regulations at 10 CFR 52.17(a) and 10 CFR 100.20(c) require that the NRC take into

account the site's physical characteristics (including seismology, meteorology, geology, and

hydrology) when determining its acceptability to host a nuclear reactor(s).

The regulations at 10 CFR Parts 52 and 100 are applicable to SSAR Section 2.4.4, which

addresses the physical characteristics, including hydrology, the Commission considers when

determining the site acceptability for a power reactor. To satisfy the hydrologic requirements of

10 CFR Parts 52 and 100, the applicant's safety assessment should describe the hydrologic

characteristics of the region and contain an analysis of potential dam failures. The applicant

should describe in detail sufficient to assess the site acceptability and the potential for those

characteristics to influence the design of SSCs important to safety. Meeting this criterion

provides reasonable assurance that the effects of high water levels resulting from failure of

upstream dams, as well as those of low water levels resulting from failure of a downstream clam,

will pose no undue risk to the type of facility proposed for the site.

In those cases for which a reactor design is not specified, the ESP applicant may instead

provide a PPE to characterize a facility or facilities for comparison with the site's hydrologic

characteristics. A PPE can be developed for a single type of facility or a group of candidate

facilities by selecting the limiting values of parameters. Important PPE parameters for SSAR

Section 2.4 include, but are not limited to, precipitation (e.g., maximum design rainfall rate arid

snow load) and the allowable site water level (e.g., maximum allowable flood or tsunami surcle

level arid maximum allowable ground water level).

The regulation at 10 CFR 100.23 requires consideration of geologic and seismic factors in the

determination of site suitability. Pursuant to 10 CFR 100.23(c), the applicant must obtain

geologib and seismic data for evaluating seismically induced floods, including failure of an

upstream dam during an earthquake.

The regulation at 10 CFR 100.23 is applicable to Section 2.4.4 of RS-002, Attachment 2,

because it requires investigation of seismically induced floods or low water levels that guide the

Commission in its consideration of the suitability of proposed sites for nuclear power plants.

RG 1.70, Revision 3, "Standard Format and Content of Safety Analysis Reports for Nuclear

Power Reactors-LWR Edition," issued November 1978, provides more detailed guidance on

the investigation of seismically induced floods, including results for seismically induced dam

failures and antecedent flood flows coincident with the flood peak. Meeting the requirements of

10 CFR 100.23 provides reasonable assurance that, given the geologic and seismic

characteristics of the proposed site, a nuclear power plant(s) of a specified type (or falling within

a PPE) could be constructed and operated on the proposed site without undue risk to the health

and safety of the public with respect to those characteristics.

The staff used the following criteria to meet the requirements of 10 CFR Part 52, 10 CFR

Part 100, and 10 CFR 100.23, as they relate to dam failures:

* 1The staff will review the applicant's analyses and independently assess the coincident

river flows at the site and at the dams being analyzed. ANSI/ANS-2.8-1992 provides

cuidance on acceptable river flow conditions to be assumed coincident with the dam

failure event. To be acceptable, the applicant's estimates (which may include landslideinduced failures) of the flood discharge resulting from the coincident events should be no

more than 5 percent less conservative than the staff estimates. If the applicant's

2-95
estimates differ by more than 5 percent, the applicant should fully document and justify

its estimates or accept the staff estimates.

The applicant should identify the location of dams and potentially "likely" or severe

modes of failure. The applicant also should identify dams or embankments for the

purpose of impounding water for a nuclear power plant(s) that might be constructed on

the proposed site, and discuss the potential for multiple, seismically induced dam

failures and the domino failure of a series of dams. Applicants should use approved

models of the USACE and the Tennessee Valley Authority to predict the downstream

water levels resulting from a dam breach. First-time use of other models will necessitate

complete model description and documentation. The staff bases its acceptance of the

model (and subsequent analyses) on staff review of model theory, available verification,

and application. In cases which assume something other than instantaneous failure, the

conservatism of the rate of failure and shape of the breach should be well documented.

The applicant should document a determination of the peak flow rate and water level at

the site for the worst possible combination of dam failures, summary analysis that

substantiates the condition as the critical permutation, and a description (and the bases)

of all coefficients and methods used. In addition, the applicant should consider the

effects of other concurrent events on plant safety, such as blockage of the river and

waterborne missiles.

* The applicant also should consider the effects of coincident and antecedent flood flows

(or low flows for downstream structures) on initial pool levels. Depending upon

estimated failure modes and the elevation difference between plant grade and normal

river levels, it may be acceptable to use conservative, simplified procedures to estimate

flood levels at the site. Where calculated flood levels using simplified methods are at or

above plant grade and use assumptions which cannot be demonstrated as conservative,

applicants should use unsteady flow methods to develop flood levels at the site.

References 7,13, and 14 of RS-002 are acceptable methods; however, other programs

could be acceptable with proper documentation and justification. The applicant should

summarize computations, coefficients, and methods used to establish the water level at

the site for the most critical dam failures. Coincident wind-generated wave activity

should be considered in a manner similar to that discussed in Section 2.4.3 of RS-002.

RG 1.59 provides guidance for estimating the design basis for flooding, considering the worst

single phenomenon and a combination of less severe phenomena.

2.4.4.3 Technical Evaluation

The staff consulted maps published by the USGS to independently verify the applicant's

statement that no other dams exist upstream of Clinton Dam. The staff found that a small

impoundment called Dawson Lake, created by construction of a dam on the North Fork of Salt

Creek, exists upstream of the ESP site. Dawson Lake is located approximately 17.1 miles

north-northeast of the ESP site. Dawson Lake has a surface area of 152 ac, with an average

depth of 9.8 ft and a storage capacity of 67.10 million ft3 or 1541 ac-ft. The lake is mainly used

for recreation.

The applicant should consider the effects of the failure of the Dawson Lake dam in SSAR

Section 2.4.4. In response to RAI 2.4.1-3, the applicant added information to SSAR

2-96
Section 2.4.1.2 regarding dams upstream and downstream of Clinton Lake to support its

statement that such dams could not affect the availability of water at the ESP site.

The applicant stated that, with respect to future dams, a representative of the IDNR, Office of

Water, Division of Water Resources Management, Dam Safety Section, advised that there are

no recent or pending permits for recreational or water supply dams upstream of Clinton Lake.

The applicant revised SSAR Section 2.4.1.2 to state that there are no existing reservoirs or

dams upstream or downstream from Clinton Lake that could affect the availability of water to

Clinton Lake. The applicant identified four recreational dams, two on the North Fork of Salt

Creek upstream of Clinton Lake (Moraine View Dam on Dawson Lake, and Vance Lake Dam on

Clyde '/ance Lake) and two downstream of Clinton Lake (Weldon Springs State Park Lake Elam

and Little Galilee Lake Dam).

The staff determined that the maximum combined storage capacity of the two reservoirs

upstream of Clinton Lake is 4446 ac-ft. The original capacity of Clinton Lake at normal water

surface elevation of 690 ft MSL, as determined by the staff using the stage-storage relationship

for Clinton Lake given in CPS USAR Figure 2.4-14, is 74,200 ac-ft. The maximum combined

storage capacities of the two reservoirs upstream of Clinton Lake is about 6 percent of the

normal storage capacity of Clinton Lake. The staff determined, using the same stage-storage

relationship for Clinton Lake, that an increase in storage by 4446 ac-ft, with an initial water

surface elevation in Clinton Lake of 690 ft MSL, would result in an increase in water surface

elevation of 3.1 ft. This estimate is very conservative, since it ignores water discharged over the

service spillway when the water surface elevation in Clinton Lake exceeds its crest elevation of

690 ft MISL. Discharge over the service spillway reduces the water surface elevation in Clinton

Lake, and the final increase in water surface elevation resulting from a breach of the two

upstream dams is likely to be less than 3.1 ft.

The staff's estimate of maximum water surface elevation in Clinton Lake because of PMF, wind

setup, and wave runup, as discussed in Section 2.4.3 of this SER, is 716.5 ft MSL. The staff

plans tc include 716.5 ft MSL as a site characteristic in any ESP that might be issued for this

application. Even if the maximum water surface elevation in Clinton Lake were to be

augmented by 3.1 ft because of a breach of the two upstream dams, leading to a water surface

elevation of 719.6 ft MSL in Clinton Lake, the ESP site, located at 735 ft MSL, would be safe

from flooding. Therefore, the staff determined that the applicant's response to RAI 2.4.1-3 is

satisfactory.

2-97
Figure 2.4-10 Dawson Lake and Dam located approximately 17.1 miles north-northeast of

the ESP site. Dawson Lake is located on the North Fork of Salt Creek.

2-98
2.4.4.4 Conclusions

As set lorth above, the applicant provided sufficient information pertaining to potential dam

failures at the site. SSAR Section 2.4.4 conforms to Section 2.4.4 of RS-002, Attachment 2,

with regard to this objective.

Section 2.4.4 of RS-002, Attachment 2, provides that the SSAR should address the

requirements of 10 CFR Parts 52 and 100 as they relate to the identification and evaluation of

potential dam failures at the site. Although the applicant did not specifically address the above

regulations in SSAR Section 2.4.4, the staff concludes that by conforming to Section 2.4.4 of

RS-002, Attachment 2, it has met the requirements for potential dam failures with respect to

10 CFFi 52.17(a) and 10 CFR 100.20(c). Further, the staff finds that the applicant has

considered the most severe natural phenomena that have been historically reported for the site

and surrounding area in establishing the design-basis dam failure, with sufficient margin for the

limited accuracy, quantity, and period of time in which the historical data have been

accumulated.

2.4.5 Probable Maximum Surge and Seiche Flooding

The EGC ESP site is located on the shores of Clinton Lake, approximately 6 miles east of the

city of Clinton in DeWitt County, in central Illinois at elevation 735 ft MSL.

2.4.5.1 Technical Information in the Application

The applicant stated in Revision 0 of SSAR Section 2.4.5 that there are no large bodies of water

near the ESP site where significant storm surges and seiche can occur. The applicant also

stated that Clinton Lake is not large enough to develop surge and seiche conditions more

critical than the PMF condition. In Revision 4 of the SSAR, the applicant revised their approach

to provide a higher level of conservatism, and the maximum storm surge at the site was stated

as 0.3 ft. This value was computed using a wind speed of 100 mph, an effective fetch of 0.8 rni,

and a water depth of 40.5 ft.

2.4.5.2 Regulatory Evaluation

SSAR Table 1.5-1 demonstrates the applicant's conformance to the NRC RGs. The staff

requested, in RAI 1.5-1, that the applicant provide a comprehensive listing of the NRC

regulations applicable to its ESP SSAR. In its response to this RAI, the applicant indicated that

RS-002, Attachment 2, identifies the NRC regulations applicable to its ESP SSAR. RS-002,

Attachment 2, describes the methods of review and the applicable acceptance criteria that the

staff should use to develop its findings and conclusions related to the hydrologic aspects of site

characterization for an ESP. Although the applicant did not indicate how it addresses the

hydrology-related site suitability criteria in RS-002, Attachment 2, the staff reviewed this portion

of the application for conformance with the applicable regulations and considered the

corresponding regulatory guidance, as identified below.

Section 2.4.5 of RS-002, Attachment 2, provides the review guidance used by the staff in

evaluating this SSAR section. The applicant must meet the requirements of 10 CFR Parts 52

and 100 as they relate to evaluating the hydrologic characteristics of the site. To determine

whether the applicant met the relevant hydrologic requirements of 10 CFR Parts 52 and 100,

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the staff used the specific criteria in 10 CFR 52.17(a) and 10 CFR 100.20(c), which require that

the site's physical characteristics (including seismology, meteorology, geology, and hydrology)

be considered when-determining its acceptability for a nuclear reactor(s). Further, RS-002,

Attachment 2, states the following:

To satisfy the hydrologic requirements of 10 CFR Parts 52 and 100, the

applicant's safety assessment should contain a description of the surface and

subsurface hydrologic characteristics of the region and an analysis of the

potential for flooding due to surges or seiches. This description should be

sufficient to assess the acceptability of the site and the potential for a surge or

seiche to influence the design of structures, systems, and components important

to safety for a nuclear power plant or plants of specified type that might be

constructed on the proposed site. Meeting this requirement provides reasonable

assurance that the most severe flooding likely to occur as a result of storm

surges or seiches would not pose an undue risk to the type of facility proposed

for the site.

In those cases in which a reactor design is not specified, the ESP applicant may instead provide

a PPE to characterize a facility or facilities for comparison with the hydrologic characteristics of

the site. A PPE can be developed for a single type of facility or a group of candidate facilities by

selecting the limiting values of parameters. Important PPE parameters for safety assessment

identified in SSAR Section 2.4 include but are not limited to precipitation (e.g., maximum design

rainfall rate and snow load) and the allowable site water level (e.g., maximum allowable flood or

tsunami surge level and maximum allowable ground water level).

If it has determined that surge and seiche flooding estimates are necessary to identify flood

design bases, the staff will consider the applicant's analysis complete and acceptable if the

following areas are addressed and can be independently and comparably evaluated from the

applicant's submission.

* All reasonable combinations of probable maximum hurricane, moving squall line, or

other cyclonic wind storm parameters are investigated, and the most critical combination

is selected for use in estimating a water level.

* Models used in the evaluation are verified or have been previously approved by the

staff.

* Detailed descriptions of bottom profiles are provided (or are readily obtainable) to enable

an independent staff estimate of surge levels.

* Detailed descriptions of shoreline protection and safety-related facilities are provided to

enable an independent staff estimate of wind-generated waves, runup, and potential

erosion and sedimentation.

* Ambient water levels, including tides and sea level anomalies, are estimated using

NOAA and USACE publications as described below.

* Combinations of surge levels and waves that may be critical to the design of a nuclear

power plant(s) of specified type (or falling within a PPE) that might be constructed on the

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proposed site are considered, and adequate information is supplied to allow a

determination that no adverse combinations have been omitted.

* iAt the COL stage, if the applicant elects Position 2 of RG 1.59, then it should

demonstrate that the design basis for flood protection of all safety-related facilities

identified in RG 1.29 is adequate in terms of the time necessary for implementation of

any emergency procedures. The applicant should also demonstrate that all potential

flood situations that could negate the time and capability to initiate flood emergency

procedures are provided for in the less severe design basis selected.

In this section of the safety assessment, the applicant may also justify that surge and seiche

flooding estimates are not necessary to identify the flood design basis (e.g., the site is not near

a large body of water).

Hydrometeorological estimates and criteria for development of probable maximum hurricanes

for east and Gulf Coast sites, squall lines for the Great Lakes, and severe cyclonic wind storms

for all lake sites by USACE, NOAA, and the staff are used for evaluating the conservatism of the

applicant's estimates of severe windstorm conditions, as discussed in RG 1.59. The USACE

and NOAA criteria call for variation of the basic meteorological parameters within given limits to

determine the most severe combination that could result. The applicant's hydrometeorological

analysis should be based on the most critical combination of these parameters.

The staff used data from the publications of NOAA, USACE, and other sources (such as tide

tables, tide records, and historical lake level records) to substantiate antecedent water levels.

These antecedent water levels should be as high as the "1 0-percent exceedance" monthly

spring high tide, plus a sea level anomaly based on the maximum difference between recorded

and predicted average water levels for durations of 2 weeks or longer for coastal locations or

the 100-year recurrence interval high water for the Great Lakes. In a similar manner,

independent staff analysis can evaluate the storm track, wind fields, effective fetch lengths,

direction of approach, timing, and frictional surface and bottom effects to ensure that the mosi:

critical values have been selected. Models used to estimate surge hydrographs that have not

previously been reviewed and approved by the staff are verified by reproducing historical

events, with any discrepancies in the model being on the conservative (i.e., high) side.

Criteria and methods of USACE, as generally summarized in Reference 9 of RS-002,

Attachment 2, are used as a standard to evaluate the applicant's estimate of coincident windgenerated wave action and runup.

Criteria and methods of USACE and other standard techniques are used to evaluate the

potential for oscillation of waves at natural periodicity.

At the COL stage, the applicant will use the criteria and methods of USACE to evaluate the

adequacy of protection from flooding, including the static and dynamic effects of broken,

breaking, and nonbreaking waves. RG 1.102, Revision 1, "Flood Protection for Nuclear Power

Plants," issued February 1976, provides further guidance on flood protection. RG 1.125,

Revision 1, "Physical Models for Design and Operation of Hydraulic Structures and Systems for

Nuclear Power Plants," issued October 1978, provides guidance for using physical models in

assessing flood protection.

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2.4.5.3 Technical Evaluation

The staff conductdd'its review in accordance with' Sectionr'2.4.5 of RS-002, Attachment 2, and ''

RG 1.59. The ESP site is located inland on the shores of Clinton Lake, formed by inundation of

the North Fork of Salt Creek and Salt Creek by Clinton Dam, located approximately 1200 ft

downstream of the confluence of the North Fork of Salt Creek with Salt Creek. Salt Creek flows

west and joins with the Sangamon River, which in turn joins the Illinois River. The Illinois River

is a tributary of the Mississippi River.

The ESP site is located at an elevation of 735 ft MSL. The staff concludes that the ESP site is

not subject to storm surge from either the ocean or the Great Lakes.

The following describes the staff's independent evaluation performed to estimate seiche effects.

Fetch length is one of the key parameters for determining wind setup and is generally based

upon the longest straight-line distance from the site to the opposing shore. Although the site is

approximately 3 miles from the dam and 10 miles from the upstream end of the reservoir, the

longest straight-line distance to the opposing shore is approximately 6340 ft (see Figure 2.4-11

of this SER).

Irregular lake bathymetry and strong thermal stratification, which exists during various parts of

the year, affect wind setup. An accurate determination of the wind setup that considers all of

these complicating factors would require use of a multidimensional hydrodynamic and water

quality model.

A simplified and conservative approach to estimate wind setup is to assume that the lake is not

thermally stratified and can be represented as a uniform rectangular basin with one side equal

to the fetch length. The staff assumed a uniformly distributed wind stress along the water

surface in the direction of the fetch to simplify the hydrodynamic equations of motion and make

it possible to obtain an analytic solution for the surface setup. As presented in N.S. Heaps

(1984) the resulting solution is:

CU 2 L

h

where ? is the wind setup in ft; U is the wind speed in mph; h is the average depth of the lake in

ft; L is the fetch length in ft; and C is an empirical coefficient equal to approximately 1 .5x1 07.

The staff used a value of 6340 ft for L. Bathymetry contours (see Figure 2.4-11 of this SER)

indicate that the original river level was at an elevation of approximately 660 ft MSL. Since the

water depth, h, is in the denominator, a smaller depth would produce a larger (i.e., more

conservative) wind setup. Therefore, the staff used the relatively conservative average water

depth value of 30 ft.

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Figure 2.4-11 Clinton Power Station site and fetch length

One of the derivation assumptions in the wind setup equation above is that the wind speed is

steady and uniformly blowing in the direction of maximum fetch. The staff conservatively

estimated the PMWS, as defined by ANSI/ANS 2.8-1992, to be equal to a 100-mph wind. This

windstorm is based upon the location of the site, which is within 150 miles of the Great Lakes.

The staff used this conservative value as the steady over-water wind speed in the wind setup

equation.

Using these parameters, the staff estimated the resulting wind setup as 0.3 ft. The staff

combined this increase in water surface elevation at the ESP site with the water surface

elevation estimated as a result of the PMF and coincident wind wave activity to estimate the

maximum water surface elevation at the site in Section 2.4.3 of this SER.

The staff estimated the period of oscillation resulting from seiche, along the fetch length line

shown in Figure 2.4-11 of this SER, based on the theory for free oscillation of water of uniform

depth and temperature in a rectangular basin (Wilson, 1972):

T 2L

where T is the period of seiche motion in seconds; g is the acceleration resulting from gravity

(32.2 feet per square second (ft/s2)); and L and h are as defined in the equation for wind setup.

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The staff estimated the resulting seiche period to be approximately 6.8 minutes. This period is

significantly shorter than meteorologically induced wave periods (e.g., synoptic storm pattern

frequency and dramatic reversals in steady win'ddiredtion-rie-t'uired for wind setup). Therefore,

the staff concluded that meteorologically forced resonance is not likely. The staff also

concluded that seismically induced seiche is unlikely in Clinton Lake because of the large

difference between the period of oscillation resulting from seiche and that of seismically induced

vibrations.

2.4.5.4 Conclusions

As set forth above, the applicant provided sufficient information pertaining to the identification

and evaluation of probable maximum surge and seiche flooding at the site. SSAR Section 2.4.1

conforms to Section 2.4.5 of RS-002, Attachment 2, with regard to this objective.

Section 2.4.5 of RS-002, Attachment 2, provides that the SSAR should address the

requirements of 10 CFR Parts 52 and 100 as they relate to identifying and evaluating probable

maximum surge and seiche flooding at the site. Although the applicant did not specifically

address the above regulations in SSAR Section 2.4.5, the staff concludes that, by conforming to

Section 2.4.5 of RS-002, Attachment 2, it has met the requirements to identify and evaluate

probable maximum surge and seiche flooding at the site with respect to 10 CFR 52.17(a) and

10 CFR 100.20(c). In addition, the seismically induced flooding analysis reflects the most

severe seismic event historically reported for the site and surrounding area (with sufficient

margin for the limited accuracy, quantity, and period of time in which the historical data have

been accumulated). In addition, the staff concludes that the applicant partially conforms to

GDC 2, insofar as that analysis defines design bases for seismically induced surge and seiche.

2.4.6 Probable Maximum Tsunami Flooding

The EGC ESP site is 6 miles east of the city of Clinton, in DeWitt County, located in central

Illinois. It is adjacent to Unit 1 of the CPS on the shore of Clinton Lake, an impoundment on

Salt Creek. Salt Creek flows 50 miles from the Clinton Dam to its confluence with the

Sangamon River. The Sangamon River, from its confluence with Salt Creek, flows 40 miles to

merge with the Illinois River north of Beardstown. The Illinois River flows 90 miles from its

confluence with the Sangamon River to meet the Mississippi River near Grafton. The

Mississippi River flows 1172 miles from its confluence with the Illinois River to the Gulf of

Mexico (NOAA, 2004). The Gulf of Mexico is the body of open water directly downstream from

Clinton Lake that is subject to seismically generated tsunamis.

2.4.6.1 Technical Information in the Application

The applicant stated in Revision 0 of SSAR Section 2.4.6 that "the site will not be subjected to

the effects of tsunami flooding because the site is not adjacent to a coastal area." In Revision 3

of the SSAR, the applicant also considered the effects of a lake tsunami caused by a hillslope

failure. The applicant's analysis produced a maximum tsunami height at 0.4 ft. Based on the

elevation of the ESP site, the applicant concluded that landslide-induced tsunamis do not pose

a risk to the site.

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2.4.6.2 Regulatory Evaluation

SSAR Table 1.5-1 presents the applicant's conformance to the NRC RGs. The staff reques:ed,

in RAI 1.5-1, that the applicant provide a comprehensive listing of the NRC regulations

applicable to its ESP SSAR. In its response to this RAI, the applicant indicated that RS-002,

Attachment 2, identifies the NRC regulations applicable to its ESP SSAR. RS-002,

Attachment 2, describes the methods of review and the applicable acceptance criteria that the

staff uses to develop its findings and conclusions related to the hydrologic aspects of site

characl:erization for an ESP. Although the applicant did not indicate how it addressed the

hydrology-related site suitability criteria in RS-002, Attachment 2, the staff reviewed this portion

of the application for conformance with the applicable regulations and considered the

corresponding regulatory guidance, as identified below.

Section 2.4.6 of RS-002, Attachment 2, provides the following review guidance used by the staff

in evaluating this SSAR section:

* 10 CFR Parts 52 and 100, as they relate to identifying and evaluating the hydrologic

features of the site

* 10 CFR 100.23, as it relates to investigating the tsunami potential at the site

The regulations at 10 CFR 52.17(a) and 10 CFR 100.20(c) require that the site's physical

characteristics (including seismology, meteorology, geology, and hydrology) be taken into

account when determining its acceptability to host a nuclear reactor(s). The regulations at

10 CFR Parts 52 and 100 are applicable to Section 2.4.6 of RS-002, Attachment 2, because

they address the physical characteristics, including hydrology, the Commission considers when

determining the acceptability of the proposed site. To satisfy the hydrologic requirements of

10 CFR Parts 52 and 100, the applicant's safety assessment should contain a description of the

hydrologic characteristics of the coastal region in which the proposed site is located and an

analysis of severe seismically induced waves. The applicant should describe in detail sufficient

to assess the acceptability of the site and the potential for a tsunami to influence the design

of SSCs important to safety for a nuclear power plant(s) of specified type that might be

constructed on the proposed site. Meeting this requirement provides reasonable assurance that

the most severe flooding likely to occur as a result of a tsunami would pose no undue risk to the

type of facility proposed for the site.

In those cases for which a reactor design is not specified, the ESP applicant may instead

provide a PPE to characterize a facility or facilities for comparison with the hydrologic

characteristics of the site. A PPE can be developed for a single type of facility or a group of

candidate facilities by selecting limiting values of parameters. Important PPE parameters for

safety assessment identified in Section 2.4 include, but are not limited to, precipitation (e.g.,

maximum design rainfall rate and snow load) and the allowable site water level (e.g., maximum

allowable flood or tsunami surge level and maximum allowable ground water level).

The regulation at 10 CFR 100.23(c) requires that geologic and seismic factors be considered

when determining suitability of the site. This regulation also requires an investigation to obtain

geologic and seismic data necessary for evaluating seismically induced floods and water

waves. The regulation is applicable to Section 2.4.6 of RS-002, Attachment 2, because it

requires investigation of distantly and locally generated waves or tsunami that have affected o'

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could affect a proposed site, including available evidence regarding the runup or drawdown

associated with historic tsunami in the same coastal region, as well as local features of coastal

topography that might modify runup or drawdown; RG 1.70 provides more detailed guidance on

the investigation of seismically induced flooding.

To determine whether the applicant met the requirements of 10 CFR Parts 52 and 100, as well

as 10 CFR 100.23, with respect to tsunamis -and the analysis thereof, the staff used the

following specific criteria:

If it has been determined that tsunami estimates are necessary to identify flood or lowwater design bases, the staff will consider the analysis complete if the following areas

are addressed and can be independently and comparably evaluated from the applicant's

submission:

- All potential distant and local tsunami generators, including volcanoes and areas

of potential landslides, are investigated and the most critical ones are selected.

- Conservative values of seismic characteristics (source dimensions, fault

orientation, and vertical displacement) for the tsunami generators selected are

used in the analysis.

- All models used in the analysis are verified or have been previously approved by

the staff. RG 1.125 provides guidance on the use of physical models of wave

protection structures.

- Bathymetric data are provided (or are readily obtainable).

Detailed descriptions of shoreline protection and safety-related facilities are

provided for wave runup and drawdown estimates. RG 1.102 provides guidance

on flood protection for nuclear power plants.

- Ambient water levels, including tides, sea level anomalies, and wind waves, are

estimated using NOAA and Corps of Engineers publications as described below.

- If the applicant adopts Position 2 of RG 1.59, it should show at the COL that the

design basis for tsunami protection of all safety-related facilities identified in

RG 1.29 is adequate in terms of the time necessary for implementation of any

emergency procedures.

* The applicant's estimates of tsunami runup and drawdown levels are acceptable if the

estimates are no more than 5 percent less conservative than the staff's estimates. If the

applicant's estimates are more than 5 percent less conservative (based on the

difference between normal water levels and the maximum runup or drawdown levels)

than the staff's, the applicant should fully document and justify its estimates or accept

the staff's estimates.

* This section of the safety assessment will also be acceptable if it states the criteria used

to determine that tsunami flooding estimates are not necessary to identify the flood

design basis (e.g., the site is not near a large body of water).

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2.4.6.5 Technical Evaluation

During its independent review, the staff found that, in extreme cases along coastal areas, the

shoreline water level has risen to more than 50 ft for a tsunami of distant origin and over 100 ft

for tsunami waves generated near the earthquake's epicenter (NOAA, 2004). However, since

the ESP site is located at an elevation of 735 ft MSL and is at a great distance from the coast

and more than 93 miles from the Great Lakes, the staff concluded that the effects of even the

largest ocean tsunami or a tsunami caused in the Great Lakes would not be high enough to

exceed the elevation of the ESP site.

The staff also considered the potential for flooding along the shores of Clinton Lake near the

ESP siue that could result from a seismically induced hillslope failure. Such a wave would have

the potential to cause a tsunami-like wave, as discussed in RG 1.59. The applicant's response

to RAI 2.4.2-3, however, indicated that the slopes near the ESP site have been stable for the

past 30 years, and that no landslides are documented for DeWitt County.

The updated SSAR Figure 1.2-4 (in response to RAI 2.4.1 -1) displays the location of the

essential safety-related features of the ESP site. All features, except the new intake structures,

are located more than 600 ft from the shores of Clinton Lake at an elevation of 735 ft MSL, or

45 ft above the normal water surface elevation of Clinton Lake. The height of the hillslope

banks directly opposite the ESP site is approximately 40 ft above the surface of the water.

Waves generated from a hillslope failure on these banks would also need to transect the UHSS

pond arid underwater dikes before reaching the ESP site, potentially removing energy from

these waves as they pass over the shallow water zones. The staff therefore concluded that

tsunami-like waves induced by hillslope failure do not pose a risk to the ESP site.

2.4.6.4 Conclusions

As set forth above, the applicant provided sufficient information pertaining to the identification

and evaluation of probable maximum tsunami flooding at the site. SSAR Section 2.4.6

conforms to Section 2.4.6 of RS-002, Attachment 2, with regard to this objective.

Section 2.4.6 of RS-002, Attachment 2, provides that the SSAR should address the

requirements of 10 CFR Parts 52 and 100 as they relate to identifying and evaluating probabl a

maximum tsunami flooding at the site. Although the applicant did not specifically address these

regulations in SSAR Section 2.4.6, the staff concludes that, by conforming to Section 2.4.6 of

RS-002, Attachment 2, it has met the requirements to identify and evaluate tsunami flooding

with respect to 10 CFR 52.17(a) and 10 CFR 100.20(c). Further, the staff finds that the

applicant has considered the most severe natural phenomena that have been historically

reported for the site and surrounding area in establishing the design bases for tsunamis, with

sufficient margin for the limited accuracy, quantity, and period of time in which the historical data

have been accumulated. Therefore, the applicant partially conforms to GDC 2, insofar as thai:

analysis defines design bases related to tsunamis.

2.4.7 Ice Effects

The EGG ESP site is located on the shore of Clinton Lake, approximately 6 miles east of the

city of Clinton in Dewitt County, Illinois. Clinton Lake is an impoundment formed by construction

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of an earthen dam across Salt Creek about 1200 ft downstream from the confluence of the

North Fork of Salt Creek with Salt Creek. The ESP site is located approximately 3.5 miles

northeast of the dam.

The climate of central Illinois is typically continental, with cold winters and frequent short-period

fluctuations in temperature, humidity, cloudiness, and wind direction. Alternating periods of

steady precipitation (rain, freezing rain, sleet, or snow) and clear, crisp cold weather

characterize winter.

2.4.7.1 Technical Information in the Application

The applicant used the USGS streamfrlow data measured at the Rowell gauge to identify ice

formation in streams. The gauge is located approximately 12 miles downstream from the

Clinton Dam. The applicant reported intermittent ice effects during the winter months. An ice

jam recorded on February 11, 1959, resulted in a maximum gauge height of 24.84 ft and a peak

discharge of 7500 cfs. The gauge datum was at elevation 610 ft MSL. The applicant estimated

that a discharge of 7500 cfs corresponds to a gauge height of 22.14 ft and, consequently, the

ice jam raised the water surface by 2.7 ft.

The applicant stated that the wintertime PMP depth in February is 13.8 in., 11.4 in. less than the

48-hour PMP depth for August of 25.2 in. The applicant concluded that the effects of an ice jam

flood in combination with a wintertime PMF on the water surface in Clinton Lake would be less

than that resulting from the summertime PMF.

The applicant estimated the average thickness of the ice sheet that could form on the surface of

Clinton Lake as 10 in., neglecting the heat discharged into the lake during operation of any

station units. The design water level of the UHS is 675 ft MSL, and the inlet to the CPS

screenhouse is at elevation 670 ft MSL. The applicant stated that a water depth of 12.3 ft

above the intake will be available for station operation, even under low-water conditions. The

applicant concluded that the formation of a 1 0-in.-thick ice sheet will not block flow into the CPS

screenhouse.

The applicant stated that low-flow conditions resulting from ice jams on streams upstream of the

ESP site will not affect the UHS because of its submerged conditions. The applicant stated that

the UHS capacity will be maintained.

The applicant stated that the only ESP facility safety-related structure exposed to the ice sheet

formed on the surface of Clinton Lake would be the intake structure. The intake structure would

be similar to, but considerably smaller than, the existing intake structure. The new intake would

be located at the same depth as the existing intake.

The applicant described the possibility of an ice sheet formation on the surface of Clinton Lake

in SSAR Section 2.4.7, but that section did not describe the possibility nor the impact of a

collision of the ice sheet or a breakaway chunk of the ice sheet with the intake structure. The

staff requested, in RAI 2.4.7-1, that the applicant discuss the potential for ice sheet collision

impacts on the intake structure and quantify the force of this impact. In response to RAI 2.4.7-1,

the applicant stated that because a potential for formation of an ice sheet that could affect the

intake structure exists, it will consider ice sheet effects at the COL stage. The applicant revised

SSAR Section 2.4.7 to state that the force resulting from the interaction of a moving ice sheet

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and a structure results from crushing, bending, buckling, splitting, or a combination of these

modes. The total force on the entire structure is important in designing foundations that resist

sliding and overturning. Contact forces over small areas are important for designing the internal

structural members and external skin of the structure.

SSAR section 2.4.7 stated that the expected average thickness of an ice sheet that may form

on the surface of Clinton Lake is 10 in. The staff requested, in RAI 2.4.7-2, that the applicant

explain how it estimated the ice sheet thickness identified in SSAR Section 2.4.7 and provide

the input assumptions for this estimation. In response to RAI 2.4.7-2, the applicant stated that it

calculated the ice thickness using the method described in USACE, EM 1110-2-1612,

"Engineering and Design-Ice Engineering," issued in October 2002. General assumptions in

the applicant's calculation included an ice formation period of November through February arid

little snow accumulation on the ice surface. Since there are no records for freezeup of Clinton

Lake, the applicant determined an approximate date based on observed freezeup dates for

Lake Monona in Madison, Wisconsin, which is of similar size and volume as Clinton Lake and is

located approximately 180 miles north of Clinton Lake. The applicant used air temperature data

from Decatur, Illinois, located 10 miles south of Clinton Lake, to estimate freezing degree-days

for the winter seasons of 1978 through 2003. The applicant used a conservative coefficient of

ice cover (0.8) that assumed a windy lake with no snow cover. The applicant reported a

maximum ice thickness of 22.2 in. and an average thickness of 14.2 in. The applicant will

revise the SSAR to include additional information on ice depth.

SSAR Section 2.4.7 did not provide sufficient detail for the staff to determine the relationship of

the ESF intake structure to the existing CPS intake structure. It was also not possible to

determine the depth of water over the intake during normal and low-water conditions. The staff

requested, in RAI 2.4.7-3, that the applicant describe the relationship, including the layout and

depth, of the ESP intake relative to the current CPS intake. In response to RAI 2.4.7-3, the

applicant stated that the ESP facility intake will be located 65 ft west of the existing CPS plant

intake. *rhe applicant stated that the bottom concrete slab of the CPS intake structure is located

at an elevation of 657.5 ft MSL, and the intake extends from an elevation of 670 ft MSL to an

elevation of 697 ft MSL. The elevation of the bottom of Clinton Lake is 668.5 ft MSL. The

applicant stated that the layout of the ESP facility intake would be similar to the CPS plant

intake. The bottom of the ESP facility intake would be located at an elevation of 670 ft MSL,

and the inlet opening would extend upwards to at least the normal water surface elevation in

Clinton Lake, which is 690 ft MSL. The applicant stated that the basemat of the ESP facility

intake would be located at an approximate elevation of 657.5 ft MSL; the final elevation would

depend on the submergence required by the pumps. The applicant also stated that the ESP

facility intake pumps would be mounted at an approximate elevation of 699 ft MSL, the same

elevation as the CPS intake pumps.

SSAR Section 2.4.7 did not provide sufficient detail regarding formation of frazil and anchor ice

on or near the intake structure. The staff requested, in RAI 2.4.7-4, that the applicant describe

site characteristics for frazil and anchor ice formation. In response to RAI 2.4.7-4, the applicant

revised Chapter 2 of the SSAR and added a new section (Section 2.4.7.1) on frazil ice and

anchor ice. The applicant stated in the new SSAR Section 2.4.7.1 that accumulation of frazil

and anchor ice can cause blockages of intake water systems. This ice accumulates on trash

racks or screens in the intake pathway. Frazil ice has a fine, small, needle-like structure or thin,

flat, circular plates of ice suspended in water. In supercooled water, frazil ice particles can

adhere to form clusters or flocs that can accumulate in trash racks or screens. Frazil ice on the

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surface of supercooled water can form floating ice pans. Frazil ice can also form as hanging

dams on the bottom of a solid ice sheet. Anchor ice is submerged ice attached to the

streambed. Generally, anchor ice forms in shallow, turbulent waters. The applicant stated that

conditions that might lead to formation of frazil or anchor ice could occur in streams that empty

into Clinton Lake but are not expected in the intake structure area. The applicant stated that

when anchor ice breaks loose from the streambed, it flows into Clinton Lake and forms or joins

with the cover ice on the lake. The applicant concluded that this anchor ice would not interfere

with the operation of the ESP facility intake structure.

The applicant stated that the CPS water intake is designed to avoid obstruction from surface ice

and accumulation of frazil ice by circulating waste heat through a warming line back to the inlet

of the screenhouse. This warming line is designed to maintain a minimum water temperature of

40 OF at the intake during winter operation. The applicant stated that the CPS plant has not

experienced operational problems because of frazil ice accumulation in the intake.

The applicant stated that the ESP facility intake would be located in the vicinity of the existing

CPS intake. The applicant stated that a warming line from the hot side of the cooling towers

would be provided to the ESP facility intake to prevent formation of frazil ice at the intake for

NHS cooling tower makeup. The applicant also stated that it would design these features

independently of the existing CPS facility.

SSAR Section 2.4.7 did not provide sufficient information regarding formation of ice in the lake

or near the intake structure during periods when the existing unit is nonoperational, thus

eliminating the heat load to Clinton Lake. The staff requested, in RAI 2.4.7-5, that the applicant

discuss the impacts to ice formation if the existing unit were no longer operating. In response to

RAI 2.4.7-5, the applicant discussed this issue in two new paragraphs that it added to the end of

SSAR Section 2.4.7, as well as in the new SSAR Section 2.4.7.1 provided in response to

RAI 2.4.7-4.

The two new paragraphs that the applicant added to Section 2.4.7 state that no ice formation

currently occurs in the discharge channel when the CPS Unit 1 is operating. The applicant

expected no change to occur with the addition of the proposed ESP facility. The capacity of the

discharge channel is approximately 3058.3 cfs or 1.37 million gpm at a discharge velocity of

1.5 feet per second (fps). The discharge from CPS Unit 1 is approximately 445,000 gpm of

warm cooling water during the winter months. The ESP facility would add a blowdown water

discharge of 12,000 gpm, increasing the discharge in the channel to 457,000 gpm. The

applicant stated that this combined discharge is well within the discharge capacity of the

channel.

The applicant stated that there is some possibility of ice formation on portions of the discharge

channel if only the ESP facility is in operation. Under these circumstances, warm water

discharge to the channel would be significantly reduced, resulting in a lower heat output and a

lower flow velocity, leading to an increased potential for surface ice accumulation, particularly at

locations away from the point of discharge. The applicant stated that the ice accumulation

would be much thinner than the predicted normal lake accumulation because of the heat and

velocity components of the ESP facility discharge. The applicant also stated that, if ice did form,

it would remain on the surface, allowing unrestricted flow below the water surface. The

applicant concluded that it did not expect jamming and clogging of the discharge channel

because of icing.

2-110
SSAR Section 2.4.7 did not provide sufficient detail for the staff to determine if formation of ice

on the lake and near the intake structure could constrain intake depth. The staff requested, in

RAI 2.4.7-6, that the applicant discuss whether ice sheet formation is likely to constrain the ESP

facility UHS intake depth. In response to RAI 2.4.7-6, the applicant stated that ice sheet

formation in Clinton Lake will not constrain the ESP facility's UHS intake depth. The applicant

stated that the thickness of ice cover is a small percentage of the intake height, and warming

water used to prevent formation of frazil ice will retard the formation of an ice cover in the

immediate area of the intake trash racks or screens. The applicant revised SSAR Section 2.4.7

to provide additional information on ice effects related to the ESP facility's UHS intake depth.

SSAR section 2.4.7 provided an average thickness of an ice sheet on the surface of Clinton

Lake. The staff needed to understand if such an ice sheet formation, coupled with a loss of

Clinton Dam and subsequent draining of the main lake, could lead to a loss of capacity of the

submerged UHS pond. The staff requested, in RAI 2.4.7-8, that the applicant describe the

reduction in UHS capacity caused by a loss of Clinton Dam during periods when an ice sheet is

covering the lake. In response to RAI 2.4.7-8, the applicant stated that the UHS for the ESP

facility will consist of cooling towers, if the selected reactor type does not use passive

emergency cooling methods. The applicant stated that Clinton Lake is used as a source of

makeup water for the ESP facility's UHS cooling towers and not as a heat sink. The applicant

stated that if Clinton Dam were to be lost, any surface ice would also be expected to be lost

since it floats on the surface. The applicant also stated that, if this surface ice sheet were to

drop to an elevation equal to the top of the submerged UHS pond, a small decrease in the

capacitir of the submerged UHS pond, which acts as the heat sink for CPS Unit 1, would occur.

The applicant stated that during this condition, additional heat removal capacity would be

available in the submerged UHS pond in the form of latent heat of fusion of ice. The applicant

also stated that adequate water for makeup to the ESP facility's UHS cooling towers would be

available, since the required shutdown of CPS after a dam failure would supply heat to the

submerged UHS pond and convert the ice back into water.

In Revision 2 of the SSAR, the applicant stated that ice thickness calculations were carried out

for the period 1902 through 2001. The applicant reported that the average ice sheet thickness

over this period was 16.2 in. and that the maximum was 27.0 in. during 1977-78 winter. The

applicant used accumulated freezing degree-days (AFDD) data from USACE Engineering

Research and Development Center (ERDC) at the Cold Regions Research and Engineering

Laboratory (CRREL) and the approach as described by ERDC/CRREL Technical Note 04-3.

The applicant used a value of 0.8 for the ice cover condition coefficient. The applicant stated

that the average AFDD was 409.9 with a maximum of 1141.5 (in Fahrenheit degree days) .

The applicant stated in Revision 2 of the SSAR that the openings of ESP intake structure will

extend vertically from the water surface elevation to approximately 669 ft MSL, providing a

vertical opening of about 21 ft when the Clinton Lake water surface elevation is at a normal pool

level of 690 ft MSL. -An ice sheet, equal in thickness to the maximum estimated ice-sheet

thickness of 27.0 in., would potentially block only a small portion of the intake opening, leaving

approximately 18.75 ft of vertical opening for water intake with initial lake water surface

elevation at 690 ft MSL before ice formation, and a vertical opening of 5.75 ft if the initial lake

water surface elevation were at the minimum of 677 ft MSL. The applicant stated that this

vertical opening, combined with a normal horizontal dimension of the opening for an intake

structure, would still be adequate for intake water requirements of the ESP plant.

2-111
The applicant stated in Revision 2 of the SSAR that no ice currently forms in the discharge

channel with the CPS in operation, which discharges about 445,000 gpm of warm cooling water

during winter months-- The -applicant reported that the capacity of the discharge canal at a flow

velocity of 1.5 fps is 1,372,000 gpm, which will not be exceeded with the addition of

approximately 12,000 gpm of warm blowdown water from the proposed ESP facility.

The applicant stated that there is some possibility of ice formation in the discharge channel if

the ESP facility is operated alone and the CPS is off line, since the warm water discharge to the

canal would be reduced to only 12,000 gpm. However, the applicant stated that any such ice

would be thin, remain only on the surface, and not restrict flow in the discharge canal.

In Revision 2 of the SSAR, the applicant included a description of formation of frazil and anchor

ice. The applicant stated that the current CPS facility water intake is designed to avoid

obstruction from surface ice and accumulation of frazil ice by recirculating warm cooling water

via a warming line back into the inlet to the screen house. The applicant noted that the warming

line is designed to maintain a minimum water temperature of 40 F during winter at the intake.

The applicant reported that the CPS has not encountered a problem due to frazil ice

accumulation on intake facilities.

The applicant stated in Revision 2 of the SSAR that a means to prevent the formation of frazil

ice at the intake for essential service water cooling tower make-up would be provided, such as a

warming line from the hot side of the cooling towers back to the intake. The applicant stated

that the design of these features would support the operation of the ESP facility independent of

the CPS facility.

The applicant estimated that approximately 326 ac-ft of liquid water would be displace by a 27.0

in ice sheet settling down on the UHS pond in the event of complete loss of the main dam. The

applicant also estimated that an excess capacity of 395 ac-ft is normally available. Since the

evaporation of water from the pond would be negligible in presence of complete ice cover, the

applicant estimated that the net change would result in essentially the same excess capacity of

liquid water in the UHS pond. If the main dam failure occurs with maximum ice thickness on the

lake and the CPS facility not in operation, the UHS water normally reserved for CPS shutdown

would also be available to the ESP facility. The applicant concluded that the UHS liquid water

capacity is sufficient to support the combined emergency operation of CPS and the ESP

facilities.

2.4.7.2 Regulatory Evaluation

SSAR Table 1.5-1 presents the applicant's conformance to the NRC RGs. The staff requested,

in RAI 1.5-1, that the applicant provide a comprehensive listing of the NRC regulations

applicable to its ESP SSAR. In its response to this RAI, the applicant indicated that RS-002,

Attachment 2, identifies the NRC regulations applicable to its ESP SSAR. RS-002,

Attachment 2, describes the methods of review and the applicable acceptance criteria that the

staff uses to develop its findings and conclusions related to the hydrologic aspects of site

characterization for an ESP. Although the applicant did not indicate how the individual sections

of SSAR Section 2.4 addressed the hydrology-related site suitability criteria in RS-002,

Attachment 2, the staff reviewed this portion of the application for conformance with the

applicable regulations and considered the corresponding regulatory guidance, as identified

below.

2-112
Section 2.4.7 of RS-002, Attachment 2, provides the review guidance used by the staff in

evaluating this SSAR section. Acceptance criteria for this section are based on meeting the

requirements of 10 CFR Parts 52 and 100, as they relate to identifying and evaluating the

hydrologic features of the site. Further, RS-002, Attachment 2, states the following:

Compliance with 10 CFR 52.17(a) and 10 CFR 100.20(c) require that the site's

physical characteristics (including seismology, meteorology, geology, and

hydrology) be taken into account when determining its acceptability for a nuclear

power reactor. To satisfy the hydrologic requirements of 10 CFR Parts 52 and

*100, the SSAR should contain a description of any icing phenomena with the

potential to result in adverse effects to the intake structure or other safety-related

facilities for a nuclear power plant or plants of a specified type (or falling within a

l'PE) that might be constructed on the proposed site. Ice-related characteristics

historically associated with the site and region should be described, and an

analysis should be performed to determine the potential for flooding, low water,

or ice damage to safety-related SSCs. The analysis should be sufficient to

evaluate the site's acceptability and to assess the potential for those

characteristics to influence the design of SSCs important to safety for a nuclear

power plant or plants of a specified type (or falling within a PPE) that might be

constructed on the proposed site. Meeting this guidance provides reasonable

assurance that the effects of potentially severe icing conditions would pose no

undue risk to the type of facility proposed for the site.

In those cases for which a reactor design is not specified, the ESP applicant may instead

provide a PPE to characterize a facility or facilities for comparison with the hydrologic

characteristics of the site. A PPE can be developed for a single type of facility or a group of

candidate facilities by selecting limiting values of relevant parameters. RG 1.59 provides

guidance for developing the hydrometeorologic design basis.

To judge whether the applicant has met the requirements of 10 CFR Parts 52 and 100, as they

relate to ice effects, the staff used the following specific criteria in RS-002, Attachment 2:

Publications of NOAA, USGS, USACE, and other sources are used to identify the history

and potential for ice formation in the region. Historical maximum depths of icing should

be noted, as well as mass and velocity of any large, floating ice bodies. The phrase,

'historical low water ice affected," or similar phrases in streamflow records (USGS and

State publications) will alert the reviewer to the potential for ice effects. The applicant

shlould consider and evaluate if the following items are necessary:

- The regional ice and ice jam formation history should be described to enable an

independent determination of the need for including ice effects in the design

basis.

- If the potential for icing is severe, based on regional icing history, it should be

shown that water supplies capable of meeting safety-related needs are available

from under the ice formations postulated and that safety-related equipment could

be protected from icing as in the second item above. If this cannot be shown, it

should be demonstrated that alternate sources of water that could be protected

2-113
from freezing are available and that the alternate source would be capable of

meeting safety-related requirements in such situations.

- If floating ice is prevalent, based on regional icing history, potential impact forces

on safety-related intakes should be considered. The dynamic loading caused by

floating ice should be included in the structural design basis. (This item is to be

addressed at the COL or CP stage.)

- If ice blockage of the river or estuary is possible, the applicant should

demonstrate that the resulting water level in the vicinity of the site has been

considered. If this water level would adversely affect the intake structure, or

other safety-related facilities of a nuclear power plant(s) of a specified type (or

falling within a PPE) that might be constructed on the proposed site, it should be

demonstrated that an alternate safety-related water supply would not also be

adversely affected.

The applicant's estimates of potential ice flooding or low flows are acceptable if the

estimates are no more than 5 percent less conservative than the staff estimates. If the

applicant's estimates are more than 5 percent less conservative than the staff's, the

applicant should fully document and justify its estimates or accept the staff estimates.

2.4.7.3 Technical Evaluation

The applicant reported an ice jam on Salt Creek at Rowell that formed on February 11, 1959.

The staff searched the USACE historical Ice Jam Database and found two reported ice jams on

Salt Creek near Rowell. One of these jams was the February 11, 1959, ice jam the applicant

reported. This ice jam resulted in a maximum gauge height of 24.84 ft. The staff found that the

mean daily discharge in Salt Creek near Rowell on this day was 6800 cfs and the peak

discharge was 7500 cfs, according to the USGS streamflow observations in the NWISWeb Data

for the Nation Web site. The other ice jam was reported on January 8, 1996. This ice jam

resulted in low-water conditions on January 8 and 9, with a daily mean discharge of 8.5 cfs.

Examination of daily streamflow records at Rowell shows a decrease in daily mean discharge

from 13 cfs on January 1 to a low of 8.5 cfs on January 8 and 9, and a return to 13 cfs on

January 16,1996.

The staff prepared a stage-discharge relationship from available gauge heights for peak

streamf low at the Rowell gauge using data from the period before the construction of Clinton

Dam. Figure 2.4-12 of this SER shows this stage-discharge relationship. Using this

relationship, the staff estimated a stage of 22.8 ft corresponding to a discharge of 7500 cfs, and

an ice-jam-induced stage increase of 2.0 ft. If an ice-jam-induced flood were to augment the

PMF, the maximum expected water surface elevation in Clinton Lake would be 718.5 ft MSL.

The staff estimated the all-season PMP depth for Clinton Lake's drainage area in Section 2.4.3

of this SER using HMRs 51 and 52 and ANSI/ANS-2.8-1992. The 48-hour PMP depth was

26.8 in. and the 72-hour PMP depth was 28.7 in. The National Weather Service's current HMRs

do not provide a method to estimate a monthly PMP for areas exceeding 10 mi2. Methods for

estimating a monthly PMP appear in HMR 33, but the current HMRs (i.e., HMRs 51 and 52)

supersede that report. The staff independently confirmed that the 48-hour winter PMP depth is

less than the all-season 48-hour PMP depth. The staff's estimate of the all-season PMP using

2-114
the current HMRs is greater than the applicant's winter and all-season PMP. The staff

concluded that a flood generated by a winter PMP and augmented by an ice-jam flood would be

less critical than the all-season PMF.

Stage-Discharge Relationship for Salt Creek at Rowell, IL

C1

tn

CN

.-~

U

0

0

CD

:0

U*)

0:

0o

0

0

CD

CD

U')

01

15 17.5 20 22.5 25 27.5 30

Gage Heigh (ft)

Figure 2.4-12 Stage-discharge relationship for Salt Creek at Rowell, IL

The staff independently estimated the likely surface ice thickness that might form near the

intake structures. During this estimation, the staff used mean daily air temperatures recorded at

the Decatur, Illinois, meteorologic station. Maximum and minimum daily air temperatures at this

station are available for water years 1902 to 1999. The staff estimated cumulative degree-days

starting December 1 through May 31 for each water year. The most severe cumulative degreEdays below freezing occurred in water year 1978 (see Figure 2.4-13 of this SER).

The maximum accumulated degree-days below freezing during'the period of December 1, 1976,

to May 31, 1977, was 1086.5 OF, as shown in Figure 2.4-13. The staff used Assur's method

(Chow, 1964) to estimate a maximum ice thickness of 31.4 in. The staff determined that it is

possible for an ice sheet to form for extended periods in Clinton Lake.

2-115
Water Year 1978

-, I,

CD

CD

a)

Dec1 Jan 1 Feb 1 Mar 1 Apr1 May 1 Jun 1

Figure 2.4-13 Accumulated degree-days since December 1, 1977, at the Decatur

meteorologic station

SSAR Section 2.4.7 did not describe the possibility and potential impact of a collision of th e 'ice

sheet or a breakaway chunk of the ice sheet with the intake structure. The staff needed to

evaluate the possibility of any limitations on the performance of safety-related intakes

subsequent to such an impact. In RAI 2.4.7-1, the staff requested that the applicant discuss this

potential collision and its impact on the ESP facility intake structure. In response to RAI 2.4.7-1,

the applicant stated that a potential exists for an ice sheet to affect the intake structure, and the

COL applicant would consider these effects at the COL stage. Since the ESP facility intake

structure is safety related and the potential for ice formation is a site-induced condition, the COL

applicant would need to demonstrate that the intake structure can withstand the effects of any

ice sheet crushing, bending, buckling, splitting, or a combination of these modes. This is COL

Action Item 2.4-5. The staff had planned to include this issue as DSER Permit Condition 2.4-5.

The staff had also planned to specify attributes of the ice sheet, such as its thickness, mass,

and velocity, that the applicant should use for design of the ESP facility's UHS intake structures.

The staff established maximum ice thickness based on its review of applicant's response to

DSER Open Item 2.4-9 (see below). However, the need for a UHS intake structure will depend

on whether the selected reactor type requires a UHS. The staff determined that COL Action

Item 2.4-5 is sufficient to ensure the safety of the ESP facility's UHS intake structures, if the

selected reactor design requires a UHS and concluded that it is not necessary to impose DSER

Permit Condition 2.4-5.

2-116
SSAR Section 2.4.7 did not provide sufficient details about the estimation of ice sheet thickness.

In RAI 2.4.7-2, the staff requested that the applicant provide details of the ice sheet thickness

estima ion, including the input assumptions for the method employed. The staff performed ius

own independent estimation of the thickness of an ice sheet that may form on the surface of

Clinton Lake. The staff used air temperature data from the Decatur meteorologic station as

described above. The staff's estimate of ice sheet thickness was significantly greater than that

of the applicant's. Therefore, the staff determined that the applicant needed to provide more

details regarding the method and air temperature dataset it used in estimating the thickness of

an ice sheet that may form on the surface of Clinton Lake. The staff also asked the applicant to

demonstrate that the ice thickness estimate is adequate. This was DSER Open Item 2.4-9.

In response to DSER Open Item 2.4-9, the applicant stated, in its submission to the NRC daled

April 26, 2005, that it obtained additional data, evaluated the differences between its and the

staff's methods, and revised its estimate of ice thickness in Clinton Lake. The applicant

presented the air temperature data and the method used for estimating the ice thickness in

Clinton Lake in an attachment to its response.

The applicant stated that the above described evaluation established an expected maximum ice

thickness of 24.8 in. for Clinton Lake, which should be used for determining the water available

in the submerged UHS pond. The applicant stated that it based its estimation of expected

maximum ice thickness on worst-case available air temperature data from the Decatur

meteorologic station, which resulted in an estimated 1065 OF accumulated freezing degreedays. The applicant used procedures described in USACE EM1110-2-1612 (this document is

also referred to as USACE (2002)) to estimate ice thickness as a function of estimated

accumulated freezing degree-days. The applicant estimated the onset of ice layer formation in

Clinton Lake based on observed freezing in another lake located approximately 180 miles north

of Clinton Lake. The applicant disagreed with the staff's method for setting the onset of ice

layer formation (the onset date affected the estimation of accumulated freezing degree-days)

and the actual relationship used to estimate the ice thickness (the applicant claimed that the

relationship used by the staff in the DSER did not consider recent advances in ice thickness

estimation relationships).

The staff reviewed the applicant's response to DSER Open Item 2.4-9, including the additional

data presented by the applicant and the details of the methods employed by the applicant for

estimating ice thickness in Clinton Lake. The staff determined that the applicant used the same

data as the staff had in preparing the DSER, except for the slightly longer duration of the

dataset. The staff used air temperature collected at the Decatur meteorologic station for water

years 1902-1999, and the applicant used air temperature data for all winters from 1896-2003.

The longer dataset used by the applicant did not change the worst winter year (in terms of

accumulated freezing degree-days) from that determined by the staff in its previous

assessment.

The staff determined that there are two major differences in the revised ice-thickness procedure

presented by the applicant in its response to DSER Open Item 2.4-9 as compared to the staff's

previous procedure used in the DSER. The first difference is that the applicant used the

estimation equation in USACE (2002), whereas the staff used Assur's 1956 equation in its

DSER review. The second difference is that the applicant estimated the maximum accumulal:ed

freezing degree-days starting from an estimated freezeup onset date, whereas the staff used a

2-117
fixed December 1 freezeup date in its DSER review. These two differences are discussed in

detail below.

Ice Thickness Estimation Equation

Assur's ice-thickness estimation equation, which the staff used in the DSER, was published in

1956. The USACE (2002) estimation equation is more recent than Assur's estimation equation,

although both equations estimate an ice thickness that is proportional to the square root of

accumulated freezing degree-days. The difference between the two methods arises from the

use of different coefficients of proportionality. Assur's equation applies a constant of

proportionality of (1.06 x a), with different values for a recommended for ice sheets covered

with moderate snow (a ranging from 0.65 to 0.75) and for ice sheets not covered with snow (a

ranging from 0.85 to 0.9). Assur suggested a theoretical maximum value of 1.0 for a. The

USACE (2002) equation applies a constant of proportionality a, only. The recommended value

of a under windy, snow-free lake conditions is 0.8 and that under average lake conditions, in the

presence of a snow cover, ranges from 0.5 to 0.7. Assur's equation is more conservative than

the USACE (2002) equation because of the differences in the recommended values of a and

the presence of 1.06 multiplier in Assur's equation. The staff used the most conservative a

(equal to 0.9) recommended by Assur in the DSER review, which implies an ice sheet not

covered with snow. For similar conditions, USACE (2002) recommends a maximum a of 0.8.

Therefore, use of Assur's equation would yield an ice thickness 19 percent larger than that

derived from the USACE (2002) equation for the same accumulated freezing degree-days.

The applicant stated in its response to DSER Open Item 2.4-9 that the USACE (2002) equation

was more accurate because it was a refinement on the earlier method based on additional

study. The staff's review of USACE (2002) did not provide any substantiation of this statement.

The applicant did not provide any other reference that describes this refinement to enable the

staff to assess the accuracy of the USACE (2002) equation in relation to Assur's equation. The

applicant also stated that both ice-thickness estimation equations likely overestimate the ice

thickness, but did not provide any references to substantiate this statement.

The staff contacted researchers at the USACE CRREL to determine the currently accepted

standard for estimating ice thickness. Based on email communication with CRREL, the staff

determined that USACE (2002) is the currently accepted standard for design ice engineering.

Based on the above review, the staff determined that the USACE (2002) equation is acceptable

for estimating the ice thickness in Clinton Lake and other safety-related water storage

reservoirs, should any be required by the selected ESP plant reactor type.

USACE (2002) states that a differential equation describing the rate of thermal growth of an ice

cover can be written based on several assumptions. These assumptions are (USACE, 2002):

1. Ice forms in a homogeneous, horizontal layer,

2. Ice grows only at its horizontal interface with water,

3. The thermal conditions in the ice layer are quasi-steady,

4. The heat flux from the water is negligible,

5. The heat flux is only in the vertical direction, and

6. The heat loss from the surface of the ice layer to the atmosphere is a linear function of the

temperature difference between the surface of the ice layer and the air.

2-118
The first five assumptions above are appropriate for an ice cover formation on a lake surface

when the horizontal extent of the ice cover is large compared to its thickness, and the lake is not

very deep. The sixth assumption may be inaccurate at the beginning of ice formation when the

ice cover is very thin.

The rate of thermal growth of ice can be expressed as

dh 1 (T.- T,)

dt PA( h 1J

ki + i

where h is ice thichness, t is time, Tm is temperature at ice and water interface, Ta is air

temperature, k1 is thermal conductivity of ice, Ha is heat transfer coefficient from the surface of

the ice lo the atmosphere, p is density of ice, and A is latent heat of ice. The nonlinear

differential equation above can be solved (USACE 2002) to yield

h = V(B+hk)2+ 2A(Uj -Uk)- B

where hi, is calculated ice thickness on fth day, hk is ice thickness on kth day, either observed or

calculated with j> k,

k. kJ k

A= B H Uj= (Tm. Tji),andUk =E (T. Ta-)*

U, and LI. are accumulated freezing degree-days between onset of freezeup and days jand k,

respectively, with Uj > U., and Ta, is air temperature on Rth day. If heat conduction through the

ice cover is the controlling rate in overall energy flux (i.e., k, << Hb), B can be ignored.

Additionally, if initial ice thickness is assumed to be zero (i.e., Uk = 0), then ice thickness on fth

day is

hi = ore

where

a= '.

Maximurn Accumulated Freezing Degree-Days

The applicant used accumulated freezing degree-days in the USACE (2002) ice-thickness

estimation equation based on the most severe winter on record at Decatur, Illinois. The staff

2-119
used this same winter in its DSER estimation of ice thickness for Clinton Lake. However, the

applicant's estimate of accumulated freezing degree-days is 963 'F, as compared to the staff's

DSER estimate of 1086.5 OF; the applicant's estimate is, 11.4 percent lower than the staff's

DSER estimate.

The staff's review of the applicant's method for estimating accumulated freezing degree-days

during winter revealed that the difference between the applicant and the staff's estimate arises

mainly from the difference between the onset of freezeup determined by the applicant and that

previously assumed by the staff. The applicant presented data for observed freezeup of

Monona Lake, which is located approximately 180 miles north of Clinton Lake near Madison,

Wisconsin. The Wisconsin State Climatology Office has maintained freezeup dates for Monona

Lake since 1851. The applicant analyzed accumulated freezing degree-days and

corresponding observed freezeup dates for Monona Lake for the winters from 1896 through

2003, and concluded that accumulated freezing degree-days ranging from a low of 80 OF to a

high of 406 OF are required for Monona Lake to reach freezeup. The applicant argued that

freezeup in Clinton Lake would be similar to that in Monona Lake, even though the two lakes

have different average depths (15 ft for Clinton Lake as compared to 27 ft for Monona Lake).

For the winter of 1977-78, the applicant estimated a freezeup date of December 27 for Clinton

Lake, assuming that approximately the same number of accumulated freezing degree-days

would be required for freezeup to occur for both lakes. The applicant estimated cumulative

positive freezing degree-days from November 1 through the day before the observed freezeup

date at Monona Lake and assumed that the date of freezeup at Clinton Lake would be the day

with the same or nearly the same cumulative positive freezing degree-days. Based on this

assumption, the applicant-estimated maximum accumulated freezing degree-days during the

winter of 1977-78 is 963 OF, a reduction of 11.4 percent from the staff's DSER estimate of

1086.5 OF.

The staff contacted the Wisconsin State Climatology Office and talked to Dr. Edward Hopkins,

the Assistant State Climatologist. Based on this conversation, the staff determined that lake

freezeup data for the United States can be obtained from the National Snow and Ice Data

Center located in Boulder, Colorado. The Wisconsin State Climatology Office has done some

characterization of the extensive freezeup and ice observation it carries out and maintains for

some of the Wisconsin lakes, including Monona Lake. According to this characterization (see

httD://www.aos.wisc.edu/%/o7Esco/lakesficesumO5.html), the median freezeup date for Monona

Lake is December 15. The earliest Monona Lake froze was on November 22, 1880. The latest

freezeup date was January 30,1932.

During the conversation with Dr. Hopkins, the staff also became aware of a power plant that

discharges warm water, run through its condenser, into Monona Lake. The staff's further

investigation revealed that Madison Gas and Electric owns and operates Blount Station,

which was constructed in 1902 with a maximum generating capacity of 200 megawatts (MW)

(see httD://www.mue.com/aboutlelectric/blount.htm). Although more details of the Blount

Station discharge are not available, the staff concluded that Monona Lake is not an appropriate

lake to compare to Clinton Lake in terms of freezeup for two reasons. First, the warm water

discharged from Blount Station into Monona Lake has some influence on its freezeup dates,

particularly since 1902, affecting any estimation of freezeup dates under natural conditions

using the observed freezeup of Monona Lake since 1902. An inspection of the time series

of duration of ice cover (created by the Wisconsin State Climatology Office) on Monona Lake

for the winters from 1851 to 2005 revealed a significant drop in the duration of ice cover

2-120
immediately after construction of the Blount Station in 1902 (see

http://www.aos.wisc.edu/%7Esco/lakes/monona-dur.aif), reflecting the effect of the power plant

discharge on the freezing characteristics of the lake. Second, Monona Lake is significantly

deeper (27 ft) than Clinton Lake (15 ft). Based on these reasons, the staff determined that the

applicant's conclusion that Clinton Lake's freezeup is similar to that of Monona Lake is not

appropriate.

The staff obtained freezeup data for lakes in the vicinity of Clinton Lake from the National Snow

and Ice Data Center, but could not locate a lake with characteristics similar to those of Clinton

Lake for an independent verification of the freezeup dates the applicant used in its analysis.

Based on the characteristics of Monona Lake, accounting for the fact that its freezeup in winier

is affecl:ed by discharge form Blount Station, the staff determined that it is not overly

conservative to assume a freezeup date of December 1 for Clinton Lake. In years not affected

by the E~lount Station discharge, Monona Lake froze as early as November 22.

Based on the above review, the staff determined that ice thickness in Clinton Lake should be

determined using a conservative freezeup date of December 1 and the USACE (2002)

estimation equation. The staff's revised its estimate of maximum ice thickness in Clinton Lake

to 26.4 in. as shown below.

h. =a r * = 0.8 x 06 = 26.4 in

Based cn the above review, the staff had planned to include a maximum ice thickness of

26.4 in. as a site characteristic in any ESP that may be issued for this site.

Subsequent to discussions with the applicant over concerns that December 1 may be too

conservative (i.e., early in the winter season) for initiation of freeze-up, the staff reviewed

USACE technical note ERDC/CRREL TN-04-3, "Methods to estimate River Ice Thickness

Based on Meteorological Data" by K.D. White. This technical note recommends that freezing

degree clays (FDD) and AFDD be calculated starting October 1 of each water year. The

technical note mentions that AFDD do not begin accumulating until the first sustained period of

cold temperatures, and that the "zero AFDD" point be assigned to a day in late fall or early

winter when the AFDD curve goes from a negative to a consistently positive slope.

The stafi obtained AFDD data from ERDC located in Hanover, New Hampshire. ERDC

calculated AFDD data based on mean daily air temperature recorded at the National Weather

Service cstation in Decatur, Illinois, for water years 1902 to 2000. According to USACE (E-mail

correspondence between Rajiv Prasad and Carrie M. Vuyovich), AFDD on any day of the winter

season, AFDDn, represents the accumulated difference between freezing and the average daily

temperature for the previous n days. The accumulation process starts each fall before the

average daily temperature has fallen below freezing. ERDC starts calculation of AFDD on

August 1 of each year and the calculation ends July 31 of the following year. AFDD graph

through et winter can show multiple peaks. Early in the winter, AFDD graph can also fall to zero

during warm spells.

The staff extracted the "zero AFDD" date for each water year during 1902-2000 corresponding

to maximim AFDD values. The uzero AFDD" date corresponding to maximum AFDD for water

years on record varied from November 16 to March 5, with 14 percent falling in November,

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60 percent in December, 21 percent in January, four percent in February, and one percent in

March. Fifteen percent of "zero AFDD" dates preceded December 1. The staff determined that

winter of water-yearl 978 (calendar-years -1 977-1978) was the coldest on record with a

maximum AFDD of 1141.5 'F (Figure 2.4-14 below). The 'zero AFDD' day for this year was

November 25,1977. The maximum AFDD occurred on March 10, 1978. The staff revised their

estimate of maximum ice thickness in Clinton Lake to 27.0 in as shown below.

hi = a(- NATFD = 0.8x 4 = 27.0 in

Water Year 1978

CDCD1

C.,'

0

C)

C)

C

ay

IV

P

a}

Ea

E

C.)

0~

C)

CO

CD

C)

0)

C)

CN.

0~

Od 1 Nov 1 Dec 1 -Jan 1 Feb I Mar l Apr 1 May I Jun I

Figure 2.4-14 AFDD during 1977-78 as calculated by Engineering Research and

Development Center, Hanover, New Hampshire.

The applicant revised its ice thickness estimation and described the revisions to the application

in a letter dated December 21, 2005, to the NRC. The applicant stated that ice thickness was

estimated for the Clinton Lake during the period 1902-2001. The applicant obtained AFDD data

for Decatur, Illinois, from the ERDC and revised its estimation of ice thickness using the

procedure described in the USACE Engineering and Design-Ice Engineering Manual

(EM 1 10-2-1612) and USACE technical note ERDC/CRREL TN-04-3. The applicant used a

value of 0.8 for the coefficient of ice cover condition (a in the equation above). The applicant

reported that the mean ice thickness estimated over the period 1902-2001 is 16.2 in. with a

maximum ice thickness of 27.0 in. during the 1977-78 winter.

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The applicant stated further that the only ESP structure exposed to ice in Clinton Lake is the

new ESIP intake structure, which will be similar to, but smaller than the existing CPS intake

structure. The intake openings of the ESP intake structure are expected to vertically extend

from an elevation of 690 ft MSL, the normal water surface elevation in Clinton Lake, to 669 ft

MSL providing an opening of approximately 21 ft within the lake. The applicant stated that the

maximum estimated ice thickness of 27 in. (2.25 ft) would only block a relatively small portion of

the total ESP intake opening with 18.75 ft of the opening still available for inflow. The applicant

stated that if the water surface elevation in Clinton Lake falls to its minimum elevation of 677 ft

MSL, tile height of the intake opening will reduce to 5.75 ft, which, the applicant stated, is more

than adequate to maintain required inflow for the ESP facility intake. These design issues will

be reviewed by the staff at the COL stage according to existing NRC regulations and regulatory

guidance.

The applicant also stated that the final intake structure design will include effects of applicable

ice forces on the intake structure including those related to crushing, bending, buckling, splitting,

or a combination of these. The applicant stated that the total force on the entire structure is

important for the design of foundations to resist sliding and overturning, and local contact forces

are important in the design of internal intake structural members and the external skin of the

intake structure. As stated above, the design issues will be reviewed by staff at the COL stage

according to existing NRC regulations and regulatory guidance.

Based on the above review, the staff proposes to include a maximum ice thickness of 27 in. as

a site characteristic in any ESP that may be issued for this site. Therefore, the staff consider;

Open Item 2.4-9 resolved.

SSAR section 2.4.7 did not provide sufficient detail for the staff to determine the relationship of

the ESP facility's intake structure to the existing CPS intake structure and the depth of water

over the intake during normal and low-water conditions. The staff needed this information to

evaluate the performance limitations of the intakes during icy or low-water conditions. In

RAI 2.4.7-3, the staff requested that the applicant describe the relationship, including its layout

and depth, of the ESP facility's intake relative to the current CPS intake. The applicant's

response to RAI 2.4.7-3 did not resolve the staff's concern about the precise layout of the ESP

facility's intake structure. According to Figure 5.3-1 in the EGC ESP environmental report (ER),

the ESP facility's UHS intake would be located at an elevation of 668 ft MSL, which is below the

lake bottom mentioned in the RAI response. The staff needed the bounding dimensions and

critical elevations of the ESP facility's intake structure, including its conceptual plan and cross

section, clearly indicating the elevation of the basemat, the elevation of the screenhouse

opening, the elevation of the NHS makeup water intake pipe, the elevation of the UHS makeup

water intake pipe, and their relationship to the existing lake bed. The staff asked the applicant

to provide a schematic diagram clearly showing these items. This was DSER Open

Item 2.4-10.

In response to DSER Open Item 2.4-10, the applicant stated, in its submission to the NRC

dated April 4, 2005, that the EGC ESP ER Figure 5.3-1 is a cross section of Clinton Lake

looking away from the CPS intake; the 668 ft MSL elevation refers to the lake and not the plant

intake structure. The applicant stated that the design of the ESP intake structure will depend

upon the reactor selected for the ESP facility and, therefore, no schematic diagrams of the

intake structure are available at the ESP stage. The applicant noted that SSAR Section 2.4.7

provides the approximate elevation of the screenhouse openings and mentions that the ESP

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intake structure will be similar to the existing CPS intake structure except that it will be smaller.

The intake opening(s) to the ESP intake structure will extend vertically from an elevation of

690 ft MSL or higher to -approximately 669 ft MSL. The applicant stated that the basemat of the

ESP intake structure is expected to be located similarly to that of the CPS intake structure,

which is located at an elevation of 657.5 ft MSL. The final design elevation of the ESP intake

basemat will depend on the submergence requirements of the ESP UHS makeup water pumps.

The applicant also stated that there will be no intake pipe since vertical intake pumps will be

located in suction bays behind the intake screens. The applicant stated that the lake bottom at

the intake is at an elevation of 668.5 ft MSL.

The staff's concern in DSER Open Item 2.4-10 was to verify that the ESP UHS makeup pumps

will have sufficient submergence within the intake structure to ensure that no interference is

caused by any ice sheet that may form on the surface of Clinton Lake during low-water

conditions in the lake. The staff reviewed the applicant's response to DSER Open Item 2.4-10

and concluded that sufficient design details of the ESP UHS makeup water pumps are not

available at the ESP stage to justify a schematic diagram of the proposed ESP intake structure.

The staff will evaluate the design of the ESP intake structure at the COL stage in accordance

with NRC regulations and regulatory guidance to ensure the safety of the ESP facility. Based

on this review, the staff considers DSER Open Item 2.4-10 resolved (see COL Action

Item 2.4-7).

SSAR Section 2.4.7 did not provide sufficient detail regarding formation of frazil and anchor ice

on or near the intake structure. The staff needed this information to assess the adequacy of the

intake structure during prolonged cold conditions. In RAI 2.4.7-4, the staff requested that the

applicant describe site characteristics for frazil and anchor ice formation. In response to

RAI 2.4.7-4, the applicant described a warming line that is used to maintain a minimum water

temperature of 40 'F in the CPS intake and suggested a similar approach for the ESP facility.

Based on the applicant's proposed approach, the COL applicant will have to design the ESP

facility's UHS intake to maintain a minimum water temperature of 40 OF at all times to preclude

formation of frazil and anchor ice on the intake inlet. This is COL Action Item 2.4-6. The staff

planned to include this item as DSER Permit Condition 2.4-6. However, the need for an ESP

facility UHS intake structure is dependent on whether the selected reactor design requires a

UHS. Since the reactor design has not been selected at the ESP stage, the staff determined

that COL Action Item 2.4-6 is sufficient to preclude the formation of frazil and anchor ice on the

ESP facility's UHS intake inlet, should the selected reactor design require one. The staff

concluded, therefore, that it is not necessary to impose DSER Permit Condition 2.4-6.

SSAR Section 2.4.7 did not provide sufficient information regarding formation of ice in the lake

or near the intake structure during periods when the existing unit is nonoperational, thus

eliminating the heat load to Clinton Lake. In RAI 2.4.7-5, the staff requested that the applicant

discuss the impacts to ice formation if the existing unit were no longer operating. The staff

determined that the applicant's response to RAI 2.4.7-5 was inadequate for two reasons. First,

the applicant did not discuss the impact of ice formation when CPS Unit 1 was no longer

operating. Second, the staff was concerned with ice formation in Clinton Lake and not in the

discharge channel. COL Action Item 2.4-6 will ensure that the minimum intake water

temperature is 40 'F at all times and, in the event that CPS Unit 1 is no longer in operation, the

ESP facility would be shut down when the intake water temperature fell below 40 'F.

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SSAR Section 2.4.7 did not provide sufficient detail for the staff to determine whether the

formation of ice on the lake and near the intake structure could constrain intake depth. The staff

needed this information to evaluate the adequacy of safety-related intakes. In RAI 2.4.7-6, the

staff requested that the applicant discuss whether ice sheet formation is likely to constrain the

ESP facility's UHS intake depth. Based on a minimum safe ESP facility shutdown water surface

elevation of 677 ft MSL, reduced by the staff-estimated maximum ice sheet thickness of

31.4 in., the staff determined that the ESP facility's UHS intake needs to be located below an.

elevation of 674.4 ft MSL. According to ER Figure 5.3-1, the ESP facility's UHS intake would be

located at an elevation of 668 ft MSL. The staff concluded that the ice sheet formed on Clinton

Lake would not constrain the intake. This is predicated on the location of the ESP facility's UHS

intake at an elevation of 668 ft MSL. This is COL Action Item 2.4-7. The staff had planned to

include this item as DSER Permit Condition 2.4-7. However, the need for an ESP facility UHS

intake structure depends on whether the selected reactor design requires a UHS. Since the

reactor design has not been selected at the ESP stage, the staff determined that COL

Action Item 2.4-7 is sufficient to ensure that the ESP facility's UHS intake will be located at an

elevation of 668 ft MSL. The staff concluded, therefore, that it is not necessary to impose

DSER Permit Condition 2.4-7.

SSAR section 2.4.7 provided an average thickness of an ice sheet on the surface of Clinton

Lake. lI: is possible that some loss in capacity of the submerged UHS pond could occur if such

an ice sheet formation were coincident with a loss of Clinton Dam, thus resulting in the draining

of the rriain lake. In RAI 2.4.7-8, the staff requested that the applicant describe the reduction in

submerged UHS pond capacity caused by a loss of Clinton Dam coincident with an ice sheet

covering the lake. The applicant's RAI response that surface ice on the submerged UHS pond

would float away in the event of a complete loss of Clinton Dam is not a conservative

assumption. The staff determined that it is conservative to assume that surface ice could

remain in the submerged UHS pond upon the loss of Clinton Dam, leading to reduced water

storage capacity in the submerged UHS pond. Similarly, the applicant's RAI response that a

drop of surface ice below the top of the submerged UHS dam upon loss of Clinton Dam would

lead to a small reduction in capacity in the submerged UHS pond is not a conservative

assumption. The applicant did not quantify this loss of capacity in the submerged UHS pond, as

originally requested in RAI 2.4.7-8.

The applicant's response to RAI 2.4.7-8 is neither consistent nor conservative for several

additional reasons. The applicant stated that Clinton Lake would be used as a source of

makeup water for the ESP facility's UHS, and not as a heat sink. However, in its response to ihe

RAI, the applicant took credit for heat of fusion of ice available for heat removal, even though it

argued that most of the surface ice would float away and be lost. The staff agrees with the

applicant that the submerged UHS pond should not be considered a heat sink for the ESP

facility UHS. The staff disagreed, therefore, that heat of fusion of ice is available for cooling

needs.

The stafi determined that the applicant should quantify the reduction in water storage capacity

of the submerged UHS pond in the event of a complete loss of Clinton Dam coincident with the

presence of surface ice. This was DSER Open Item 2.4-11.

In response to DSER Open Item 2.4-11, the applicant stated, in its submission to the NRC

dated April 26, 2005, that the amount of water displaced by the settling of an ice sheet into the

submerged UHS pond following a catastrophic failure of Clinton Dam, while an ice sheet was

2-125
already present on the surface of Clinton Lake, would be approximately 300 ac-ft. The

applicant estimated this displacement using the top surface area of 158 ac for the submerged

UHS pond multiplied by ad'ice'sheet thickness of 24.8 in. and then accounting for the ratio of

the density of ice to the density of water, which is 0.917 (158 ac x 24.8 in. / 12 in./ft x 0.917 =

299.4 ac-ft).

The applicant stated that its previous assumption that the ice would float away in the event that

Clinton Dam broke was based on the scenario with both the CPS and the ESP facility operating.

The applicant stated that excess capacity in the submerged UHS pond is greater with the ice

sheet covering the surface than without the ice sheet because the ice cover would restrict

evaporation from the submerged UHS pond to a negligible amount. The applicant stated that

excess volume in the submerged UHS pond corresponding to both ice-covered and open-water

scenarios is provided in response to DSER Open Items 2.4-14 and 2.4-16.

The applicant also stated that if complete failure of the Clinton Dam were to take place while an

ice sheet was covering the submerged UHS pond, but CPS was not operating, then the volume

usually reserved for the CPS UHS cooling requirements (approximately 327 ac-ft over 30 days)

would also be available to the ESP facility's UHS makeup (approximately 87 ac-ft over 30 days)

and would be sufficient to meet the ESP facility's UHS requirements.

The staff reviewed the applicant's response to DSER Open Item 2.4-11 and concluded that it

provided enough information to quantify a reduction in water storage capacity of the submerged

UHS pond resulting from the presence of surface ice in Clinton Lake. Based on the staff's

revised estimate of maximum ice thickness (see the discussion above related to DSER Open

Item 2.4-9) in Clinton Lake, the staff estimated that the volume of displaced liquid water caused

by this ice sheet settling into the submerged UHS pond is approximately 326 ac-ft (158 ac x

27.0 in / 12 in/ft x 0.917 = 326.0 ac-ft). The staff also used the information provided by the

applicant in response to Open Item 2.4-11 to help resolve other open items related to the

submerged UHS pond water storage capacity.

In a letter dated December 21, 2005, the applicant revised its maximum ice thickness estimate

to 27.0 in. The applicant also revised its earlier response to Open Item 2.4-11 in this letter and

revised its estimate of reduction in the storage capacity within the submerged UHS pond in

presence of surface ice. The applicant stated that the reduction of storage capacity in the

submerged UHS pond due to an ice sheet 27.0 in. in thickness will be approximately 326 ac-ft.

Based on applicant's revised response to Open Item 2.4-11, the staff determined that

applicant's revised ice thickness is identical to the staff's independent estimate. Therefore, the

staff considers Open Item 2.4-11 resolved.

2.4.7.4 Conclusions

As set forth above, the applicant provided sufficient information pertaining to the identification

and evaluation of ice effects at the site. SSAR Section 2.4.7 conforms to Section 2.4.7 of

RS-002, Attachment 2, with regard to this objective.

Section 2.4.7 of RS-002, Attachment 2, provides that the SSAR should address the

requirements of 10 CFR Parts 52 and 100 as they relate to identifying and evaluating ice effects

at the site. Although the applicant did not specifically address the above regulations in SSAR

Section 2.4.7, the staff concludes that by conforming to RS-002, Attachment 2, Section 2.4.7, it

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has met the requirements to identify and evaluate ice effects at the site with respect to 10 CFR

52.17(a) and 10 CFR 100.20(c), except as noted in Section 2.4.7.3 above. Further, with the

exceptions noted, the applicant considered the most severe natural phenomena that have been

historically reported for the site and surrounding area in establishing design-basis information

pertaini.ig to ice effects, with sufficient margin for the limited accuracy, quantity, and period o1

time in which the historical data have been accumulated.

2.4.8 Cooling Water Canals and Reservoirs

Clinton Lake, an impoundment formed by construction of an earthen dam across Salt Creek

about 1200 ft downstream from the confluence of the North Fork of Salt Creek with Salt Creek,

was constructed to provide cooling water for the CPS. The ESP site is approximately 3.5 miles

northeast of the dam.

Unit 1 of CPS uses a once-through cooling system to dissipate heat from the turbine condenser.

A discharge flume is provided to convey CPS Unit 1 circulating water discharge to the Salt

Creek finger of Clinton Lake. The UHS for CPS Unit 1 is water held behind a submerged dam

constructed within the North Fork of Salt Creek in Clinton Lake. The applicant refers to this

water source as the submerged UHS pond.

The ESP facility would also use Clinton Lake as the source of cooling water. The applicant

proposed that the ESP facility use a closed cooling system with wet cooling tower(s). The UHS

for the ESP facility would consist of a mechanical draft cooling tower(s) with no water storage.

The submerged UHS pond using the new intake would supply any makeup water required for

the ESP facility's UHS for a period of 30 days. Therefore, the new intake would be a safetyrelated structure.

2.4.8.1 Technical Information in the Application

The applicant stated in SSAR Section 2.4.8.1 that it would use Clinton Lake as a source of raw

water for the ESP facility. The applicant would add a new intake structure near the existing

CPS Unit 1 screenhouse to supply water to the ESP facility. The ESP facility would use cooling

tower(s) for normal cooling and possibly also for safety-related cooling. The lake would supply

makeup water for evaporation and blowdown losses from the tower(s).

The applicant evaluated the capacity of the lake under a design drought with a 1 00-year

recurrence interval. The applicant committed to maintain the lake water surface elevation at

677 ft MEAL even during a 1 00-year drought. The applicant stated in the SSAR that, if

necessary, it would use a power reduction program to minimize makeup water requirements to

maintain the lake water surface elevation at 677 ft MSL.

The applicant stated in SSAR Section 2.4.8.1.1 that no changes would be made to the Clinton

Dam for the ESP facility. The dam, a homogeneous earthfill dam with a maximum height of

65 ft above the bed of Salt Creek, is 3040 ft long. The top of the dam is at an elevation of

711.8 ft MSL. Both the upstream and downstream faces of the dam have side slopes of

3:1 (horizontal to vertical). The upstream face has an 18-in. thick riprap for protection against

erosion from a 50-mph wind wave on the normal pool level of the lake. On the downstream

face, seeded topsoil provides protection against erosion from rainfall. An 1 8-in.-thick riprap is

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also provided. At the toe of the dam, for protection against tailwater erosion, there is an 18-in.-

thick riprap designed for 50-mph wind acting on a 100-year tailwater flood level.

The applicant estimated the PMF level in Clinton Lake to be 708.8 ft MSL and the maximum

level, corresponding to wave runup acting on the PMF level, to be 711.95 ft MSL. The top of

the dam is at a slightly lower elevation of 711.8 ft MSL. The applicant estimated that the

duration for which wave action on a PMF level would lead to overtopping of the dam as

2.5 hours. The applicant stated that this overtopping would occur in the form of a fine spray and

that this spray falling on the downstream face of the dam would not result in any significant

damage to the dam.

The applicant stated in SSAR Section 2.4.8.1.2 that the ESP facility would require no changes

to the service spillway. The service spillway is designed to pass the design flood of 100-year

recurrence interval with a water surface elevation of 697 ft MSL in the lake. The service

spillway, located on the west abutment of the dam, is an uncontrolled concrete ogee

semicircular in plan, with a crest length of 175 ft and a crest elevation of 690 ft MSL. The height

of the concrete ogee is 10 ft. Water is discharged from the ogee through an 80-ft-wide concrete

chute into a stilling basin, and a discharge canal conveys the water from the stilling basin to the

main channel of Salt Creek. Riprap extends for 80 ft downstream from the stilling basin as

protection against erosion. Peak discharge through the service spillway corresponding to the

100-year flood is 11,450 cfs, and that corresponding to the PMF is 33,200 cfs.

The applicant stated that it used the 100-year flood water level in the lake as the basis for

determining the crest elevation of the auxiliary spillway. The auxiliary spillway functions only

during floods greater than the 100-year flood. The crest of the auxiliary spillway is at an

elevation of 700 ft MSL to allow the 100-year flood to discharge entirely through the service

spillway.

The applicant stated in SSAR Section 2.4.8.1.3 that the ESP facility requires no changes to the

auxiliary spillway. The auxiliary spillway is located to the east of the dam and is designed to

pass floods greater than the 100-year flood, including the PMF. The auxiliary spillway is of the

open-cut type, with a crest length of 1200 ft and a crest elevation of 700 ft MSL. The applicant

estimated peak discharge through the auxiliary spillway during the PMF as 102,800 cfs. The

maximum water velocity at the crest is 14 ft/s. The crest control section of the auxiliary spillway

is 25 ft wide and consists of asphalt concrete. To protect the crest against scouring, concrete

cutoffs and riprap are provided upstream and downstream of the crest.

The applicant stated in SSAR Section 2.4.8.1.4 that the ESP facility would require no changes

to the lake outlet works. The lake outlet works are located on the west abutment of the dam,

160 ft east of the service spillway. The primary function of the lake outlet works is to release a

minimum flow of 5 cfs downstream of the dam. The lake outlet works consist of a submerged

concrete intake, a 36-in.-diameter entrance pipe, a control house with three sluice gates, and a

48-in.-diameter outlet pipe, which terminates at the spillway stilling basin. The crest of the

intake structure for the outlet works is at an elevation of 686 ft MSL, with an inlet diameter of

84 in. transitioning to a 36-in.-diameter throat. A trash rack and a vortex breaker are provided at

the inlet. The sluice gates regulate the downstream releases. The gates are manually operated

from the top of the control house.

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The applicant stated in SSAR Section 2.4.8.1.5 that the existing submerged UHS pond would

serve as the source of makeup water for the safety-related cooling tower(s) for the ESP facility

when water from Clinton Lake was not available. The new intake structure, which would be

located next to the existing screenhouse for the CPS intake, would supply the makeup water.

The applicant judged the capacity of the submerged UHS pond to be sufficient to meet the

safety-related cooling water requirement for the existing CPS unit, as well as to meet the

makeup water requirement for the safety-related cooling tower(s) of the ESP facility for 30 days.

The applicant states that there would be no change in the flowpath through the submerged LIHS

pond. The UHS pond consists of a submerged pond behind a submerged dam constructed

across the North Fork of Salt Creek. This submerged dam is located 1 mi west of the CPS

Unit 1 screenhouse. The top of the submerged dam is at an elevation of 675 ft MSL; its top

width is 30 ft and its length is 2350 ft. The submerged dam consists of homogeneous

compacted backfill material, and both of its faces have a side slope of 5:1 (horizontal to

vertical). A 2-ft-thick compacted soil-cement layer covers the top and both faces of the

submerged dam. The surface area of the submerged UHS pond at the design elevation of

675 ft IVISL is 158 ac, and its corresponding volume is 1067 ac-ft.

The top of the baffle dike within the submerged UHS pond is at an elevation of 676 ft MSL. A

3-ft-thick compacted soil-cement layer covers the dike. The baffle dike is 3300 ft long.

The applicant analyzed flow conditions over the submerged UHS dam resulting from a sudden

breach of the main dam. A 100-ft-wide breach extending from the top of the dam to the creek

bed was assumed to occur during the PMF event, with the water surface elevation of the lake at

708.8 ft MSL. The applicant analyzed the flow conditions over the submerged UHS dam using

the level-pool routing procedure and estimated water surface elevations upstream and

downstream of the submerged UHS dam. The applicant estimated maximum velocities at the

crest and at the toe of the submerged UHS dam to be 3.8 and 11.8 fps, respectively, 43 hours

after the main dam breach. The maximum velocity estimated on the face of the baffle dike is

1.2 fps.

The applicant also estimated velocities over the submerged UHS dam and the baffle dike during

a PMF event with the lake level at the 100-year drought elevation of 682.3 ft MSL. Estimates of

these maximum velocities over the submerged UHS dam and the baffle dike are 2.1 and

2.6 fps, respectively.

The applicant concluded that during both scenarios, the main dam breach and the occurrence

of a PMF with the lake at the 100-year drought elevation, the compacted soil-cement layer

would protect the submerged UHS dam and the baffle dike.

The applicant stated in SSAR Section 2.4.8.2 that the existing CPS discharge flume would

convey the blowdown discharge from the ESP facility to the Salt Creek finger of Clinton Lake.

The applicant stated that the discharge flume was designed to carry a maximum flow of

3057 cfs that would be discharged from CPS Unit 1 and the abandoned CPS Unit 2. The

applicant stated that, because of the abandonment of CPS Unit 2, current flow in the discharge

flume is only 50 percent of its design capacity.

The applicant states that there would be no change to the discharge flume. The discharge

flume is located to the east of the plant area and runs due east towards Clinton Lake. The

2-129
applicant stated that the discharge point of the flume into Clinton Lake provides an effective

cooling surface area of 3650 ac in Clinton Lake. The flume has a bottom width of 120 ft, a side

slope of 3:1 (horizontal to vertical), a total length of 3.4 milesgand a nonscouring design velocity

of 1.5 fps). The minimum freeboard of 3.8 ft is provided in the flume. A 6-in.-thick crushed

stone layer covers the side slopes of the flume for protection against erosion from wind wave

action, and riprap on the lakeside of the embankment fill protects against erosion resulting from

wind wave action in the lake. Two drop structures are provided along the flume to adapt it to

ground topography and to prevent scouring in the flume. Both drop structures are 70 ft wide.

One drop structure is designed for an 18-ft drop, and the second is designed for a 26-ft drop.

The staff requested, in RAI 2.4.8-1, that the applicant explain how it calculated the cooling water

needs for the CPS and ESP facilities, as discussed in SSAR Section 2.4.8.1.5. In response to

RAI 2.4.8-1, the applicant stated that it used the LAKET model, which is a one-dimensional lake

temperature prediction program, to estimate the 30-day cooling water needs for emergency

shutdown of CPS Unit 1. The applicant performed the LAKET modeling as part of the CPS

UHS design to support two 992-megawatt electric (MWe) power generation facilities. The

applicant stated that this design considers the volume of cooling water required for the two CPS

facilities, loss in the submerged UHS pond capacity resulting from sedimentation from a

100-year flood event and from liquefaction resulting from a seismic event, and the volume of

water required for fire protection. This analysis established the minimum design volume of the

CPS submerged UHS pond as 849 ac-ft.

The applicant stated that the UHS for the ESP facility would consist of new cooling tower(s) that

would provide necessary heat dissipation but require makeup water. The applicant estimated

the 30-day makeup water volume based on the 30-day makeup water estimate from the PPE,

plus a 33 percent factor for blowdown and an additional 20 percent factor for overall margin.

The applicant stated that the 30-day makeup volume for the ESP facility would be 87 ac-ft.

The applicant stated that it periodically measures the volume in the submerged UHS pond and

recently measured it to be 1022 ac-ft. The applicant stated that, if the CPS UHS 30-day

minimum design volume of 849 ac-ft were subtracted from the recently measured volume of the

submerged UHS pond, the remaining available volume would be 173 ac-ft, which is 86 ac-ft

greater than that required for the ESP facility. The applicant concluded that the current CPS

submerged UHS pond has sufficient capacity to serve both CPS Unit 1 and to provide makeup

for the new nuclear unit(s).

The applicant stated that it also checked the surface area of the submerged UHS pond, as it is

the single most important factor in controlling the heat dissipation from the CPS heat sink. The

design surface area of the CPS submerged UHS pond at a water surface elevation of 675 ft

MSL is approximately 150 ac. The applicant stated that the as-built surface area of the

submerged UHS pond at a water surface elevation of 675 ft MSL is 158 ac, slightly larger than

the design surface area. The applicant stated that a 0.5-ft reduction in the water surface

elevation of the submerged UHS pond would be expected if a volume of 87 ac-ft, equal to the

30-day ESP facility UHS makeup water requirement, were withdrawn. The applicant concluded

that the design heat dissipation capacity of the CPS submerged UHS pond would be maintained

while accounting for the ESP facility UHS makeup water requirements.

The applicant provided a review of the original CPS UHS modeling using the LAKET program.

The applicant stated that it performed the original analysis to determine the maximum possible

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starting water temperature in the submerged UHS pond without exceeding the 95 'F UHS outlet

temperature that could exist during a two-unit loss-of-coolant accident (LOCA) and a loss of

offsite power (LOOP). The applicant stated that the model was updated in 1985, and a

sensitivity test was performed in 1986. The applicant stated that it estimated maximum

temperatures in the submerged UHS pond at various depths during this sensitivity analysis to

determine whether dredging would be necessary to remove accumulated sediment. The

analysis also determined the maximum submerged UHS pond water temperature that will allow

shutdown of one of the units from 100-percent power load without exceeding the maximum

allowable UHS outlet temperature of 95 'F. The analysis indicated that the maximum allowable

UHS outlet temperature of 95 OF for CPS will not be exceeded with an initial submerged UH';

pond volume of 590 ac-ft and an initial submerged UHS pond water temperature ranging from

84 to 95 'F.

The applicant stated that a review of the model documentation indicated that the input to the

original 1995 LAKET model and the additional modeling performed in 1985 and 1986 were

based on worst-case or most-conservative environmental parameters. The applicant stated that

it examined temperatures in Salt Creek downstream from Clinton Lake for the period before

1975 arid for recent time periods. The applicant found no significant changes in temperature

between these two periods and concluded that the original model results are still applicable.

The applicant noted that it based the previous modeling on a one-dimensional vertically and

laterally averaged approach, which does not account for thermal stratification. The applicant

stated that thermal stratification would result in higher surface temperatures than the depthaverage!d value, resulting in enhanced heat transfer to the atmosphere, thus making model

predictions more conservative by predicting a lower heat transfer rate than would actually be

expected to occur. The applicant stated that the existing intake structure is located such that it

draws water from the deeper part of the lake. The new ESP facility intake structure would also

be designed to draw water from the deeper part of the lake. The applicant reasoned that, since

deeper water is likely to be cooler because of thermal stratification, the initial model approach

and its results remain valid for the ESP application.

The applicant stated that the submerged UHS pond for the CPS is designed to provide sufficient

water and cooling capacity to safely shut down two 992-MWe boiling water reactors (BWR) units

and maintain the plant in the shutdown condition for a period of 30 days. The minimum

submerged UHS pond design volume of 849 ac-ft accounts for the minimum cooling capacity of

590 ac-ft to meet the 95 -F service water inlet maximum temperature, the fire protection

requirement of 3 ac-ft, a loss in capacity because of sedimentation from a 100-year flood of

35 ac-ft, and a loss in capacity because of sedimentation from liquefaction of 221 ac-ft.

Currently, the CPS consists of a single 1138.5-MWe facility. The applicant concluded that the

minimum submerged UHS pond design volume of 849 ac-ft, based on two 992-MWe BWR

units, is sufficient for the single existing 11 38.5-MWe CPS facility.

The applicant stated that the CPS conducts annual surveys as part of the submerged UHS

pond sedimentation monitoring program, and it also monitors sediment accumulation after a

major flood passes through the cooling lake. The Monitoring Program Reports 20-23

(1998-2002) indicate that, immediately following the dredging in 1991, the volume of the

submerged UHS pond was 1054 ac-ft and, in 2001, the volume declined to 1022 ac-ft because

of sedimentation.

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The applicant stated that the ESP facility would require a maximum of 87 ac-ft of cooling water

from the submerged UHS pond for its 30-day emergency shutdown supply. The applicant

estimated that a minimum volume of 935 ac-ft in the submerged UHS pond would be available

for the existing CPS unit, assuming none of the ESP facility's UHS-required water, equal to

87 ac-ft, is returned to the submerged UHS pond. The applicant concluded that this scenario

allows for a reserve volume of 86 ac-ft for sediment accumulation based on the 2001 measured

volume of the submerged UHS pond.

The applicant stated that it would maintain adequate volume in the submerged UHS pond for

the requirements of the existing CPS unit and makeup for the proposed ESP facility UHS to

account for the minimum required volume of 849 ac-ft for the CPS unit and the minimum

required volume of 87 ac-ft for the ESP facility. The applicant stated that, if it elected to

construct an additional nuclear power plant at the site, it would modify the current practice of

dredging the submerged UHS pond when its capacity declines to less than 849 ac-ft so that

dredging would occur when the capacity of the submerged UHS pond decreased to 936 ac-ft.

The applicant stated that the estimated annual sedimentation amount is 5 ac-ft. The applicant

also stated that, while dredging should occur based on volume measurements of the

submerged UHS pond, the new dredging threshold of 936 ac-ft would be expected to result in

dredging at least once every 23 years.

The applicant stated that the relationship between the surface area and the volume of the

submerged UHS pond based on the design and as-built data found in the September 1975 and

April 1985 modeling indicates that the immediate reduction in existing volume by 87 ac-ft would

result in a decrease of the water level in the submerged UHS pond of approximately 0.5 ft. The

applicant stated that this change in water level would not significantly impact the surface area.

The applicant estimated that the new surface area would remain the same or larger than the

design surface area, indicating that the heat rejection capacity of the submerged UHS pond

would be maintained. The applicant also stated that, according to Section 9.2.5.3 of the CPS

USAR, the total heat rejection to the submerged UHS pond over 30 days following an

emergency shutdown of the CPS unit would be less than that assumed during the design of the

UHS. The applicant concluded that the original modeling of the UHS is still applicable for the

new proposed conditions.

The applicant revised SSAR Section 2.4.8.1.5 to provide additional information regarding its

estimation of the cooling water requirements.

The staff requested, in RAI 2.4.8-2, that the applicant discuss how it estimated the flow

velocities over the crest and toe of the submerged UHS dam, as discussed in SSAR

Section 2.4.8.1.5. The staff also asked the applicant to provide figures indicating where the toe

of the UHS dam is located relative to the fill shown in SSAR Figures 2.4-14 and 2.4-15. In

response to RAI 2.4.8-2, the applicant stated that the SSAR Section 2.4.8.1.5 discussion of flow

velocities over the crest and toe of the submerged UHS dam is an unnecessary detail for an

ESP review and that it would revise this section by removing the discussion of velocities over

the crest.

The staff requested, in RAI 2.4.8-3, that the applicant describe lake drawdown calculations. In

response to RAI 2.4.8-3, the applicant updated SSAR Section 2.4.11.1, which discusses the

Clinton Lake drawdown evaluation, to provide additional details of this evaluation.

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In its RAI response, the applicant stated that it considered runoff, evaporation, and forced

evaporation in the drawdown evaluation. The applicant stated that it had established two,

5-year design droughts with return periods of 50 and 100 years and obtained low-flow data for

both design droughts from the CPS USAR. The original low-flow data came from Bulletin 51,

"Low Flows of Illinois Stream for Impounding Reservoir Design," of the Illinois State Water

Authority, issued 1964.

The applicant stated that it used the normal lake water surface elevation of 690 ft MSL as the

starting water surface elevation during the drawdown evaluation. The applicant obtained lake

stage-storage relationship information from the CPS ER based on the original lake volume of

74,200 ac-ft at normal lake water surface elevation. The applicant estimated Inflow into the lake

on a monthly basis by multiplying the rainfall runoff, expressed as a depth, by the watershed

area. Outflow from the lake was assumed to consist of downstream discharge, net lake

evaporation minus lake precipitation, forced evaporation resulting from existing plant operation,

seepage loss, and cooling water consumed by the ESP facility. The applicant assumed the

downstream discharge through the dam to be a minimum of 5 cfs when the lake level was at or

below the 690 ft MSL spill elevation. The drought analysis did not allow the lake level to exceed

690 ft IWSL. The analysis did allow the discharge to be greater than 5 cfs, if inflow would

increase the lake level above the spillway elevation of 690 ft MSL. The CPS USAR provided

data on net lake evaporation minus lake precipitation data for both design droughts.

The applicant stated that it developed forced evaporation data for the existing CPS unit from

data given in the CPS USAR. The initial forced evaporation data were based on two 992-MWe

BWR plants operating at a 70-percent load factor. Forced evaporation is defined as the

additional evaporation resulting from an increase in lake water temperature caused by the

discharge of cooling water to the lake from the once-through cooling system for the two original

plants. The applicant subsequently revised the forced evaporation rate for the two originally

proposed plants to estimate the rate for the single, uprated existing CPS unit. The CPS Unit 1

was uprated from its original 992-MWe rating to 1138.5 MWe in 2002. The applicant divided the

forced evaporation rate from the CPS USAR by 0.7 to obtain the forced-evaporation rate for a

1 00-percent load factor. The applicant then divided the resulting forced-evaporation rate by two

because only one of the two originally planned units was constructed. This new forcedevaporalion rate was again adjusted for the plant uprate by multiplying by a factor of 1.147

(1138 divided by 992).

The applicant stated that it had recently checked the forced-evaporation rates for the original

992-MWe plant operating at a 100-percent load factor. Forced and natural evaporation occur

simultaneously as the circulating cooling water flows through the cooling loop. To differentiate

between the amounts of natural and forced evaporation, the applicant determined the

equilibrium temperature of the lake on a monthly basis using monthly meteorologic data over

the period of record. The applicant stated that the equilibrium temperature is the temperature of

water in the lake about 1 ft below the surface, where the heat input to the lake is exactly

balanced by the heat output from the lake. The applicant stated that the equilibrium

temperature is determined by performing a heat balance for solar heat gain, heat loss by

convection, evaporative cooling, and radiant heat transfer from the water to the surroundings.

The amount of natural evaporation is determined based on the equilibrium temperature.

The applicant stated that it developed a model based on the method of Langhaar to determine

the amount of forced evaporation. The model was validated based on its agreement with the

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results of an earlier study by Edinger. The applicant then applied the model to simulate the

cooling lake for each month using monthly average climatic conditions over the period of record.

The applicant stated that the evaporation estimated by this-model was the total, or the sum of

natural and forced evaporation. Forced evaporation was the difference between the total and

previously estimated natural evaporation.

The applicant stated that the analysis for the existing CPS unit and the ESP facility assumed a

1 00-percent load factor during their respective operations. It was assumed that each design

drought would begin in January of the first year. Seepage loss was assumed to be 0.5 percent

of the lake capacity per month. The applicant carried out the drawdown calculations on a

monthly time step. EGC calculated a net volume gain or loss by subtracting losses and adding

gains to the initial lake volume for each month to obtain the initial lake volume for the next

month. The applicant used the lake stage-surface area and stage-volume relationship from the

CPS ER to estimate lake water surface elevation and area for the next month. It then repeated

these calculations for the 50-year and the 100-year drought.

The applicant also determined the amount of cooling water available during the droughts. The

average annual water consumption for the existing CPS unit at 100-percent load factor is

1100 ac-ft per month (ac-ft/mo). The applicant stated that the total amount of water available

during the 100-year drought is 2400 ac-ft/mo. The applicant estimated that the amount of

available water in excess of that needed for the CPS unit is 1300 ac-ft/mo during the 100-year

drought. The applicant stated that, based on the drawdown analysis corresponding to the

50-year drought, the total amount of water available during the 50-year drought is

3100 ac-ft/mo. The applicant estimated that the amount of available water in excess of that

needed for the CPS unit is 2000 ac-ft/mo during the 50-year drought.

The applicant also stated that the available water quantities are expected to maintain the lake

water surface elevation at or above the CPS minimum lake elevation of 677 ft MSL with both the

existing CPS unit and the proposed ESP facility in operation.

The staff requested, in RAI 2.4.8-4, that the applicant describe how it estimated the UHS

capacity loss resulting from sediment or debris during extreme events. In response to

RAI 2.4.8-4, the applicant stated that the ESP facility would use the safety-related cooling

tower(s) as the UHS, if one were to be required, and would use the CPS submerged UHS pond

only as a source of makeup water. For this reason, sediment or debris does not directly affect

the ESP facility's UHS.

The applicant stated that, according to soil surveys of Illinois, early spring rains in areas where

soil is exposed because of farming can cause extensive erosion when the soil surface is

partially frozen leading to greater runoff. The applicant stated that the highest 24-hour PMP

occurs in the summer and fall (June through September), with the monthly PMP value ranging

from 24.4 to 31.2 in. The applicant reasoned that the occurrence of the PMP would not be

coincident with the conditions for maximum runoff.

The applicant stated that the design of the CPS UHS pond considered four failure modes:

(1) loss of cooling water inventory because of its displacement by alluvial flow slides into the

UHS

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(2) loss of the service water system because of blockage of the service water pump intakes

from unstable soil flow blocking or entering the intake structure

(3) loss of UHS circulation pattern because of local slides producing dams or dikes across

the circulation channel

(4) loss of UHS water as a result of the UHS dam or its flanks breaching because of a

combination of seismic loading, liquefaction, and washout

The applicant stated that, in addition to the storage requirements for cooling purposes and fire

water supply, the submerged UHS pond was designed to account for sedimentation. The

design of the submerged UHS pond considered sediment inflow from liquefaction and an

associated loss in capacity of 221 ac-ft, fire water storage capacity of 3 ac-ft, minimum cooling

water capacity of 590 ac-ft required to meet the 95 'F shutdown service water inlet temperature,

and loss; in capacity of 35 ac-ft from sedimentation resulting from a 1 00-year flood.

In Revision 4 of the SSAR, the applicant stated that the probable maximum flood water surface

elevation is 709.8 ft MSL. The applicant also stated that any overtopping wave would only

produce a spray because of riprap placed on the upstream face of the dam. The applicant

stated that the downstream face of the dam is protected against gully erosion by grass and

therefore, any overtopping resulting in spray on the downstream face is not expected to resul: in

significant damage to the dam.

2.4.8.2 Regulatoiy Evaluation

Acceptance criteria for this section are based on meeting the requirements of 10 CFR Parts 52

and 100 as they relate to identifying and evaluating the hydrologic features of the site.

Compliance with 10 CFR 52.17(a) and 10 CFR 100.20(c) requires consideration of the site's

physical characteristics (including seismology, meteorology, geology, and hydrology) when

determining its acceptability for a nuclear power reactor. To satisfy the hydrologic requirements

of 10 CFR Parts 52 and 100, the applicant's safety assessment should contain a description of

cooling water canals and reservoirs for a nuclear power plant(s) of specified type (or falling

within a PPE) that might be constructed on the proposed site. The applicant should include

details in its analysis of cooling water canals and reservoirs sufficient to evaluate the site's

acceptability and to assess the potential for those characteristics to influence the design of

SSCs important to safety for a nuclear power plant(s) of specified type (or falling within a PPE)

that might be constructed on the proposed site. Meeting this requirement provides reasonable

assurance that the capacities of cooling water canals and reservoirs are adequate.

In those cases for which a reactor design is not specified, the ESP applicant may instead

provide E. PPE to characterize a facility or facilities for comparison with the hydrologic

characteristics of the site. The applicant can develop a PPE for a single type of facility or a

group of candidate facilities by selecting the limiting values of parameters. Important PPE

parameters for safety assessment described in SSAR Section 2.4 include, but are not limited lo,

cooling needs (e.g., adverse local meteorological conditions, high ambient temperature).

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2.4.8.3 Technical Evaluation

The staff visually inspected the site during the site safety analysis visit on May 11,2004. The

staff determined that the SSAR accurately describes the intakes, discharge canals, outfalls, and

reservoirs near the ESP site.

The applicant stated in SSAR Section 2.4.8.1 that the ESP facility would use cooling tower(s)

for the normal cooling of the power plant. In addition, the applicant stated in SSAR

Section 2.4.8.1 that the UHS system for the ESP facility might also use cooling tower(s). In the

same section, the applicant stated that a lake drawdown analysis, to be performed at the design

stage, would indicate whether a load reduction to the ESP facility, or a wet/dry hybrid cooling

tower system, might be necessary to maintain water surface elevation in Clinton Lake at or

above 677 ft MSL during a 100-year drought.

According to the PPE table (SSAR Table 1.4-1, item 3.3.9), average makeup water for the UHS

system with mechanical draft cooling tower(s) is 555 gpm. This makeup water flow is equivalent

to a volume of 73.6 ac-ft over a 30-day period. The staff estimated that applying a 33-percent

factor for blowdown, and an overall 20-percent margin, the 30-day makeup water needed for the

ESP facility's UHS system would be 73.6 x 1.33 x 1.2 = 117.4 ac-ft. The staff's estimate was

considerably different from the applicant's estimate of 87 ac-ft. The staff determined that the

applicant needed to justify its makeup water requirements for the proposed UHS. This was

DSER Open Item 2.4-12.

In response to DSER Open Item 2.4-12, the applicant stated, in its submission to the NRC

dated April 4, 2005, that the difference between the EGC and the NRC estimates of the 30-day

makeup water needed for the ESP facility's UHS is the result of double counting of the

blowdown in the NRC estimate. The applicant explained that if the average makeup flow rate of

555 gpm (SSAR Table 1.4-1, item 3.3.9) used by the NRC in its calculations, which includes

blowdown, were replaced by 411 gpm (SSAR Table 1.4-1, item 3.3.7), the 30-day makeup

water volume needed for the ESP UHS system would be 87 ac-ft.

The staff reviewed the applicant's response to DSER Open Item 2.4-12 and verified that the

applicant's calculations were accurate. The staff also verified that the 30-day makeup water

volume required by the ESP facility's UHS, excluding blowdown, would be 87 ac-ft. Based on

the above review, the staff considers DSER Open Item 2.4-12 resolved.

The staff concluded that the applicant needed to provide additional details on the ESP facility's

normal and UHS systems and their cooling water requirements to allow determination of the

maximum PPE heat rejection parameters. The applicant needed to provide a commitment to

specific ESP facility normal and UHS systems for the staff to conclude this review. The staff

needed this information at the ESP stage to evaluate the adequacy of the water stored in the

submerged UHS pond available for the ESP facility. This was DSER Open Item 2.4-13.

In response to DSER Open Item 2.4-13, the applicant stated, in its submission to the NRC

dated April 4, 2005, that SSAR Table 1.4-1 provides the maximum PPE heat rejection

requirements and, therefore, the staff need not determine them.

The applicant stated that the ESP facility NHS will be a mechanical draft cooling or a natural

draft cooling tower system. The applicant stated that the NHS cooling tower may use dry

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cooling in combination with wet cooling, or only wet cooling, depending on the selected reactor

type for the ESP facility. The applicant also stated that a commercial decision might be made to

use wet/dry cooling to limit the amount of evaporation and maintain plant operation during

drough: periods.

The applicant stated that the ESP facility's UHS, if one were required by the selected reactor

type, would consist of a mechanical draft cooling tower(s). The applicant also stated that sorne

of the reactor types that could be used for the ESP facility use passive cooling or air blast

cooling and do not require a UHS. The applicant argued that because not all reactor types that

could be used for the ESP facility require a UHS, the SSAR was written to recognize that a UHS

will be provided only if required.

The applicant stated that the adequacy of the submerged UHS pond volume available for the

ESP facility cannot be determined until the design of the ESP facility is determined. The

applicant stated that at the ESP stage, it was only possible to determine the volume of water

available in the submerged UHS pond that could be utilized for safe shutdown of the ESP

facility.

The staif reviewed the applicant's response to DSER Open Item 2.4-13 and determined that, as

stated in the SSAR and as reiterated by in its response, it is possible that the ESP facility may

require a water-cooled UHS. The actual design of the NHS and UHS is an issue that is beyond

the scope of this ESP review. However, site characteristics that govern and may limit the

design of the NHS and UHS must be established at the ESP stage. The COL or CP applicant

needs to conclusively establish that any water-cooled UHS that may be required by a reactor

type selected for the ESP facility will be designed to a maximum 30-day makeup water

requirement not exceeding 87 ac-ft. This is COL Action Item 2.4-8. The COL or CP applicant

also needs to establish that the ESP facility's NHS is designed such that there is no overreliance on the UHS for frequent plant shutdowns. This is COL Action Item 2.4-9. Therefore,

the staff considers DSER Open Item 2.4-13 to be resolved.

The stafi requested, in RAI 2.4.8-1, that the applicant explain how it calculated the cooling waler

needs for the CPS Unit 1 and the ESP facility. In response to RAI 2.4.8-1, the applicant

described earlier modeling performed for the original analysis of the CPS UHS. The model

used (LA KET) is apparently no longer available for independent evaluation by the staff. The

documentation of earlier applications of the model is limited to the description provided in the

CPS USAR. The applicant stated that the depth-averaged temperature model would be more

conservative than a stratified model, since the higher surface temperatures would result in

increased heat loss. The staff agreed that a depth-averaged temperature model would indeed

be conservative for temperature; however, the increased heat loss would come, in part, from

increased forced evaporation. This implies that a depth-averaged model may not be

conservative in terms of the volumetric analysis. The applicant stated that the UHS for CPS

was designed for two units, of which only one was constructed. The UHS volume requirements

for the Ei'P facility would be far less than the requirements for the two 992-MWe units originally

planned. The applicant did not provide the volume requirements for the existing single upratecl

11 38.5-MWe CPS facility. The staff concluded that inadequate information exists to review the

earlier modeling study on which the applicant relied. The staff determined that the applicant

needed to provide the volume requirements of the UHS for the CPS, taking into consideration

the latest power uprate. This was DSER Open Item 2.4-14.

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In response to DSER Open Item 2.4-14, the applicant stated, in its submission to the NRC

dated April 26, 2005, that the required capacity of the UHS for the CPS uprated Unit 1 is

586 ac-ft. The applicant-estimated CPS shutdown cooling water consumptive use-is 327 ac-ft,

obtained by multiplying the consumptive water use of 590 ac-ft for the two originally planned

CPS units by the ratio of the uprated CPS unit shutdown heat load to the shutdown heat load of

the two CPS units originally planned (590 ac-ft x 99,973 BTU / 180,455 BTU = 327 ac-ft). The

required capacity of the UHS (i.e., 586 ac-ft) includes 327 ac-ft consumptive use for the CPS

facility, 3 ac-ft for fire protection, 35 ac-ft for sedimentation from a 100-year flood, and 221 ac-ft

for sediment inflow during SSE liquefaction.

The staff reviewed the applicant's response to DSER Open Item 2.4-14 and determined that the

consumptive water use for the uprated CPS facility is 327 ac-ft. The applicant provided enough

information to resolve the issue stated in DSER Open Item 2.4-14. Therefore, the staff

considers DSER Open Item 2.4-14 resolved.

The staff requested, in RAI 2.4.8-2, that the applicant discuss how it computed the flow

velocities over the crest and the toe of the submerged UHS dam. The staff also asked the

applicant to provide figures indicating where the toe of the submerged UHS dam is located with

respect to the fill shown in SSAR Figures 2.4-14 and 2.4-15. In response to RAI 2.4.8-2, the

applicant stated that a discussion of flow velocities over the crest and toe of the submerged

UHS dam is an unnecessary detail for an ESP review and it revised the appropriate section of

the SSAR to remove the discussion of the flow velocities. SSAR Section 2.4.8.1 describes

stabilization of the submerged UHS dam and the baffle dike with compacted soil-cement. Such

measures should protect these structures against erosion. The staff determined, therefore, that

the applicant specified erosion protection measures and that its response is satisfactory.

The staff requested, in RAI 2.4.8-3, that the applicant describe its lake drawdown calculations.

In response to RAI 2.4.8-3, the applicant described an analysis of changes in pool elevation

resulting from droughts of 5-year duration with a recurrence period of 50 and 100 years. The

applicant did not provide a basis for selecting the 5-year-duration drought over a shorter drought

duration which would provide a much lower inflow, albeit for a shorter duration. The staff, based

on an independent reading of the report from an earlier study conducted by the Illinois State

Water Survey that the applicant used as the basis for the assumed low-flow conditions,

concluded that a drought period of shorter duration with the same recurrence period could result

in considerably more challenging conditions for lake level. For instance, based on data in the

report for the Rowell gauge on Salt Creek, using a recurrence interval of 40 years, the inflows

(expressed as area-averaged runoff) for the 1 -year drought and 5-year drought are

approximately 1 in. and 23 in., respectively. The applicant relied on the CPS USAR as the

basis for its values of natural evaporation and precipitation. It performed the analysis using a

spreadsheet calculation and provided the spreadsheet as Attachment C to its responses to

RAls 5.2-1 and 5.2-2 generated from the staff's review of the applicant's ER. The staff reviewed

the applicant's narrative response to RAI 2.4.8-3, the associated spreadsheet calculations, and

the Illinois State Water Survey report on low flows of Illinois streams. The staff concluded that

the applicant needed to provide a rationale for using the 5-year drought duration as opposed to

a shorter duration drought with a significantly lower inflow estimate. This was DSER Open

Item 2.4-15.

In response to DSER Open Item 2.4-15, the applicant stated, in its submission to the NRC

dated April 26, 2005, that the 5-year-duration drought was used to evaluate Clinton Lake in the

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original lake study and the more recent evaluation of the uprated CPS. The applicant stated

that, for consistency, the same duration drought was also used for the current ESP application.

The applicant also stated that a review of duration of the drought indicated that it is still

appropriate rather than a shorter duration drought of significantly lower inflow estimate.

The applicant stated that the storage capacity of Clinton Lake is large enough that short

duration droughts of 1 to 2 years do not create critical conditions. The applicant's simple massbalance calculation with zero inflow indicated that it will take approximately 20 months for

Clinton Lake to drop from an initial water surface elevation of 690 ft MSL to the CPS and ESP

facility shutdown water surface elevation of 677 ft MSL. The applicant also stated that with an

extreme low inflow of 0.04 in. every month, the lake can support normal plant operation for

approximately 29 months.

The applicant stated that its review of inflow values associated with the current 5-year-duraticon

drought indicated that shorter-duration droughts are embedded within the 5-year drought used

in its analysis for the ESP application. The applicant stated that CPS USAR Table 2.4-24

shows the "5-year duration" drought used in the analysis for the ESP application. The first year

of the 5-year drought had a cumulative runoff volume of 0.85 in., which is close to the 45-yea:

recurrence interval, 1-year inflow volume of 0.91 in. shown by Table 4 of the Stall (1964) report.

The applicant argued that the 1-year, 50-year recurrence interval drought is thus accounted for

in the first year of the 5-year-duration drought. Similarly, the applicant argued, that the first

2 years of the 5-year drought had a cumulative inflow of 4.9 in. as compared to the 45-year

recurrence interval, 2-year inflow volume of 4.94 in., reported by Stall (1964). Also, the 5-year

duration of the CPS USAR analysis had a cumulative inflow of 24 in., as compared to 23 in.

reported in Stall (1964). The applicant stated that similar comparisons and conclusions are also

valid for the 100-year recurrence interval drought that it used in the ESP drought analysis.

The staff reviewed the applicant's response to DSER Open Item 2.4-15 and adopted a simpler

way to envelop the effects of severe, sustained drought in the Clinton Lake watershed on the

lake and its ability to sustain operation of the CPS and the ESP facility. The staff conservatively

estimated the rate of fall in water surface elevation in Clinton Lake during drought conditions by

assuming that (1) both the CPS and the ESP facility were operating at 100 percent of their

respective capacities, (2) there was no inflow into the lake, (3) Clinton Lake was discharging the

minimum required 5 cfs downstream of the dam, and (4) the natural evaporation from the lake

was set to a conservatively high estimate equal to the 8.35 inches per month (in./mo) of

evaporal ion reported by Roberts and Stall (1967) for July 1936.

The staff estimated the forced evaporation for the existing CPS by assuming that all heat

produced by the CPS which was not converted into electrical energy would be dissipated as

latent heat of evaporation from Clinton Lake. This assumption resulted in an estimated 38 cfs of

forced evaporation caused by the heat load from the CPS. The forced evaporation for the ESP

facility was assumed equal to the PPE value of 70.2 cfs, reported in SSAR Table 1.4-1,

item 2.4.7. The staff assumed that the total outflow from the Clinton Lake, consisting of natural

evaporation, forced evaporation caused by the presence of the CPS and ESP facilities, and the

downstream release from the dam would occur with the water surface area of Clinton Lake fixed

at a conservatively low value of 2550 ac corresponding approximately to a water surface

elevation of 677 ft MSL, thereby resulting in a correspondingly larger water surface drop rate.

The staff -estimated the maximum water surface drop rate in Clinton Lake to be 41.1 inJmo.

Based on this conservatively estimated water surface drop rate, the staff determined that it will

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take approximately 18 days for the water surface in Clinton Lake to fall from 679 ft MSL to 677 ft

MSL.

While it is possible for a more rapid decrease in water surface elevation in Clinton Lake to occur

in the presence of a more severe combination of starting water surface elevation, low inflow,

and little precipitation, the staff considers the 18-day period required for the water surface

elevation to fall from 679 ft MSL to 677 ft MSL indicative of Clinton Lake's large capacity, which

allows a gradual decrease in its water surface elevation, even under extreme droughts. The

staff concluded, therefore, that water surface elevation in Clinton Lake does not fall rapidly and

sufficient time will be available to plant operators before the low-water surface elevation

shutdown threshold is reached to plan a shutdown of the proposed ESP facility without

endangering its safety, even under severe drought conditions. The staff also concluded that the

water surface elevation in Clinton Lake does not fall near the low-water surface elevation

shutdown threshold frequently enough to result in an excessive reliance of the ESP facility on its

UHS, if one were required. Based on the above review, the staff considers DSER Open

Item 2.4-15 resolved.

The staff requested, in RAI 2.4.8-4, that the applicant describe how it estimated UHS capacity

loss because of sediment or debris loads during extreme events. In response to RAI 2.4.8-4,

the applicant stated that the ESP facility would use cooling tower(s) as the UHS and would only

use the submerged UHS pond as a source of makeup water. The applicant explained that, for

this reason, sediment or debris would not directly affect the ESP facility UHS.

The applicant stated that the design of the UHS considered the following factors:

* loss of storage capacity because of sediment inflow from liquefaction, equal to 221 ac-ft

* a fire water requirement of 3 ac-ft

* minimum cooling water capacity of 590 ac-ft required for CPS Unit 1

* loss in capacity of 35 ac-ft from sedimentation resulting from a 100-year flood

The staff's estimate of ice sheet formation in Clinton Lake indicated that the maximum ice

thickness could reach 31.4 in. Under these icing conditions, if the main dam were to fail, or the

water surface elevation in Clinton Lake were to fall to 675 ft MSL, some loss in the storage

capacity of the submerged UHS pond would be likely because the ice sheet would settle down

into the pond behind the submerged UHS dam. The staff conservatively estimated this loss in

capacity by multiplying the surface area of the submerged UHS pond at elevation 675 ft MSL by

the maximum thickness of the ice sheet. The staff estimated that the loss in submerged UHS

pond capacity because of icing would be 413 ac-ft. Based on this estimate and the issue

described in DSER Open Item 2.4-12, the staff concluded that the applicant needed to establish

that the submerged UHS pond has adequate capacity to provide makeup water to the ESP

facility UHS. This was DSER Open Item 2.4-16.

In response to DSER Open Item 2.4-16, the applicant stated, in its submission to the NRC

dated April 26, 2005, that the required capacity of the submerged UHS pond was established

based on maximum evaporative loss from the facilities and temperature limitations of 95 OF at

the plant intakes.

The applicant stated that the design capacity of the submerged UHS pond with water surface

elevation at 675 ft MSL and a top water surface area of 158 ac is 1067 ac-ft. The applicant

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estimated the 30-d total UHS cooling requirement for the CPS and the ESP facility to be

327 ac-ft and 87 ac-ft, respectively. Additionally, 3 ac-ft may be required for fire protection,

35 ac-fl for sediment accumulation from a 100-year flood event, and 221 ac-ft for sediment

inflow caused by liquefaction during an SSE. The applicant-estimated water use for all these

requirements is 673 ac-ft, leaving 394 ac-ft of excess capacity in the submerged UHS pond.

The applicant stated that it determined the maximum evaporative loss from the submerged UHS

pond during warm weather conditions when atmospheric cooling may be limited. The applicant

argued that with an ice cover on the lake, evaporative loss would be limited to a negligible

quantity. Under this scenario, the applicant estimated the CPS UHS cooling needs for 30 days

as 0 ac-ft. Given a 30-day UHS makeup requirement for the ESP facility of 87 ac-ft, 3 ac-ft for

fire protection, 35 ac-ft for sediment accumulation from a 100-year flood event, and 221 ac-ft for

sediment inflow caused by liquefaction during an SSE, the applicant estimated that the excess

capacit, in the submerged UHS pond during ice-covered conditions would be 421 ac-ft, allowing

for a loss of liquid water displace by a 24.8-in thick ice sheet approximately equal to 300 ac-ft

(158 ac x 24.8 in. / 12 in./ft x 0.917 = 299.4 ac-ft, as stated by the applicant in response to

DSER C)pen Item 2.4-11). The applicant thus concluded that the excess capacity in the

submerged UHS pond accounting for the ESP facility's 30-day UHS makeup water requirement

is greater with an ice sheet formed on the surface of the submerged UHS pond than without i-e

formation.

The staff reviewed the applicant's response to DSER Open Item 2.4-16 and determined that the

negligible evaporative loss argument is acceptable when an ice sheet is covering the

submerged UHS pond. The staff's revised estimate of the maximum thickness of an ice sheet

that may form on Clinton Lake is 27 in. (see discussion related to DSER Open Item 2.4-9

above). Based on this revised maximum ice thickness, the volume of liquid water displaced, if

this ice sheet were to settle down into the submerged UHS pond, is approximately 319 ac-ft

(see discussion related to DSER Open Item 2.4-11 above).

The staff also determined that the applicant used the design capacity of the submerged UHS

pond (1C067 ac-ft) while estimating the volume of excess water in the submerged UHS pond.

The applicant reported, in response to DSER Open Item 2.4-17 (see discussion related to

DSER Open Item 2.4-17 below), that the storage capacity of the submerged UHS pond in 2004

was reduced to 991 ac-ft by sediment accumulation. The staff determined that the present

storage capacity of the submerged UHS pond must be used to establish excess capacity within

it. Most of the CPS 30-day UHS consumptive loss would occur as evaporation from the free

water surface under elevated water temperature condition. The presence of an ice sheet on

most of the surface of the UHS pond would prevent evaporation from the water surface in

contact with the ice sheet. Therefore, the CPS 30-day UHS consumptive loss would be reduced

to an insignificant amount. The staff determined the excess capacity to be approximately

318 ac-ft without an ice-cover on the lake (991 ac-ft - (327 ac-ft for CPS 30-day UHS

consumptive loss + 3 ac-ft for fire + 35 ac-ft for 100-year flood sedimentation + 221 ac-ft

liquefaction sedimentation from SSE + 87 ac-ft for ESP facility 30-day UHS makeup)) =

318 ac-ftjl, and approximately 319 ac-ft with an ice-sheet covering the surface of the submerged

UHS ponJ (991 ac-ft - {insignificant CPS 30-day UHS consumptive loss + 3 ac-ft for fire +

35 ac-ft for 100-year flood sedimentation + 221 ac-ft liquefaction sedimentation from SSE +

87 ac-ft for ESP facility UHS 30-d makeup + 326 ac-ft lost to ice sheet)) = 319 ac-ft).

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In its letter dated December 21, 2005, the applicant revised its estimate of maximum ice thickness in Clinton Lake. The applicant also revised its response to Open Item 2.4-16 in this letter. The applicant stated that reduction in water storage capacity of the submerged UHS pond due to an ice sheet 27.0 in. in thickness will be approximately 326 ac-ft. The applicant estimated the excess water storage capacity within the submerged UHS pond to be approximately 395 ac-ft, based on a total available capacity of 1067 ac-ft. Applicant's estimate (approximately 395 ac-ft) therefore, is larger than staff's estimate (318 or 319 ac-ft). This difference is due to different total storage capacities of the submerged UHS pond used by the applicant and the staff. The applicant stated in response to Open Item 2.4-17 below that the total storage capacity of the submerged UHS pond was reduced to 991 ac-ft in 2004 due to sediment accumulation. As stated above, staff determined that the current storage capacity of the submerged UHS pond must be used to determine excess water storage capacity within it. Due to this difference, the staff's estimate of excess capacity in the submerged UHS pond is much smaller than that stated by the applicant. Nevertheless, the staff estimate of excess capacity in the submerged UHS pond is adequate to provide makeup water to the ESP facility UHS, if one is needed by the selected reactor type. The staff's proposed COL Action Item 2.4-10, stated below, requires that the submerged UHS pond will be dredged frequently to ensure that adequate liquid water will be available for the ESP facility UHS, if a UHS is required by selected reactor type. The frequency of dredging will be established at the COL stage. Therefore, the staff considers DSER Open Item 2.4-16 resolved.

The applicant stated that it monitors the CPS UHS for sediment accumulation periodically and after a major flood passes through the submerged UHS pond. The applicant committed to perform necessary dredging to prevent the accumulation of sediment from exceeding the capacity provided for sediment storage in the design. The staff evaluated the applicant's response to open items listed in this section to consider the adequacy of submerged UHS pond monitoring and dredging. The staff determined that the applicant needed to establish the monitoring and dredging requirements for the UHS pond for the combined operation of the CPS facility and a future facility consistent with the PPE parameter for maximum thermal discharge. This was DSER Open Item 2.4-17.

In response to DSER Open Item 2.4-17, the applicant stated, in its submission to the NRC dated April 26, 2005, that the NRC staff appeared to have confused the actions of the ESP applicant and those of the CPS operators. The applicant stated that the CPS operators monitor the CPS UHS for sediment accumulation, not the applicant. The applicant also stated that it did not commit to dredging the CPS UHS. The applicant also stated that the ESP review stage is inappropriate for establishing operational requirements for the ESP facility, since a water-cooled UHS may not even be required for some potential ESP facility reactor types.

The applicant stated that monitoring reports from 1991 to 2004 show a nominal reduction of 63 ac-ft in the water storage capacity of the submerged UHS pond (from 1054 ac-ft in 1991 to 991 ac-ft in 2004), a loss rate of 4.85 ac-ft/year. The applicant stated that the submerged UHS pond will have an excess capacity of 394 ac-ft, even if the ESP facility were to use a water- cooled UHS. At the stated sedimentation rate, the applicant estimated that the submerged UHS pond would require dredging once every 81 years (394 ac-ft / 4.85 ac-ft/year = 81.2 year). Based on this reasoning, the applicant stated that it did not propose a dredging frequency in the ESP application. The applicant stated that the need for dredging will be evaluated at the COL stage based on the final design of the ESP facility and the results of the CPS UHS sedimentation monitoring reports.

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The staff reviewed the applicant's response to DSER Open Item 2.4-17 and determined that,

based cn the PPE information provided in the SSAR, a water-cooled UHS may be required by

the selected ESP facility reactor type. Since the safety of the water-cooled ESP facility UHS will

depend on the water availability within the submerged UHS pond, the submerged UHS pond is

a safety-related facility for the proposed ESP facility. The staff also determined that site

characteristics related to the submerged UHS pond that may be used for design of a future

water-cooled ESP facility UHS must be established at the ESP stage. The sediment

accumulation rate of 4.85 ac-ft/yr is a normal sediment accumulation rate over the last 13 years

only, which may be subject to large increases during years of extreme flood events in the

Clinton Lake watershed. Since the submerged UHS pond is a safety-related facility for the ESP

facility based on the description in the SSAR, the monitoring and any required dredging of the

submerged UHS pond is the responsibility of the ESP facility operators and will be determined

at the CDL stage. This is COL Action Item 2.4-10. Based on the above review, the staff

considers DSER Open Item 2.4-17 resolved.

The staff had planned to include the submerged UHS pond monitoring and dredging

frequencies as a permit condition. However, the reliance of the ESP facility UHS on water

available in the submerged UHS pond is dependent on the selected reactor type requiring a

UHS. The staff concluded therefore that COL Action Item 2.4-10 is sufficient to ensure that

adequate liquid water will be available for the ESP facility's UHS, if one is required by the

selected reactor design and no additional permit conditions are necessary.

2.4.8.4 Conclusions

As set forth above, the applicant provided sufficient information pertaining to identifying and

evaluating cooling water canals and reservoirs at the site. SSAR Section 2.4.8 conforms to

Section :2.4.8 of NUREG-0800, "Standard Review Plan for the Review of Safety Analysis

Reports for Nuclear Power Plants,' issued July 1981 (hereafter referred to as the SRP), as

applicable to an ESP site.

The review guidance in SRP Section 2.4.8 provides that the SSAR should address 10 CFR

Parts 50 and 100, as they relate to identifying and evaluating cooling water canals and

reservoirs at the site. Although the applicant did not specifically address the above regulations

in SSAR Section 2.4.8, the staff concludes that by conforming to SRP Section 2.4.8 the

applicant has met the requirements for cooling water canals and reservoirs at the site with

respect to 10 CFR 52.17(a) and 10 CFR 1 00.20(c)(3), except as noted in Section 2.4.8.3 above.

Further, with the exception noted, the applicant considered the most severe natural phenomena

that have been historically reported for the site and surrounding area in establishing designbasis information related to cooling water canals and reservoirs, with sufficient margin for the

limited accuracy, quantity, and period of time in which the historical data have been

accumulated.

2.4.9 Channel Diversions

Relatively thin deposits of Quaternary glacial drift dominate the regional surface geology in the

vicinity of the ESP site. During the Quatemary period, continental glaciation caused widespread

glacial deposition in the region. The deposits at the ESP site are consistent with the regional

deposits and are classified as part of the Pleistocene Series, consisting predominantly of glacial

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or glacially derived sediments of glacial till, outwash, loess (a windblown silt), glaciolacustrine

deposits, and alluvium.

2.4.9.1 Technical Information in the Application

The applicant stated in SSAR Section 2.4.9 that is no existing historical evidence of channel

diversion in the Salt Creek or the North Fork of Salt Creek upstream of the Clinton Dam. The

applicant stated that, based on topographic characteristics and geologic features of the

drainage basin, landslides that might lead to blockage of streamflow into Clinton Lake are not

possible. The applicant also noted that, as discussed in SSAR Section 2.4.7, the history of ice

jam formation does not indicate streamflow diversion during the winter months.

In RAI 2.4.9-1, the staff requested the applicant to reference studies related to the geological

features or other characteristics that preclude any likelihood of channel diversion upstream of

the ESP site. In response to RAI 2.4.9-1, the applicant stated that it performed a study of

geological features and other characteristics related to the potential for channel diversion

upstream of the ESP site specifically for the ESP application. The applicant indicated that this

site-specific examination did not rely on any previously published studies other than topographic

maps. The applicant further stated that its examination of the topographic maps of Salt Creek

and the North Fork of Salt Creek did not reveal evidence of natural channel diversions, such as

oxbow lakes or broad, well-developed floodplains.

The applicant stated that the creeks and streams in the watershed generally occur in welldefined valleys. Any diversion of water out of these valleys into an adjacent drainage basin

would require sufficient energy to overcome the topography and cut a new drainage channel.

The applicant stated that, based on the physical characteristics of the drainage area and the

creek system, it is unlikely that a potential, naturally occurring channel diversion would shift

water out of the Clinton Lake watershed. In Revision 4 of the SSAR, the applicant added

information to reflect the above clarification.

2.4.9.2 Regulatory Evaluation

SSAR Table 1.5-1 shows the applicant's conformance to the NRC RGs. In RAI 1.5-1, the staff

asked the applicant to provide a comprehensive listing of NRC regulations applicable to its ESP

SSAR. In its response to this RAI, the applicant indicated that RS-002, Attachment 2, identifies

the NRC regulations applicable to its ESP SSAR. Section 2.4 of RS-002, Attachment 2,

describes the methods of review and the applicable acceptance criteria that the staff uses to

develop its findings and conclusions related to the hydrologic aspects of site characterization for

an ESP. Although the applicant did not indicate how the individual sections of SSAR

Section 2.4 address the hydrology-related site suitability criteria in RS-002, Attachment 2, the

staff reviewed this portion of the application for conformance with the applicable regulations and

considered the corresponding regulatory guidance, as identified below.

The staff used the review guidance provided in Section 2.4.9 of RS-002, Attachment 2, to

evaluate this SSAR section. These acceptance criteria relate to 10 CFR Parts 52 and 100,

insofar as they require that the site evaluation consider the hydrologic characteristics of the site.

The regulations at 10 CFR 52.17(a), 10 CFR 100.20(c), and 10 CFR 100.21 (d) require that the

NRC take into account the physical characteristics of the site (including seismology,

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meteorology, geology, and hydrology) when determining the acceptability of a site for a nuclear

reactor.

Channel diversion or realignment poses the potential for flooding or for an adverse effect on the

supply of cooling water for a nuclear power plant(s) of a specified type (or falling within a PPE)

that might be constructed on the proposed site. Therefore, it is one physical characteristic that

must be evaluated pursuant to 10 CFR 100.21(d). The consideration of the 10 CFR 100.21 (cl)

criteria in this evaluation provides reasonable assurance that the effects of flooding caused by

channel diversion resulting from severe natural phenomena would pose no undue risk to the

type of facility proposed for the site.

In those cases for which a reactor design is not specified, the ESP applicant may instead

provide a PPE to characterize a facility or facilities for comparison with the hydrologic

characteristics of the site. An ESP applicant can develop a PPE for a single type of facility or a

group of candidate facilities by selecting the limiting values of the relevant parameters.

To determine whether the applicant met the requirements of 10 CFR Parts 52 and 100, as they

relate to channel diversion, the staff used the following specific criteria:

* A description of the applicability (potential adverse effects) of stream channel diversions

is necessary.

* Historical diversions and realignments should be discussed.

* The topography and geology of the basin and its applicability to natural stream channel

diversions should be addressed.

* If applicable, the safety consequences of diversion and the potential for high- or lowwater levels, caused by upstream or downstream diversion, to adversely affect safetyrelated facilities, water supply, or the UHS should be addressed. RG 1.27, "Ultimate

Heat Sink for Nuclear Power Plants," issued January 1976, provides guidance on

acceptable UHS criteria.

2.4.9.3 Technical Evaluation

The staff developed a basic understanding of the geomorphology of the region during the site

visit on May 11, 2004. The staff's search did not produce any evidence of major channel

diversion in Salt Creek or the North Fork of Salt Creek. Channel diversions usually occur in

relatively flat, deep alluvial plains where the river channel meanders greatly.

Section 2.4.7 of this SER evaluates channel diversion resulting from ice effects, and

Section 2.4.11 of this SER evaluates channel diversion resulting from low-water conditions.

SSAR Section 2.4.9 did not provide details of historical or geological evidence of possible

diversions and meandering of Salt Creek and the North Fork of Salt Creek upstream of the ESP

site. The staff contacted the USGS Illinois Water Science Center to obtain references of

channel diversion studies carried out on Salt Creek and the North Fork of Salt Creek. The

USGS Illinois Water Science Center stated in email communication to the staff that no channel

diversion studies had been carried out on these streams.

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To evaluate the impact of channel diversion on the ESP facility, the staff considered a

hypothetical scenario in which both the North Fork of Salt Creek and the Salt Creek arms

migrated, eliminating subsequent inflow into Clinton Lake. Since channel migration usually

happens during high-flow or flood events, the staff assumed that Clinton Lake would be at a

normal pool level, should channel migration occur. Subsequent to channel migration, inflow into

Clinton Lake would stop, and water surface elevation would start to decrease because of losses

caused by natural and forced evaporation, downstream release, and ground water recharge.

During the initial period following channel migration, it is expected that the submerged UHS

pond would remain intact. The staff determined that sufficient time would be available following

the onset of channel migration to safely shut down the ESP facility using the UHS system. The

staff concluded, therefore, that, even if channel migration were to stop all inflow into Clinton

Lake, it would not adversely affect the safety of the ESP facility.

2.4.9.4 Conclusions

As set forth above, the applicant provided sufficient information pertaining to the identification

and evaluation of channel diversion at the site. SSAR Section 2.4.9 conforms to Section 2.4.9

of RS-002, Attachment 2, with regard to this objective.

Section 2.4.9 of RS-002, Attachment 2, provides that the SSAR should address the

requirements of 10 CFR Parts 52 and 100 as they relate to identifying and evaluating channel

diversion at the site. Although the applicant did not specifically address the above regulations in

SSAR Section 2.4.9, the staff concludes that, by conforming to Section 2.4.9 of RS-002,

Attachment 2, it has met the requirement to identify and evaluate channel diversion at the site

with respect to 10 CFR 52.17(a) and 10 CFR 100.20(c). Further, the applicant considered the

most severe natural phenomena that have been historically reported for the site and

surrounding area in establishing design-basis information related to channel diversions, with

sufficient margin for the limited accuracy, quantity, and period of time in which the historical data

have been accumulated.

2.4.10 Flooding Protection Requirements

The proposed ESP site grade is at an elevation of 735 ft MSL.

2.4.10.1 Technical Inform7ation in the Application

SSAR Section 2.4.3.6 estimated the design-basis flood elevation at the ESP site to be 713.8 ft

MSL. This elevation included the effects of flooding from a PMF caused by the PMP over the

Clinton Dam's drainage area, wind setup, and wave runup. The applicant stated that all safetyrelated SSCs for the ESP facilities would be located at the existing site grade of 735 ft MSL.

The applicant, therefore, concluded that the only safety-related ESP facility structure that could

be affected by flooding in Clinton Lake would be the new ESP facility's UHS intake structures.

The applicant stated in the SSAR that it would design the ESP facility UHS intake for flood

protection of all safety-related equipment located within the intake structures.

The applicant also stated that the design of the ESP facility's UHS intake would consider wind

wave forces caused by a sustained 48-mph overland wind speed acting on the PMF water

surface elevation, as well as those caused by a sustained 67-mph overland wind speed acting

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on the normal water surface elevation in Clinton Lake. The applicant noted that the design

would consider both breaking and nonbreaking waves.

The ap,:licant stated that the flooding effects of local PMP are design related and will be

considered at the COL stage.

The staff requested, in RAI 2.4.10-1, that the applicant discuss the difference in methods it used

to determine the design wind speeds of 40 mph, mentioned in SSAR Sections 2.4.3.6 and

2.4.10, and the design wind speeds of 48 mph and 67 mph, mentioned in SSAR Section 2.4.10.

In response to RAI 2.4.10-1, the applicant stated that the CPS USAR considered the 40-mph

overland wind speed to act on the PMF water surface elevation. The applicant also stated that

the design of the circulating water screenhouse for the CPS Unit 1 considered a 48-mph

overland wind speed coincident with the PMF water surface elevation. The applicant noted that

use of these design wind speeds did not result in any safety issues and concluded that the CPS

plant would not flood under any circumstances. The applicant also stated that the ESP site is

considered to be a dry site, consistent with Condition 3 of Section 2.4.3 of RS-002,

Attachment 2. The applicant further stated that the operation of the ESP facility would not

impact ihe potential for flooding at the existing dam or at the plant site. Therefore, the applicant

concluded that the calculation of wave runup effects on PMF water surface elevations is

inconsequential. The applicant stated that the ESP analyses retained the design wind speeds

to be cc nsistent with the previously completed CPS USAR analyses.

The applicant stated that a review of the more recent ANSI/ANS-2.8-1992 information indicated

that a wind speed of somewhat greater magnitude (i.e., 52 mph) is more appropriate for

estimating wave runup height coincident with PMF water surface elevation. The applicant

provided a revision to SSAR Sections 2.4.3.6 and 2.4.10 in the RAI response, using a wind

speed of 52 mph.

In Revision 4 of the SSAR, the applicant stated that the maximum hydrostatic PMF water

surface elevation is 709.8 ft MSL and, combined with other effects, the maximum water level of

Clinton l ake near the ESP facility is 716.5 ft MSL. The applicant noted that the ESP facility

grade is approximately 19 ft above the maximum combined effects elevation and 25 ft above

the hydrostatic PMF elevation. The applicant stated that the only safety-related equipment

below these elevations is the new ESP intake structure, which would be designed with

adequate flooding protection.

2.4.10.2 Regulatory Evaluation

As required by 10 CFR 100.20(c), the PMF must be estimated using historical data. Meeting

this requirement provides reasonable assurance that the effects of flooding or a loss of flooding

protection, resulting from severe natural phenomena, would pose no undue risk to the type of

facility proposed for the site.

In those cases for which a reactor design is not specified, the ESP applicant may instead

provide Et PPE to characterize a facility or facilities for comparison with the hydrologic

characteristics of the site. A PPE can be developed for a single type of facility or a group of

candidate facilities by selecting the limiting values of the relevant parameters.

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To determine whether the applicant met the requirements of 10 CFR Parts 52 and 100, as they

relate to flooding protection, the staff used the following specific criteria:

* The applicability (potential adverse effects) of a loss of flooding protection should be

described.

* Historical incidents of shore erosion and flooding damage should be discussed.

* The topography and geology of the basin and its applicability to damage as a result of

flooding should be addressed.

* If applicable, the safety consequences of a loss of flooding protection and the potential

to adversely affect safety-related facilities, water supply, or the UHS should be

addressed. RG 1.27 provides guidance on acceptable UHS criteria.

2.4.10.3 Technical Evaluation

During its review of the SSAR, the staff estimated the maximum water surface elevation at the

site for the design-basis flood to be 721.7 ft MSL. The NRC staff independently estimated this

value by combining the effects of PMF, coincident wind wave activity, and wind setup. Both

coincident wave activity and storm surge require use of a wind speed, which was conservatively

estimated by the staff to be 100 mph. This value was based upon the PMWS, as defined by

ANSI/ANS 2.8-1992, and was recommended for the location of the site being within 150 miles of

the Great Lakes. The staff estimated the local intense precipitation rate for the ESP site to be

18.15 inlh in Section 2.4.2.3 of this SER. Table 2.4-2 of this SER in this report provided the

complete hyetograph for the 6-hour local intense precipitation. Except for the new ESP facility

UHS intake structures, the ESP site grade (elevation 735 ft MSL) is above the design-basis

flood elevation.

The staff's evaluation assumed that all safety-related SSCs would be placed at or above the

applicant-stated ESP site grade, except for the new ESP facility UHS intake structures, which

are known to be located below plant grade. As stated previously in Sections 2.4.2.3 and 2.4.3.3

of this SER, the COL applicant will need to design the ESP facility's intake structures to

withstand the combined effects of PMF, coincident wind wave activity, and wind setup. This is

COL Action Item 2.4-3 as stated in Section 2.4.2.3 of this SER.

2.4.10.4 Conclusions

As set forth above, the applicant has provided sufficient information pertaining to identifying and

evaluating flooding protection requirements at the site. SSAR Section 2.4.10 conforms to SRP

Section 2.4.10 as applicable to an ESP site.

The review guidance in SRP Section 2.4.10 provides that the SSAR should address 10 CFR

Parts 50 and 100, as they relate to identifying and evaluating flooding protection requirements

at the site. Although the applicant did not specifically address the above regulations in SSAR

Section 2.4.10, the staff concludes that by conforming to SRP Section 2.4.10 the applicant has

met the requirements of flooding protection at the site with respect to 10 CFR 52.17(a) and

10 CFR 100.20(c)(3), except as noted in Section 2.4.10.3 above. Further, the applicant

considered the most severe natural phenomena that have been historically reported for the site

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and surrounding area in establishing design-basis information for flood protection, with sufficient

margin for the limited accuracy, quantity, and period of time in which the historical data have

been accumulated.

2.4.11 Low-Water Considerations

The ESP site is adjacent to Clinton Lake, which provides cooling water for the current CPS

Unit 1 and would provide cooling water for the proposed ESP facility. Events, such as low lace

elevation, seiches, wind-induced set down, and intake blockages from sediment or ice, may

reduce or limit the availability of cooling water at the site.

Clinton Lake, created by the Clinton Dam, would provide the normal cooling makeup water

supply ior the ESP facility. The submerged UHS pond, created by a submerged dam across the

North Fork of Salt Creek within Clinton Lake, would provide 30-day emergency cooling make ip

water for the ESP facility's UHS system.

Normal operation of the ESP facility would use a cooling tower(s), operated with water drawn

from a cooling tower basin(s). The basin(s) in turn would receive makeup water from the lake.

2.4.11. ,' Technical Information in the Application

The applicant used a design drought with a recurrence interval of 100 years to determine the

minimum water surface elevation in Clinton Lake. This analysis considered factors that affec:

the water surface elevation in Clinton Lake, such as runoff, evaporation, and forced

evaporation.

The applicant stated that a drawdown analysis of Clinton Lake for the original CPS, which

consisted of two 992 MWe units operating at a 70-percent load factor, was performed. The

applicant's analysis assumed the starting water surface in Clinton Lake to be equal to the

normal pool water surface elevation of 690 ft MSL. The drawdown analysis assumed a

minimum reservoir release rate of 5 cfs. This analysis also assumed a seepage loss rate of

0.5 percent of the lake capacity per month. The applicant stated that the original CPS

drawdov/n analysis evaluated the ability of Clinton Lake to provide cooling tower(s) makeup

water to the ESP facility in addition to meeting the cooling water requirements of the existing

CPS Un t 1. The applicant stated that the previous forced-evaporation rate estimate was based

on heat rejection from CPS. In the ESP facility evaluation, the applicant adjusted this estimate

by (1) dividing the original estimate by two, since only one of the two units originally planned

was constructed, (2) dividing by 0.7 to conservatively adjust the forced-evaporation rate for a

1 00-percent load factor, and (3) multiplying by 1.2 to conservatively adjust for the additional

heat load caused by the power uprate of the existing CPS Unit 1.

The applicant stated that the new drawdown analysis performed for the ESP facility determined

that the quantity of water available for cooling tower(s) makeup during a 50-year drought would

be 15,808 gpm, and the quantity available during a 1 00-year drought would be 10,222 gpm.

These available water quantities would maintain the water surface elevation in Clinton Lake at

or above the CPS minimum required water surface elevation of 677 ft MSL while both the CP'S

Unit 1 and the ESP facility were in operation.

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The applicant stated that the available water quantity during drought conditions would be

sufficient to provide makeup water for both the safety and nonsafety cooling systems' cooling

towers for some -of the reactor designs being considered for the site which use wet cooling. The

applicant stated that the bounding reactor plant cooling system makeup demand would require

the use of a wet/dry cooling tower for a turbine plant's cooling systems to reduce either the

evaporation rate or the heat discharge to the lake, so that the demand would not exceed the

available water supply from Clinton Lake.

The applicant stated that surges, seiches, or tsunami conditions were not likely to occur in

Clinton Lake or the submerged CPS UHS pond because no large body of water exists near the

ESP site. Therefore, the applicant concluded that these conditions would not produce or affect

low-water conditions at the ESP site.

The applicant stated that it evaluated the effects of drought on water surface elevations in

Clinton Lake to determine whether the operation of the existing CPS plant would be sustained

during dry periods. This analysis established a minimum water surface elevation of 677 ft MSL

in Clinton Lake for the safe operation of the CPS plant. The applicant stated that a water

surface elevation below 677 ft MSL in Clinton Lake would require a shutdown of the CPS plant

to avoid loss of safety-related plant cooling water.

The applicant stated that the drawdown analysis for the ESP site accounted for inflows

generated from direct rainfall and storm runoff, normal evaporation, forced evaporation caused

by plant cooling and resulting in increased lake water temperature, seepage losses, and a

minimum discharge from the dam for downstream flow requirements. This drought analysis was

based on the existing, uprated CPS, which consists of one 1138.5 MWe BWR operating at

100-percent load, as well as on the PPE value for ESP plant consumption.

The applicant stated that the results of the drawdown analysis established the minimum lake

water surface elevation during 50- and 100-year droughts as 685 ft MSL and 681.4 ft MSL,

respectively. The applicant stated that both of these minimum lake water surface elevations

were above the CPS minimum safety-related lake water surface elevation of 677 ft MSL.

The applicant stated that, based on inquiries to Federal and State regulatory agencies, no future

plans exist to use Salt Creek water upstream of Clinton Lake. The applicant also stated that

any future use of Salt Creek water upstream of the ESP site would not affect the availability of

safety-related cooling water supply because of the submerged condition of the UHS pond.

The applicant stated that a new intake structure located next to the existing CPS intake

structure would supply the water required for the ESP facility. This new intake would use

Clinton Lake as its source of water and would also have the capability to draw water from the

existing submerged UHS pond as an alternate source of makeup water for the safety-related

cooling tower(s). The new intake structure would house traveling screens, fire pumps, cooling

tower makeup pumps, and safety-related cooling tower makeup pumps. The applicant stated

that the makeup water pumps for the safety-related cooling tower(s) would be designed to

operate with a suction water surface elevation at least 1 ft below the lowest water surface

elevation to which the submerged UHS pond could fall after 30 days of operation without

makeup water.

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The applicant stated that, in the event of a severe drought that could reduce the water surface

elevation in Clinton Lake to 677 ft MSL or below, the ESP facility would be shut down.

The applicant stated that the essential service water cooling tower(s) would provide the UHS

cooling function for the ESP facility. These cooling tower(s) would require makeup water from

Clinton Lake. The applicant stated that the makeup water requirements range from 250 gpm

during normal operation up to a maximum of 700 gpm during a normal shutdown. The total

makeup water requirement for postaccident shutdown and cooldown for a 30-day period is

approximately 21.4 million gallons or an average makeup requirement of 495.2 gpm over the

30-day period.

The applicant stated that, in the unlikely event of a failure of the main dam and complete loss of

Clinton ILake, the existing submerged UHS pond would supply makeup water to the ESP

facility's safety-related cooling tower(s). The applicant stated that the existing CPS UHS pond

is a submerged pond within Clinton Lake formed by the construction of a submerged dam

across the North Fork of Salt Creek. The submerged UHS pond is adjacent to the ESP facilily's

intake structure where the makeup water pumps for the ESP facility's safety-related cooling

tower(s) would be located. The applicant stated that the maximum return water temperature

from the ESP facility's safety-related cooling tower(s) would be 94.7 IF, based on a 10 OF

approach and a maximum wet bulb temperature of 84.7 OF. The applicant also stated that

blowdovwn from the ESP facility's safety-related cooling tower(s) would be discharged to the

existing CPS discharge flume. The applicant stated that credit was taken for return of the

blowdovin water volume to the submerged UHS pond when determining the capability of the

submerged UHS pond to supply water to the CPS and the ESP facility.

The applicant stated that the submerged UHS pond has sufficient water storage capacity for

shutdown operation of the CPS, as well as providing makeup water for the ESP facility

shutdown for a period of at least 30 days and beyond, if necessary. The applicant stated that it

might be necessary to reduce the allowable accumulated sediment volume in the submerged

UHS pond to provide adequate additional capacity for makeup water to the ESP facility's safetyrelated cooling towers.

The applicant stated that it determined the amount of makeup water required by the ESP

facility's safety-related cooling tower(s) for a 30-day period based on the reactor plant within the

applicant's PPE possessing the bounding UHS heat load. The amount of water that would be

evaporated to provide postaccident shutdown cooling is 2.87 million ft3. The applicant

conservatively increased this water quantity by one-third to provide allowance for blowdown to

limit the concentration of impurities in the cooling tower basin to four times the concentration in

the lake. The applicant stated that this number is conservative since blowdown would be

terminated during an accident and normal operation would be at a concentration ratio higher

than 4.

The applicant stated that the original design of the submerged UHS pond was based on the

heat load from the shutdown of one CPS unit under LOCA conditions and one CPS unit under

LOOP conditions, with a total integrated heat load of 1 80,455x1 O6 BTU for 30 days. The heal

load from the single, uprated CPS unit is 99,973x1 6 BTU for 30 days under LOCA or LOOP

conditions. The applicant estimated that this value is approximately 55 percent of the CPS

submerc.ed UHS pond design heat load, thereby indicating that considerable margin is

available. The applicant stated that a review of the original CPS submerged UHS pond design

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revealed that withdrawal of water to provide makeup for the ESP facility's safety-related cooling

tower(s) would have only a small impact on heat transfer from the submerged UHS pond.

The applicant stated that the reliability of the submerged UHS pond to provide a supply of water

during drought conditions is enhanced by the location of the pond with respect to the adjacent

ground water table. The applicant stated that, because the pond is normally submerged in

Clinton Lake and the normal water surface elevation sets the base level for the adjacent ground

water during low flow or loss of the main dam, water stored in upstream alluvium would

replenish water in the submerged UHS pond. The applicant further stated that the Salt Creek

watershed would also provide a source of water for long-term cooling following loss of the

Clinton Lake dam. The applicant estimated that the watershed can supply 400 gpm at the

minimum mean daily flow and 16,150 gpm at the minimum mean monthly flow. The required

makeup flow to the ESP facility's UHS cooling tower(s) during normal operation would be

250 gpm and would bound the requirement after shutdown was achieved.

The applicant stated that it monitors the submerged UHS pond for sediment accumulation

periodically and after a major flood passes through Clinton Lake. The applicant stated that,

after the ESP facility is constructed, it might reduce the allowable sediment accumulation in the

submerged UHS pond.

In Revision 2 of the SSAR, the applicant described an assessment similar to the one described

above in order to determine the amount of cooling water available during drought periods. The

applicant stated that the excess available water on an annual average basis after satisfying

CPS consumptive demand is 1,300 ac-ft/month (9,500 gpm) during the 1 00-year drought event

and 2,000 ac-ft/month (15,100 gpm) during the 50-year drought event.

2.4.11.2 Regulatory Evaluation

SSAR Table 1.5-1 shows the applicant's conformance to the NRC RGs. In RAI 1.5-1, the staff

asked the applicant to provide a comprehensive listing of NRC regulations applicable to its ESP

SSAR. In its response to this RAI, the applicant indicated that RS-002, Attachment 2, identifies

the NRC regulations applicable to its ESP SSAR. Section 2.4 of RS-002, Attachment 2,

describes the methods of review and the applicable acceptance criteria that the staff uses to

develop its findings and conclusions related to the hydrologic aspects of site characterization for

an ESP. Although the applicant did not indicate how the individual sections of SSAR

Section 2.4 address the hydrology-related site suitability criteria in RS-002, Attachment 2, the

staff reviewed this portion of the application for conformance with the applicable regulations and

considered the corresponding regulatory guidance, as identified below.

Acceptance criteria for this section relate to the following regulations and criteria:

* 10 CFR Parts 52 and 100 require that hydrologic characteristics be considered in the

evaluation of the site.

* 10 CFR 100.23 requires, in part, that siting factors to be evaluated must include the

cooling water supply.

The regulations in 10 CFR Parts 52 and 100 require, in part, that the evaluation of a nuclear

power plant site consider hydrologic characteristics. To satisfy the requirements of 10 CFR

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Parts 52 and 100, the applicant's SSAR should describe the surface and subsurface

hydrological characteristics of the site and region. In particular, the UHS for the cooling water

system may consist of water sources that could be affected by the site's hydrologic

characteristics, resulting from river blockage or diversion, tsunami runup and drawdown, and

dam failure. These characteristics may reduce or limit the available supply of cooling water fbr

safety-related SSCs. Meeting the requirements of 10 CFR Parts 52 and 100 provides

assurance that severe hydrologic phenomena, including low-water conditions, would pose nc

undue risk to the type of facility proposed for the site.

In those cases for which a reactor design is not specified, the ESP applicant may instead

provide a PPE to characterize a facility or facilities for comparison with the hydrologic

characteristics of the site. A PPE can be developed for a single type of facility or a group of

candidate facilities by selecting the limiting values of the relevant parameters.

As required by 10 CFR 100.23, siting factors, including cooling water supply, must be evaluated

for a nuclear power plant site. The evaluation of the emergency cooling water supply for a

nuclear power plant(s) of a specified type (or falling within a PPE) that might be constructed on

the proposed site should consider river blockages, diversions, or other failures that may block

the flow of cooling water, tsunami runup and drawdown, and dam failures.

The regulations at 10 CFR 100.23 apply to this section because the UHS for the cooling water

system consists of water sources that are subject to natural events that may reduce or limit the

available supply of cooling water (i.e., the heat sink). Natural events, such as river blockages,

diversions, or other failures that may block the flow of cooling water, tsunami runup and

drawdovin, and dam failures, should be conservatively estimated to assess the potential for

these characteristics to influence the design of those SSCs important to safety for a nuclear

power plant(s) of a type specified by the applicant (or falling within a PPE) that might be

constructed on the proposed site. The available water supply should be sufficient to meet the

needs ol the plant(s) to be located at the site; those needs may fall within a PPE (e.g., the

stored water volume of the cooling water ponds), if an applicant uses that approach.

Specifically, those needs include the maximum essential design cooling water flow, as well as

the maximum design flow for normal plant needs at power and at shutdown.

The staff uses the specific criteria discussed in the paragraphs below to assess the applicant's

ability to meet the requirements of the hydrologic aspects of the above regulations. Acceptance

is based primarily on the adequacy of the UHS to supply cooling water for normal operation,

anticipated operational occurrences, safe shutdown, cooldown (first 30 days), and long-term

cooling (periods in excess of 30 days) during adverse natural conditions.

Low Flow in Rivers and Streams

For essential water supplies, the low-flow/low-level design for the primary water supply source

is based on the probable minimum low flow and low level resulting from the most severe

drought that can reasonably be considered for the region. The low-flow/low-level site

parameters for operation should not allow shutdowns caused by inadequate water supply to

trigger the frequent use of emergency systems.

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Low Water Resulting from Surges, Seiches, or Tsunami

For coastal sites, the applicant should postulate the appropriate probable maximum hurricane

wind fields at the ESP stage to estimate the maximum winds blowing offshore, thus creating a

probable minimum surge level. The applicant should estimate low water levels on inland ponds,

lakes, and rivers caused by surges based on the probable maximum winds oriented away from

the plant site. The same general analysis methods discussed in Sections 2.4.3, 2.4.5, and 2.4.6

of RS-002, Attachment 2, are applicable to low-water estimates resulting from the various

phenomena discussed. If the site is susceptible to such phenomena, minimum water levels

resulting from setdown (sometimes called runout or rundown) from hurricane surges, seiches,

and tsunami should be verified at the COL or CP stage to be higher than the intake design basis

for essential water supplies.

Historical Low Water

If historical flows and levels are used to estimate design values by inference from frequency

distribution plots, the applicant should present the data used to allow an independent

determination. The applicant may use the staff-accepted data and methods of NOAA, USGS,

SCS, USBR, and USACE.

Future Controls

This section is acceptable if water use and discharge limitations (both physical and legal) that

are already in effect or under discussion by the responsible Federal, State, regional, or local

authorities, and that may affect the water supply for a nuclear power plant(s) of a type specified

by the applicant (or falling within a PPE) that might be constructed on the proposed site, have

been considered and are substantiated by reference to reports of the appropriate agencies.

The design basis should identify and take into account the most adverse possible effects of

these controls to ensure that essential water supplies are not likely to be negatively affected in

the future.

2.4.11.3 Technical Evaluation

The staff performed two independent analyses to determine if the normal plant heat sink

(NPHS) might suddenly and/or frequently fail, which would result in excessive reliance of the

ESP facility on the UHS. Failure was defined as the lake water surface elevation dropping

below the level that would require shutdown and possible reliance on the UHS. One analysis

considered the frequency that the lake water surface elevation would drop below a specific

level. The other analysis evaluated the maximum rate at which the lake water surface elevation

could drop.

In response to RAI E5.2-1 (issued to request additional information related to the applicant's

ER), the applicant described a numerical calculation of lake water surface elevation changes for

the 24-year period of record from June 1, 1978, to April 31, 2002. The applicant provided

information on the predicted pool elevation, assuming the ESP facility had been operating

during this period. The applicant used a water budget approach, wherein the change in lake

storage results from an imbalance between inflows and outflows. The applicant considered

inflows from direct precipitation onto the lake and upstream drainage. Outflow was assumed to

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be the sum of natural evaporation, induced evaporation caused by the existing CPS Unit 1, and

direct evaporation from the ESP facility operating with wet cooling towers.

To estimate the tributary inflows, the applicant's analysis estimated monthly average runoff yield

coefficients (ratio of runoff to rainfall). These coefficients were multiplied by the recorded rainfall

during the period of record to generate a runoff record. These estimates would hot necessarily

provide conservative estimates in warm dry years and, therefore, the staff applied a different

approach.

The staff found an adjacent streamflow gauge on Kikapoo Creek at Waynesville, Illinois. The

drainage of Kikapoo Creek is adjacent to the North Fork of Salt Creek and is located to the

northwest of the ESP site. The distance of the Kikapoo Creek gauge at Waynesville from the

Clinton Dam is approximately 15.3 miles. This gauge is minimally affected by streamflow

regulation and is comparable in the size of its contributing area (227 mi2) to that of the drainage

area (2139.2 mi2) contributing flow to Clinton Lake. To estimate inflows into Clinton Lake, the

staff scaled the streamflow observed at Kikapoo Creek by the ratio of contributing area at

Clinton Dam to the contributing area at the Waynesville gauge. The time period of the

estimated inflow record is January 28, 1948, to September 30, 2001.

The staff performed a bounding analysis and found the magnitude of low-water conditions to be

more severe than those predicted by the applicant. However, the lack of pool elevation data

made it impossible for the staff to perform an adequate calibration and verification of the

approach. Because of this limitation, the staff considered the results to be inconclusive. The

second analysis performed by the staff assessed the maximum rate at which the lake water

surface elevation could be expected to drop.

The stall assumed that the induced evaporation rate caused by the existing CPS Unit 1 was

equal to the total reject heat load (i.e., the reject heat load was entirely converted to latent heat

of water vapor) or 38 cfs of evaporation. As some of the heat load would be lost to back

radiation and conductive heat exchange, this is a conservative assumption. From the PPE

table, the consumptive water loss of the ESP facility was estimated to be 70.2 cfs. The highest

monthly evaporation rate recorded by Roberts and Stall (1967) was 8.38 in. for July 1936. Afler

correcting for lake area, the staff's analysis resulted in a conservative estimate of the maximum

drop in the lake water surface elevation of 4.85 ft/mo.

At this rate of decline, the staff determined that the drop of the lake water surface elevation

would be gradual enough for the operators to react and safely shut down the ESP facility before

the minimum operating threshold was reached.

The applicant stated in SSAR Section 2.4.11.1 that, for some of the reactor designs under

consideration for the ESP facility, the available water in Clinton Lake would be sufficient for both

safety-related and normal turbine cooling water requirements. However, the applicant stated

that the cooling makeup water demand for the bounding reactor within the applicant's PPE

would require the use of a wet/dry hybrid cooling tower system for normal turbine cooling. In

Section 2.4.1.3 of this SER, the staff identified the need (DSER Open Item 2.4-2) for a

schematic representation of the complete ESP facility UHS system including the intake, piping,

any potential storage basins, the UHS cooling loop, and the cooling tower(s). The staff

determined that this schematic should clearly show all components and the water flow, including

discharges through these components.

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The applicant stated in SSAR Section 2.4.11.5 that the makeup water pumps for the safetyrelated cooling tower(s) would be designed to operate with a suction water surface elevation at

least 1 ft below the lowest water surface elevation that the submerged UHS pond could fall to

after 30 days of operation without makeup to the pond. The staff identified several open items

in DSER Section 2.4.8.3 related to the applicant's ESP facility water requirements and lake

drawdown estimation, especially under severe drought conditions. The applicant stated that, in

the event of a severe drought that may reduce the water surface elevation in Clinton Lake to

677 ft MSL or below, station shutdown operation would be followed for the ESP facility. The

staff had planned to include the water surface elevation of 677 ft MSL in Clinton Lake as the

shutdown water surface elevation for the ESP facility in a permit condition. The staff

determined that the requirement for an ESP facility UHS is dependent on the selected reactor

type, which has not been determined at the ESP stage. In the event that the reactor type

selected for the ESP facility requires a UHS, the COL applicant will need to develop a plant

shutdown protocol when the water surface elevation in Clinton Lake falls to 677 ft MSL. This is

COL Action Item 2.4-11.

The staff independently estimated the volume of available water in the submerged UHS pond

that may be used for the combined operation of the CPS and the ESP facility's UHS systems

based on the applicant's response to DSER Open Items 2.4-9, 2.4-11,2.4-14, 2.4-16, and

2.4-17. Resolution of the open items mentioned above resolves confirmatory Item 2.4-1. The

staff's estimate of minimum excess water storage capacity in the submerged UHS pond after

accounting for water required by the CPS UHS consumptive use, the ESP facility UHS makeup,

sedimentation, fire protection, and icing was approximately 318 ac-ft, as stated in

Section 2.4.8.3 of this SER. The monitoring and dredging frequencies for the submerged UHS

pond will be determined at the COL stage, as stated by COL Action Item 2.4-10 in

Section 2.4.8.3 of this SER.

2.4.11.4 Conclusions

As set forth above, the applicant provided sufficient information pertaining to the identification

and evaluation of the low-water considerations of the site. SSAR Section 2.4.11 conforms to

Section 2.4.11 of RS-002, Attachment 2 with regard to this objective.

Section 2.4.11 of RS-002, Attachment 2, provides that the SSAR should address the

requirements of 10 CFR Parts 52 and 100 as they relate to identifying and evaluating the lowwater considerations of the site. Although the applicant did not specifically address the above

regulations in SSAR Section 2.4.11, the staff concludes that, by conforming to Section 2.4.11 of

RS-002, Attachment 2, it has met the requirements for low-water conditions with respect to

10 CFR 52.17(a) and 10 CFR 100.20(c), except as noted in Section 2.4.11.3 of this SER.

Further, the applicant considered the most severe natural phenomena that have been

historically reported for the site and surrounding area in establishing design-basis information

for low-water conditions, with sufficient margin for the limited accuracy, quantity, and period of

time in which the historical data have been accumulated.

2.4.12 Ground Water

The EGC ESP site lies within the Central Lowlands Physiographic Province. Aquifers in the

Central Lowlands occur in unconsolidated sand and gravel of the Quaternary age and

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consolidated sandstone, limestone, and dolomite of the Paleozoic age. At the proposed EGC

ESP site, alluvium along the floodplains overlays glacial drift deposits.

2.4.12. 1 Technical Information in the Application

The applicant provided a description of regional and site hydrogeology and ground water

conditions in Section 2.4.13 of the SSAR. The applicant generally used the CPS USAR to

derive the information presented in the SSAR, including the subsurface site characterization

performed for the two previously proposed CPS units, as well as the ongoing monitoring for the

constructed CPS Unit 1. The applicant reported that it obtained an additional four borings wilhin

the ESP footprint as part of its pre-ESP application activities; these borings further confirm the

site geologic conceptual model presented previously in the USAR.

The applicant described the regional geologic stratigraphy of unconsolidated alluvium and

glacial drift and outwash over a consolidated sedimentary bedrock. Local ESP site conditions

are consistent with the regional conditions. The following paragraphs summarize the applicant's

description of the regional and local hydrogeologic characteristics of various strata.

The alluvium, composed of varying amounts of clay, silt, sand, and gravel, is located within

floodplains around stream corridors. In locations where the alluvium contains relatively thick

lenses cf sand and gravel, it can represent a viable water-bearing aquifer. Water in the alluvium

is generally unconfined. Borings in the vicinity where the submerged CPS UHS pond is now

located recorded alluvial deposits from 6 ft to 48 ft.

A thick layer of glacial drift and outwash underlies much of the region. The total thickness of the

glacial drift and outwash ranges from less than 50 ft to more than 400 ft. This stratum of

Wisconsinan-aged, Illinoian-aged, and Kansan-aged deposits is composed of heterogeneous

mixtures of clay, silt, sand, and gravel. Drift material is dominated by clayey silts or silty clays,

whereas outwash materials are dominated by sand and gravel. Water in the drift and outwash

is generally confined. Regional ground water movement is dominated by flow through

unconsolidated glacial outwash in glacial bedrock valleys, such as the Mahomet Bedrock

Valley, the axis of which lies near the ESP site. The glacial outwash provides the source of

much of the ground water supply used regionally. At the ESP site, glacial drift and outwash

occur a few feet below the surface. Based on strata exposed during excavation of the CPS

facility arid borings conducted for the CPS facility and the ESP application, the applicant

identified the depth and thicknesses of the Wisconsinan, Illinoian, and Kansan strata. The

Wisconsinan deposits extend from a few feet below the surface to about 698 ft MSL. The

Illinoian deposits extend from the bottom of the Wisconsinan deposits to 572 ft MSL. The total

thickness of the three drift layers average 237 ft. At the ESP site, water in the Wisconsinan

stratum is unconfined, whereas water in the Illinoian and Kansan strata is confined.

The bedrock beneath the glacial drift and outwash is Pennsylvanian-aged shale, siltstone,

limestone, and underclay. Valleys in the bedrock formed by geologic processes and filled with

glacial drft and outwash are significant hydrogeologic structures throughout the region. Water

in the bedrock formations is under confined conditions.

The dominant source of ground water for regional water use is from the glacial outwash in

bedrock valleys. Based on the CPS USAR, the applicant stated that 65 percent of public

ground water supplies are pumped from the Mahomet Bedrock Valley aquifer. Within 15 miles

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of the site, alluvial aquifers provide the public water supply only for Heyworth. No public water

supply within the 15-mile radius of the proposed site uses bedrock wells. The applicant stated

that the ESP facility will not use groundwater for either normal 'or safety-related plant

operations.

The applicant stated that the inundation of Salt Creek and the North Fork of Salt Creek resulted

in changes to the local water table, with ground water flowing toward Clinton Lake. The

presence of Clinton Lake's relatively stable pool elevation represents an important boundary

condition in describing the flow of ground water in the upper strata from the ESP site towards

the lake.

The applicant reported the results of field, as well as laboratory, estimates of permeability.

Laboratory estimates of permeability were based on grain size analysis and constant-head or

falling-head permeability tests with 18 soil samples from various locations and geologic units.

The applicant used one of these permeability estimates with its associated porosity and the

water table gradient near the ESP site to estimate the velocity in the upper aquifer to be

2.5x1 0.3 feet per day (ft/d).

The applicant proposed to maintain an inward piezometric gradient to any structure that may

receive water to ensure ground water movement into the structure rather than out of the

structure. The applicant also proposed a design in which inward gradients would not be

reversed over the range of observed water table fluctuations.

The SSAR described the ground water flowpath from the ESP site in limited detail. The SSAR

also did not specify precise locations of the ESP facility. The staff requested the applicant, in

RAI 2.4.1-1, to provide locations for the proposed ESP facility. Section 2.4.1.1 of this SER

discusses the applicant's response to the RAI.

No changes were made in Section 2.4.13 in Revision 4 of the application.

2.4.12.2 Regulatory Evaluation

SSAR Table 1.5-1 shows the applicant's conformance to the NRC RGs. In RAI 1.5-1, the staff

asked the applicant to provide a comprehensive listing of NRC regulations applicable to its ESP

SSAR. In its response to this RAI, the applicant indicated that RS-002, Attachment 2, identifies

the NRC regulations applicable to its ESP SSAR. Section 2.4 of RS-002, Attachment 2,

describes the methods of review and the applicable acceptance criteria that the staff uses to

develop its findings and conclusions related to the hydrologic aspects of site characterization for

an ESP. Although the applicant did not indicate how the individual sections of SSAR

Section 2.4 address the hydrology-related site suitability criteria in RS-002, Attachment 2, the

staff reviewed this portion of the application for conformance with the applicable regulations and

considered the corresponding regulatory guidance, as identified below.

Acceptance criteria for this section relate to the following regulations and criteria:

10 CFR Parts 52 and 100 require that the site evaluation consider hydrologic

characteristics.

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* 10 CFR 100.23 sets forth the criteria to determine the suitability of design bases for a

nuclear power plant(s) of specified type (or falling within a PPE) that might be

constructed on the proposed site with respect to the seismic characteristics of the site. It

also requires that the adequacy of the cooling water supply for emergency and long-term

shutdown decay heat removal be ensured, taking into account information concerning

the physical, including hydrological, properties of the materials underlying the site.

As specified in 10 CFR 100.20(c), the site's physical characteristics (including seismology,

meteorology, geology, and hydrology) must be considered when determining its acceptability for

a nuclear power reactor.

As required by 10 CFR 100.20(c)(3), the applicant must address factors important to

hydrological radionuclide transport using onsite measurements. To satisfy the hydrologic

requirements of 10 CFR Part 100, the staff's review of the applicant's safety assessment should

verify the description of ground water conditions at the proposed site, as well as how those

conditions could be affected by the construction and operation of a nuclear power plant(s) of

specified type (or falling within a PPE) that might be constructed on the site. Meeting this

requirement provides reasonable assurance that ground water at or near a proposed site will

not be significantly affected by the release of radioactive effluents from a plant(s) of specified

type (or falling within a PPE) that might be constructed on the proposed site.

The regulation at 10 CFR 100.23 requires that geologic and seismic factors be considered when

determining the suitability of the site and the acceptability of the design for each nuclear power

plant. In particular, 10 CFR 1 00.23(d)(4) requires that the physical properties of materials

underlying the site be considered when designing a system to supply cooling water for

emergency and long-term shutdown decay heat removal. The regulation at 10 CFR 100.23 is

applicable to Section 2.4.12 of RS-002, Attachment 2, because it addresses the requirements

for investigating vibratory ground motion, including the hydrologic conditions at and near the

site. The applicant should determine the static and dynamic engineering properties of the

materials underlying the site, including the properties (e.g., density, water content, porosity, and

strength) needed to determine the behavior of those materials in transmitting earthquakeinduced motions to the foundations of a plant(s) of specified type (or falling within a PPE) that

might be constructed on the site. Meeting this requirement provides reasonable assurance that

the effects of a safe-shutdown earthquake would not pose an undue risk to the type of facility

proposed for the site.

For those cases in which a reactor design is not specified, the ESP applicant may instead

provide a PPE to characterize a facility or facilities for comparison with the hydrologic

characteristics of the site. A PPE can be developed for a single type of facility or a group of

candidate facilities by selecting the limiting values of parameters. Important PPE parameters

for safety assessment described in SSAR Section 2.4 include, but are not limited to,

precipitation (e.g., maximum design rainfall rate and snow load) and the allowable site water

level (e.g., maximum allowable flood or tsunami surge level and maximum allowable ground

water level).

To determine whether the applicant met the requirements of the hydrologic aspects of 10 CFR

Parts 52 and 100, the staff used the following specific criteria:

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* A full, documented description of regional and local ground water aquifers, sources, and

sinks is necessary. In addition, the type of ground water use, wells, pump and storage

facilities,-and the -flow needed for a nuclear power plant(s) of specified type (or falling

within a PPE) that might be constructed on the site should be described. If ground water

is to be used as an essential source of water for safety-related equipment, the design

basis for protection from natural and accident phenomena should be compared to the

RG 1.27 guidelines. The bases and sources of data should be adequately described

and referenced.

* A description of present and projected local and regional ground water use should be

provided. Existing uses, including amounts, water levels, location, drawdown, and

source aquifers should be discussed and tabulated. Flow directions, gradients,

velocities, water levels, and the effects of potential future use on these parameters,

including any possibility for reversing the direction of ground water flow, should be

indicated. Any potential ground water recharge area within the influence of a nuclear

power plant(s) of specified type (or falling within a PPE) that might be constructed on the

site and any potential effects of construction, including dewatering, should be identified.

The influence of existing and potential future wells with respect to ground water beneath

the site should also be discussed. The bases and sources of data should be described

and referenced. References 6 through 12 of RS-002, Attachment 2, discuss certain

studies of ground water flow problems.

* The need for and extent of procedures and measures to protect present and projected

ground water users, including monitoring programs, should be discussed. These items

are site-specific and will vary with each application.

2.4.12.3 Technical Evaluation

Based on a review of a USGS document (Lloyd and Lyke, 1995), the staff determined that the

applicant's description of regional hydrogeologic conditions is accurate. The staff further __

determined that the SSAR adequately describes onsite and offsite ground water use. The

applicant stated that ground water would not be used for either normal or safety-related plant

operations. In the DSER, the staff planned to include a condition in any ESP that might be

issued for the applicant's proposed ESP site to prohibit such use. The staff had planned to

include this requirement as DSER Permit Condition 2.4-8. However, the staff determined that

normal and safety-related requirements for the ESP facility depend on the selected reactor type,

which has not been determined at the ESP stage. The staff concluded, therefore, that a COL

action item is sufficient to ensure that ground water will not be used in normal or safety-related

plant operations for the ESP facility and it is not necessary to impose DSER Permit

Condition 2.4-8. This is COL Action Item 2.4-12.

Prior construction for the CPS facility has altered, and future construction for the ESP facility

would again alter, the subsurface environment. The replacement of existing soils with fill and

cement would alter the current subsurface environment, and these changes would likely alter

the local ground water flow patterns. The staff requested, in RAI 2.4.1-1, that the applicant

define the extent of the region (including elevation) of the ESP facility. While the applicant

provided the coordinates of the areal extent of the facility, it did not provide information as to the

depth of the facility or associated disturbance, as discussed previously in DSER Open

Item 2.4-1 (Section 2.4.1.3 of this SER).

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To characterize the local subsurface environment sufficiently to understand the ground water

flowpathis, the staff requested, in RAI 2.4.13-1, more information regarding the local subsurface

environment. Based on the location of the plant relative to the piezometric boundary condition

represented by Clinton Lake, as well as the applicant's commitment to avoid using ground water

for normal or safety-related plant uses, the staff concluded that any direct impacts to the ground

water system during plant operation would be small and very localized. However, the applicant

did not bound the possible indirect impact of an overall drop in the lake pool elevation caused

by the additional consumptive use of water associated with the ESP facility. Such a drop in

elevation might alter the piezometric surface in the vicinity of the ESP facility. It was also

unclear to the staff that construction down to the PPE embedment depth could be performed

without dewatering systems that could possibly reverse the piezometric gradient for the existing

CPS unit. The staff determined that the applicant needed to provide the potential impact of

future construction for the ESP facility on the piezometric gradient for the ESP site. This was

DSER Open Item 2.4-18.

In response to DSER Open Item 2.4-18, the applicant stated, in its submission to the NRC

dated April 4, 2005, that if dewatering were to be used during construction, the potential impact

on the piezometric gradient at the ESP site would be expected to be a localized, short-term

impact to ambient ground water elevations. The applicant stated that it used site hydrogeology,

water surface elevation information obtained during the CPS site investigations, and impacts

during lake filling to anticipate the impact during operation and construction of the ESP facility.

The applicant stated that, based on measured water surface elevations, ground water gradients,

and occurrence of springs, the North Fork of Salt Creek and Salt Creek have been in the past,

and continued to be after the construction of Clinton Lake, the discharge zone for shallow

ground water at the ESP site.

The applicant stated that ER Section 5.2.1.2.4 discusses the estimated change in water surface

elevation in Clinton Lake after the addition of the ESP facility. The applicant stated that its

estimates for reduction in annual average water surface elevation in Clinton Lake are 0.2 ft with

a cooling system for the ESP facility and 0.7 ft with a wet cooling system. The applicant stated

that the estimated reduction in water surface elevation in Clinton Lake after addition of the ESP

facility is within the observed seasonal variation of water surface elevations in wells located in

the Wisconsinan deposits, which is 5 ft. as reported in SSAR Section 2.4.13.3. Therefore, the

applicant: concluded that the predicted reduction in water surface elevation in Clinton Lake after

addition of the ESP facility would not significantly change the piezometric surface in the vicinibt

of the ESP facility.

The applicant stated that if dewatering is required during construction of the ESP facility, the

ground water elevations and gradients are expected to be impacted during the construction up

to a depth equal to the PPE embedment depth. However, the applicant argued, once

construction of the ESP facility is completed, the ground water in the vicinity of the ESP facility

would return to equilibrium and the regional ground water flow pattern would be reestablished

towards the lake. The applicant also stated that because of the low permeability of the shallow

glacial material at the ESP site, sudden changes in ground water would be minimal at the ESP

site. The applicant also stated that since no permanent dewatering system would be installed at

the ESP site, there would be no long-term impact to ground water conditions at the ESP site.

The appli-ant stated that design of the excavation and the dewatering system would consider

the amount of water to be removed based on the embedment depth and the lateral extent of the

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depression in ground water table caused be dewatering. The impacts resulting from this

dewatering on the ground water system would be evaluated during preconstruction monitoring

for the ESP facility.-The applicant-stated that-the preconstruction monitoring program, identified

as preapplication in the SSAR and the ER, will include the following:

* installation of additional shallow and deep piezometers spaced at suitable intervals

away from the ESP facility, between the ESP facility and the CPS facility, and use of

piezometers located near Clinton Lake to help define the lateral continuity of sand layers

* monthly monitoring of water surface elevations in the piezometers to verify hydrostatic

loading on power plant foundation and flow directions and to estimate dewatering

volume

* installation of a 12-in. test well to perform a long-term pumping test to evaluate potential

impact of dewatering and dewatering volume

The applicant stated that the number, depths, and locations of the piezometers and the test well

would be determined after the design of the ESP facility is better defined. The data collected

from the piezometers and the test well would be used to define baseline ground water

conditions at the ESP site and to determine ground-water-related design elevations. The

applicant stated that these data would also be used to identify additional locations where ground

water conditions may need to be monitored during the construction of the ESP facility.

The staff reviewed the applicant's response to DSER Open Item 2.4-18 and carried out its own

independent estimation of the time required for ground water at the ESP site to return to

95 percent of its initial predewatering elevation. The staff used the unconfined one-dimensional

ground water flow equation with the conservative assumption of no additional recharge into the

soil during this time. The staff's conservative estimate for the time required for ground water to

return to 95 percent of its predewatering elevation exceeded 5 years.

The applicant's description of the effluent-holding facility presumed (see Sections 2.4.13.1

and 2.4.13.3 of this SER) that no scenario will exist in which liquid radioactive effluent could be

released above the ambient ground water table, including the scenario in which the effluentholding facility could be flooded, raising the release point above the ambient ground water table.

The staff agreed that under these assumptions, release of liquid radioactive effluent to ambient

ground water can be precluded. Therefore, the staff determined that it is necessary to ensure

that the hydraulic gradient will always point inwards into the radwaste holding and storage

facility from ambient ground water during construction and operation of the ESP facility,

including the time during which recovery of ground water occurs to near its predewatering

elevation. This is Permit Condition 3. Based on the above review, the staff considers DSER

Open Item 2.4-18 resolved.

The applicant estimated the average ground water velocity in the following manner:

velocity = hydraulic gradient x saturated hydraulic conductivity/effective porosity.

While the staff agreed that the equation is technically accurate, the applicant used very limited

data to estimate the three values required to derive the velocity. Based on one of two field

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permeability tests, the applicant selected the higher of the two values, 2.6x1 0-6 Wtd. For the

porosity value, only one value (25 percent) was available for the Wisconsinan Till. The

hydraulic gradient value (0.086) was based on the maximum head loss from the site to the

floodplain of the North Fork of Salt Creek. The staff required the applicant to explain why such

limited data represent a basis for a velocity estimate. In addition, the staff asked the applicant

to provide values for the hydraulic gradient, saturated hydraulic conductivity, and effective

porosity measured at the ESP site. This was DSER Open Item 2.4-19.

In response to DSER Open Item 2.4-19, the applicant stated, in its submission to the NRC

dated April 26, 2005, that it conducted a geotechnical investigation in July and August of 2002

within the footprint of the ESP facility. The applicant stated that the results of this investigation

indicated that the geotechnical conditions at the ESP site were consistent with those reported

previously by CPS investigations. Based on this information, the applicant concluded that the

CPS data were representative of the ESP site.

The applicant stated that it based its estimation of the ground water gradient on a maximum

head loss of 55 ft over a distance of 640 ft from the site to the edge of the floodplain of the North

Fork of Salt Creek. The applicant stated that according to the CPS USAR, the impoundment

created by the Clinton Dam resulted in a shift of the ground water-surface water interface

southeast of its original location towards the CPS. However, the resulting hydraulic gradient

from CFS to the lake was reduced, even though the water level in the North Fork of Salt Creek

rose to 690 ft MSL after the impoundment. The applicant thus argued that use of the CPS

hydraulic gradient is conservative.

The applicant stated that it took the hydraulic conductivity and effective porosity values from the

CPS USAR, and, although there were just a few measurements for Wisconsinan Till, the values

used in ihe SSAR are relatively consistent with field and laboratory measurements for Illinoian

Till, also collected during the CPS investigations. The applicant concluded that for this reason,

the soil properties used in the SSAR are representative of the ESP site.

The applicant stated that it will collect additional hydrogeologic data as part of the COL

preconstruction monitoring program; it will use these data to verify the hydraulic gradient, flow

directions, and ground water velocity, if these parameters are needed for the COL evaluations.

The stafi reviewed the applicant's response to DSER Open Item 2.4-18 and determined that the

applicant did not provide additional data to verify the conservativeness of the ground water

hydraulic gradient or that of soil properties. The CP or COL applicant will need to undertake

additional geotechnical characterization to establish conservative ground water flow velocities

and conservative soil properties representative of the hydrogeologic conditions at the ESP site.

This is CDL Action Item 2.4-13. Therefore, the staff considers DSER Open Item 2.4-18

resolved.

The staff had planned to include DSER Permit Condition 2.4-9 for the ESP holder to

demonstrate that an inward pointing hydraulic gradient will be maintained for all credible water

table conditions and for the applicant to implement a monitoring plan to ensure the maintenance

of this gradient condition. This requirement is now stated as Permit Condition 3 above.

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2.4.12.4 Conclusions

As set forth above;,the applicant provided sufficient information pertaining to the identification

and evaluation of the ground water characteristics at the site. SSAR Section 2.4.12 conforms to

Section 2.4.12 of RS-002, Attachment 2, with regard to this objective.

Section 2.4.12 of RS-002, Attachment 2, provides that the SSAR should address the

requirements of 10 CFR Parts 52 and 100 as they relate to identifying and evaluating the

ground water characteristics at the site. Although the applicant did not specifically address the

above regulations in SSAR Section 2.4.12, the staff concludes that, by conforming to

Section 2.4.12 of RS-002, Attachment 2, it has met the requirements to identify and evaluate

ground water characteristics at the site with respect to 10 CFR 52.17(a) and 10 CFR 1 00.20(c),

except as noted in Section 2.4.12.3 above.

2.4.13 Accidental Releases of Liquid Effluents to Ground and Surface Waters

The EGC ESP site lies within the Central Lowlands Physiographic Province. Aquifers in the

Central Lowlands occur in unconsolidated sand and gravel of the Quaternary age and

consolidated sandstone, limestone, and dolomite of the Paleozoic age. At the proposed EGC

ESP site, alluvium along the floodplains overlays glacial drift deposits.

The requirements of 10 CFR 100.20(c)(3) provide the site suitability determination factors

related to accidental releases to the liquid pathway. This regulation outlines factors important to

hydrologic radionuclide transport, such as soil, sediment, and rock characteristics; adsorption

and retention coefficients; ground water velocity; and distances to the nearest body of surface

water, which must be obtained from onsite measurements.

2.4.13.1 Technical Information in the Application

In the two paragraphs comprising SSAR Section 2.4.12, the applicant stated that it is extremely

unlikely that effluents can move out of facilities containing liquid radioactive wastes because of

the high water table elevation. The applicant's position is that the high water table results in an

inward-directed hydraulic gradient that would allow ground water into the facility but not out of

the facility.

The applicant identified the closest surface water withdrawal for drinking water purposes to be

242 miles downstream at Alton, Illinois.

In Revision 4 of SSAR Section 2.4.12, the applicant states that the issue of a possible

groundwater pathway for liquid effluents will be reviewed at the COL stage.

2.4.13.2 Regulatory Evaluation

SSAR Table 1.5-1 shows the applicant's conformance to the NRC RGs. In RAI 1.5-1, the staff

asked the applicant to provide a comprehensive listing of NRC regulations applicable to its ESP

SSAR. In its response to this RAI, the applicant indicated that RS-002, Attachment 2, identifies

the NRC regulations applicable to its ESP SSAR. Section 2.4 of RS-002, Attachment 2,

describes the methods of review and the applicable acceptance criteria that the staff uses to

develop its findings and conclusions related to the hydrologic aspects of site characterization for

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an ESP. Although the applicant did not indicate how the individual sections of SSAR

Section 2.4 address the hydrology-related site suitability criteria in RS-002, Attachment 2, the!

staff reviewed this portion of the application for conformance with the applicable regulations,

and considered the corresponding regulatory guidance, as identified below.

Acceptance criteria for this section relate to the following regulations and criteria:

1 0 CFR Parts 52 and 100, as they relate to the evaluation of a site's hydrologic

characteristics with respect to the consequences of the escape of radioactive material

from the facility

Compliance with 10 CFR Parts 52 and 100 requires that local geological and hydrological

characteristics be considered when determining the acceptability of a nuclear power plant site.

The geological and hydrological characteristics of the site may have a bearing on the potential

consequences of radioactive materials escaping from a nuclear power plant(s) of specified type

(or falling within a PPE) that might be constructed on the proposed site. The applicant should

plan for special precautions if a reactor(s) were to be located at a site where a significant

quantity of radioactive effluent could accidentally flow into nearby streams or rivers or find ready

access lo underground water tables.

These criteria apply to Section 2.4.13 of RS-002, Attachment 2, because the reviewer evaluates

site hydrologic characteristics with respect to the potential consequences of radioactive

materials escaping from a nuclear power plant(s) of specified type (or falling within a PPE) that

might be constructed on the proposed site. The staff reviews radionuclide transport

characteristics of the ground water and surface water environments with respect to accidental

releases to ensure that current and future users of ground water and surface water are not

adversely affected by an accidental release of radioactive materials. RGs 1.1 13, Revision 1,

"Estimating Aquatic Dispersion of Effluents from Accidental and Routine Reactor Releases for

the Purpose of Implementing Appendix I," issued April 1977, and 4.4, "Reporting Procedure for

Mathematical Models Selected to Predict Heated Effluent Dispersion in Natural Water Bodies,"

issued May 1974, provide guidance in selecting and using surface water models for analyzing

the flow flield and dispersion of contaminants in surface waters.

Meeting the requirements of 10 CFR Parts 52 and 100 provides reasonable assurance that

accidental releases of liquid effluents to ground water and surface water, as well as their

adverse impact on public health and safety, will be minimized.

In those cases for which a reactor design is not specified, the ESP applicant may instead

provide a PPE to characterize a facility or facilities for comparison with the hydrologic

characteristics of the site. A PPE can be developed for a single type of facility or a group of

candidate facilities by selecting the limiting values of parameters. Important PPE parameters

for safety assessment described in SSAR Section 2.4 include, but are not limited to,

precipitation (e.g., maximum design rainfall rate and snow load) and the allowable site water

level (e.g., maximum allowable flood or tsunami surge level and maximum allowable ground

water level).

To deterriine whether the applicant met the requirements of 10 CFR Parts 52 and 100 with

respect to accidental releases of liquid effluents, the staff used the following specific criteria in

accordance with Section 2.4.13 of RS-002:

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Radionuclide transport characteristics of the ground water environment with respect to

existing and future users should be described. The estimates and bases for the

coefficients of dispersion, adsorption, ground water velocities, travel times, gradients,

permeabilities, porosities, and ground water or piezometric levels between the site and

existing or known future surface water and ground water users should be described and

be consistent with site characteristics. Potential pathways of contamination to ground

water users should also be identified. Sources of data should be described and

referenced.

* Transport characteristics of the surface water environment with respect to existing and

known future users should be described for conditions which reflect worst-case release

mechanisms and source terms for use in postulating the most pessimistic contamination

from accidentally released liquid effluents. Estimates of physical parameters necessary

to calculate the transport of liquid effluent from the points of release to the site of existing

or known future users should be described. Potential pathways of contamination to

surface water users should be identified. Sources of information and data should be

described and referenced. Acceptance is based on the staff's evaluation of the

applicant's computational methods and the apparent completeness of the set of

parameters necessary to perform the analysis.

* Mathematical models are acceptable to analyze the flow field and dispersion of

contaminants in ground water and surface water, providing that the models have been

verified by field data and that conservative, site-specific hydrologic parameters are used.

Furthermore, conservatism should be the guide in selecting the proper model to

represent a specific physical situation. Radioactive decay and sediment adsorption may

be considered, if applicable, providing that the adsorption factors are conservative and

site specific. RG 1.113 provides guidance in selecting and using surface water models.

References 7 through 15 of RS-002, Attachment 2, discuss the transport of fluids

through porous media.

2.4.13.3 Technical Evaluation

The two paragraphs comprising SSAR Section 2.4.12 stated that it is extremely unlikely that

effluents can move out of facilities containing liquid radioactive wastes because of the high

water table elevation. The applicant's position is that the high water table results in an inwarddirected hydraulic gradient that would allow ground water into the facility but not out of the

facility.

In RAI 2.4.12-1, the staff requested additional information regarding the likelihood for liquid

effluents to reach a surface water body. The applicant provided data on the historical water

surface elevations in the two upper till strata (i.e., the Wisconsinan and Illinoian). The lowest

value recorded was 710.8 ft MSL in the Illinoian. The applicant reported the site grade as 735 ft

MSL and the maximum embedment depth from the PPE. However, the staff determined that

the applicant should also specify the maximum elevation at which any liquid radioactive waste

releases can occur in the proposed ESP facility. This was DSER Open Item 2.4-20.

In response to DSER Open Item 2.4-20, the applicant stated, in its submission to the NRC

dated April 4, 2005, that the maximum elevation at which any radioactive releases can occur

within the ESP facility would depend on the chosen reactor design. The applicant also stated

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that the associated minimum ground water elevation would also depend on the chosen reactor

design and the final location of the ESP structures. The applicant noted that the COL applicant

would address how the chosen design will preclude any liquid radioactive releases above the!

ground water table.

The staff reviewed the applicant's response to DSER Open Item 2.4-20. The staff's concern in

Open Item 2.4-20 related to the release of liquid radioactive effluent to ground water such that it

could be carried to Clinton Lake along with the regional ground water flow from the ESP site i:o

the lake. The applicant's position on this issue is that the facility containing the radioactive

effluent would be located below the ambient ground water table and would be maintained at

atmospheric pressure. The applicant argued that because of this design, ground water in

contact with the effluent-holding facility would be under hydrostatic pressure greater than

atmospheric pressure. Therefore, ground water adjacent to the walls of the effluent-holding

facility would tend to flow into the facility, and ground water in contact with the base of the

effluent-holding facility would also tend to flow into the facility, thereby precluding any release of

radioacl ive effluent into the ground water at the ESP site.

The staff determined that the applicant's description of the effluent-holding facility presumed

that no :scenario would exist in which the liquid radioactive effluent could be released above the

ambient ground water table, including the scenario in which the effluent-holding facility could be

flooded, raising the release point above the ambient ground water table. The staff agreed that

under these assumptions, release of liquid radioactive effluent to ambient ground water can Le

precluded. However, the COL or CP applicant would need to demonstrate that there will be no

likely scenario that could lead to liquid radioactive release to the ambient ground water, either

above the ambient ground water table or below it. This is COL Action Item 2.4-14. Further,

the COL. or CP applicant would be required to put a ground water monitoring system in place to

ensure that the hydraulic gradient would always point inwards into the radwaste holding and

storage facility from ambient ground water during construction and operation of the ESP facility,

including the time during which recovery of ground water occurs to near its predewatering

elevation. This is Permit Condition 3, as stated in Section 2.4.12.3 of this SER. The staff also

determined that a permit condition requiring a radwaste facility design for a future reactor with

features to preclude any and all accidental releases of radionuclides into any potential liquid

pathway is necessary. This is Permit Condition 4. Based on the above review, the staff

considers DSER Open Item 2.4-20 resolved.

The staff had planned to include a requirement that the COL applicant would need to utilize a

design in which radioactive liquid waste releases would not occur at any elevation greater than

the minimum design water table elevation outside the facility as DSER Permit Condition 2.4-10.

However, Permit Condition 4, stated above, requires a radwaste facility design that will preclude

any and all accidental releases of radionuclides into any potential liquid pathway and, therefore,

sets more restrictive criteria than that stated by DSER Permit Condition 2.4-10. Thus, the staff

concluded that it is not necessary to impose DSER Permit Condition 2.4-10.

The staff concluded that the applicant needed to provide a thorough description of the local

hydrologic setting, both that which exists currently and that which is expected after the

disruption associated with the ESP construction activities, to assure the staff that an inward

gradient will be maintained. This was DSER Open Item 2.4-21.

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In response to DSER Open Item 2.4-21, the applicant stated, in its submission to the NRC

dated April 4, 2005, that SSAR Section 2.4.13.3 and Section 5 of Appendix A to the SSAR

thoroughly describe the local hydrologic setting that currently exists at the ESP site. The

applicant stated that the local hydrologic setting after the disruption associated with the

construction of the ESP facility is expected to be similar to the existing hydrologic setting. The

applicant stated that localized, short-term impacts to ambient ground water elevations may.

occur during the construction of the ESP facility, but the applicant expects that the relatively low

permeability of the shallow glacial material that exists at the ESP site would help minimize these

impacts during the construction.

The applicant stated that, since the final ground water elevations at the ESP site would depend

on the plant design for and the location of the ESP facility within the identified ESP footprint, the

ground water system would be monitored during the COL preconstruction and construction

phases, as well as during the preoperation and operation phases of the ESP facility. The

applicant listed the following objectives for the ground water monitoring program:

* measurement of ground water elevations at a monthly frequency to verify hydrostatic

loadings and flow directions before construction of the ESP facility (preconstruction

monitoring)

* daily measurements of ground water elevations during the active construction phase to

determine the impact of dewatering (construction monitoring)

* monthly measurements of ground water elevations after the construction of the ESP

facility to evaluate any hydrologic changes caused by operation of the ESP facility

(preoperational monitoring)

* extension of preoperational monitoring for 5 years or until ground water conditions

stabilize (operational monitoring)

The applicant stated that these monitoring programs were also discussed in ER

Sections 6.3.1.3, 6.3.2.3, 6.3.3.3, and 6.3.4.3, respectively.

The staff reviewed the applicant's response to DSER Open Item 2.4-21. The staff's concern in

Open Item 2.4-21 was related to ensuring that the hydraulic gradient of the ambient ground

water at the ESP site was always directed inwards towards the effluent-holding facility to

preclude any scenario in which a discharge of radioactive effluent from the effluent-holding

facility could reach the regional ground water flow system and thus eventually the accessible

environment (The Clinton Lake). Based on the applicant's response to DSER Open

Items 2.4-20 and 2.4-21, the staff determined that the preclusion of radioactive effluent

discharge into the ambient ground water system at the ESP site is primarily and crucially

dependent on the hydraulic gradient pointing from the ambient subsurface into the effluentholding facility. The staff also determined that it is essential to institute a ground water

monitoring program at the ESP site to continuously monitor and verify that the central

assumption for the preclusion of radioactive releases to ground water is not violated. The staff

stated this requirement as Permit Condition 3 in Section 2.4.12.3 of this SER. The staff will also

require that this monitoring system be kept in place and the monitoring program be kept in

operation for the life of the ESP facility, including its decommissioning. This is Permit

Condition 5. Therefore, the staff considers DSER Open Item 2.4-21 to be resolved.

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2.4.13.4! Conclusions

As set forth above, the applicant provided sufficient information pertaining to the identification

and evaluation of accidental release of liquid effluents in ground water and surface water at the

site. SE;AR Section 2.4.13 conforms to Section 2.4.13 of RS-002, Attachment 2, with regard to

this objective.

Section 2.4.13 of RS-002, Attachment 2, provides that the SSAR should address the

requirements of 10 CFR Parts 52 and 100 as they relate to identifying and evaluating the

accidental release of liquid effluents in ground water and surface water at the site. Although the

applicant did not specifically address the above regulations in SSAR Section 2.4.13, the staff

concludes that, by conforming to Section 2.4.13 of RS-002, Attachment 2, it has met the

requirements to identify and evaluate the accidental release of liquid effluents to ground water

and surface water at the site with respect to 10 CFR 52.17(a) and 10 CFR 100.20(c), except as

noted in Section 2.4.13.3 of this SER.

2.4.15 Thermal Discharges

2.4.15.1 Normal Plant Heat Sink

The ESP site is adjacent to Clinton Lake, which provides cooling water for the current CPS

Unit 1. Events that may reduce or limit the availability of additional cooling water at this site

include 1Dw lake elevation, seiches, wind-induced set down, and intake blockages from

sediment or ice. Section 2.4 of this SER discusses these events.

The NPHS water supply for the ESP facility would be obtained from Clinton Lake, created by the

Clinton Dam. Normal operation of the ESP facility would use a cooling tower(s) operated with

water drawn from a cooling tower basin(s).

2.4.15.1.1 Technical Information in the Application

In Section 3.2.1 of the SSAR, the applicant provided a brief description of the NPHS.

In SSAR Section 3.2.1.2, the applicant stated that the flow from the normal cooling system to

the cooling towers would be 1,200,000 gpm. This slow rate reflects the recirculation of water

within the cooling system. Water would be withdrawn from Clinton Lake to make up for water

lost from evaporation and to limit the concentration of impurities in the cooling water. The

applicant stated that the cooling tower blowdown would normally be 12,000 gpm, with a

maximum of 49,000 .gpm.

The applicant stated that the maximum NPHS load during normal operation would be

15.08x109 Btu per hour (Btu/h), with a maximum discharge temperature of 100 'F. The staff

had intended to identify these values as DSER) Permit Conditions 3.2-1 and 3.2-2.

Section 2.4.15.1.3 of this SER provides a more detailed discussion of this issue.

The discharge temperature is based on a design approach of 15 "F and a maximum wet bulb

temperature of 85 'F. The applicant stated that a wet bulb temperature of 77.2 "F would only be

exceeded 1 percent of the time and that the maximum wet bulb temperature is 84.7 OF.

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2.4.15.1.2 Regulatory Evaluation

In RAI 1.5-1; the staff asked the applicant to provide a comprehensive listing of NRC regulations

applicable to its ESP SSAR. In its response to RAI 1.5-1, the applicant stated that SSAR

Section 3.2 addresses thermal discharges as required by 10 CFR 52.1 7(a)(1 )(iv), which states

that an ESP should describe the anticipated maximum levels of thermal effluents each facility

will produce.

The staff maintains that additional regulatory guidance for the purposes of ESP are found in

Appendix A, "General Design Criteria for Nuclear Power Plants," to 10 CFR Part 50, "Domestic

Licensing and Production and Utilization Facilities," and in 10 CFR 100.23(c). Two general

design criteria (GDC) are particularly relevant-GDC 2, "Design Bases for Protection Against

Natural Phenomena," and GDC 44, "Cooling Water." The staff also maintains that two RGs are

applicable-RGs 1.27 and 1.70, Revision 3. Also, an ESP applicant need not demonstrate

compliance with the GDC.

Acceptance criteria for this section relate to the following regulations:

* 10 CFR Parts 52 and 100 require that a site evaluation consider hydrological

characteristics.

* 10 CFR 100.23 requires that siting factors to be evaluated must include the cooling

water supply.

The regulations in 10 CFR Parts 52 and 100 require that the hydrological characteristics of a

potential nuclear power plant site be considered in the site evaluation. In particular, the UHS for

the cooling water system may consist of water sources affected by, among other things, site

hydrological characteristics that may reduce or limit the available supply of cooling water for

safety-related SSCs. Such characteristics include those resulting from river blockage or

diversion, tsunami runup and drawdown, and dam failure.

Meeting the requirements of 10 CFR Parts 52 and 100 provides reasonable assurance that

severe hydrological phenomena, including low-water conditions, will pose no undue risk to the

type of facility proposed for the site.

The regulation at 10 CFR 100.23 requires the evaluation of siting factors, including the cooling

water supply, for a potential nuclear power plant site. The evaluation of the emergency cooling

water supply for a nuclear power plant(s) of a specified type (or falling within a PPE) that might

be constructed on the proposed site should consider river blockages, diversion, or other failures

that may block the flow of cooling water, tsunami runup and drawdown, and dam failures.

This regulation also applies to SSAR Section 3.2 because the UHS for the cooling water system

consists of water sources that are subject to natural events that may reduce or limit the

available supply of cooling water (i.e., the heat sink). Natural events, such as river blockages or

diversion or other failures that may block the flow of cooling water, tsunami runup and

drawdown, and dam failures, should be conservatively estimated to assess the potential for

these characteristics to influence the design of SSCs important to safety for a nuclear power

plant(s) of a type specified by the applicant (or falling within a PPE) that might be constructed

on the proposed site. The available water supply should be sufficient to meet the needs of the

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plant(s) to be located at the site; such needs may fall within a PPE (e.g., the stored water

volume of the cooling water ponds), if an applicant uses that approach. Specifically, these

needs include the maximum essential design cooling water flow, as well as the maximum

design Flow for normal plant needs at power and at shutdown.

2.4.15.1.3 Technical Evaluation

The NPHS has no safety function and is not required for shutdown or accident mitigation.

However, in the event that the NPHS fails frequently and suddenly, there would be excessive

reliance on the UHS. This is the only safety-related consideration associated with the NPHS.

Section 2.4.15.2 of this SER discusses the UHS.

The staff performed two independent analyses to confirm whether the NPHS could be expected

to fail both suddenly and frequently. Failure was defined as a situation in which the lake water

surface elevation drops below the level that would require shutdown and possible reliance on

the UH'S. One staff analysis considered the frequency that the lake water surface elevation

would drop below a specific level. The other analysis evaluated the maximum rate at which the

lake waler surface elevation could drop.

In response to RAI E5.2-1 (issued to request additional information related to the applicant's

environmental report), the applicant described a numerical calculation of the changes in lake

water surface elevation for the 24-year period of record from June 1, 1978, to April 31, 2002.

The applicant provided information on the pool elevation that would be predicted if the ESP

facility had operated during this period. The applicant used a water budget approach in which

the change in lake storage results from an imbalance between inflows and outflows. The

applicant considered inflows from direct precipitation onto the lake and upstream drainage. Tbe

applicant assumed outflow to be the sum of natural evaporation, induced evaporation caused by

the existing CPS Unit 1, and direct evaporation from the EPS facility operating with wet cooling

towers.

To estimate the tributary inflows, the applicant's analysis estimated monthly average runoff yield

coefficients (i.e., the ratio of runoff to rainfall). The applicant then multiplied these coefficients

by the recorded rainfall during the period of record to generate a runoff record. By considering

only rainfall (and not snowfall), the applicant's approach resulted in conservative annual water

yield estimates. However, this approach would not necessarily provide conservative estimates

in warm, dry years. Therefore, the staff applied a different approach.

The staff found an adjacent streamflow gauge on Kikapoo Creek in Waynesville, Illinois. The

drainage of Kikapoo Creek is adjacent to that of the North Fork of Salt Creek and is located to

the northwest. The distance of the Kikapoo Creek gauge at Waynesville from the Clinton Dam

is approximately 15.3 miles. This gauge is minimally affected by streamflow regulation and is

comparable in the size of its contributing area,(i.e., 227 square miles (mi2)), to that of the

drainage area contributing flow to Clinton Lake (i.e., 289.2 mi2). The staff scaled the streamflow

observed at Kikapoo Creek by the ratio of the contributing area at Clinton Dam to the

contributing area at the Waynesville gauge to estimate inflows into Clinton Lake. The staff used

a time period for the estimated inflow record of January 28, 1948, to September 30, 2001.

The staff analysis found the frequency and magnitude of low-water conditions to be more

severe than those predicted by the applicant. However, the lack of pool elevation data made it

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impossible for the staff to perform an adequate calibration and verification of the applicant's

approach, thus rendering the results nonconclusive. However, the staff's second analysis did

adequately assess the rate at which the lake water surface elevation could be expected to drop.

The staff assumed that the induced evaporation caused by the existing CPS Unit 1 was equal to

the total reject heat load (i.e., the reject heat load was entirely converted to latent heat of water

vapor) or 38 cfs of evaporation. This assumption is conservative because some of the heat

load would be lost to back radiation and conductive heat exchange. From the PPE table, the

consumptive water loss of the ESP facility was estimated to be 70 cfs. The highest monthly

evaporation rate recorded by Roberts and Stall (1967) is 8.38 in. for July 1936. Correcting for

the lake area, this results in a conservative estimate of the drop in the lake water surface

elevation of 4.85 ft/mo. Even at this rate of decline, the drop of the lake water surface elevation

would be gradual enough for the plant to react well before the UHS system would be required.

As noted above in Section 2.4.15.1.1 of this SER, the staff had intended to impose the

applicant-stated maximum NPHS load during normal operation equal to 1 5.08x1 09 Btu/h and the

maximum discharge temperature of 100 OF as DSER Permit Conditions 3.2-1 and 3.2-2. As

explained above, the staff used the total reject heat load from the NPHS and assumed that all of

it is lost as evaporation. During this analysis, discharge temperature was not a limiting factor.

The staff's analysis showed that at the conservatively estimated rate of evaporation, a drop in

Clinton Lake's water surface elevation would be gradual. Based on this conclusion, the staff

determined that it is not necessary to impose DSER Permit Conditions 3.2-1 and 3.2-2.

2.4.15.1.4 Conclusions

As set forth above, the staff concludes that the applicant provided sufficient information to show

that the NPHS is likely to be able to perform its function consistent with the maximum thermal

discharge assumed in the PPE) (SSAR Table 1.4) and that the consequences of the NPHS

operation on the UHS are acceptable and do not lead to frequent plant shutdown or frequent

use of the UHS.

2.4.15.2 Ultimate Heat Sink

The ESP site is adjacent to Clinton Lake, which provides cooling water for the current CPS

Unit 1. The applicant proposed that the ESP facility's UHS would share the same source of

water as the existing plant. Events that might potentially reduce or limit the availability of

cooling water for the ESP facility's UHS at this site include low lake elevation, seiches, windinduced set down, and intake blockages from sediment or ice. Section 2.4 of this SER

discusses these events.

Although the UHS provides a critical safety function, the NPHS has no safety function and is not

required for shutdown or accident mitigation. The only safety-related consideration associated

with the NPHS relates to a situation in which the NPHS fails suddenly and frequently enough

that the ESP facility would be required to rely excessively on the UHS. Section 2.4.15.1 of this

SER discusses the NPHS.

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2.4.15.2.1 Technical Information in the Application

In Section 3.2.2 of the SSAR, the applicant provided a brief description of the UHS. In

Sectior 3.2.2.1, the applicant stated that, in accordance with RG 1.27, the UHS system would

consist of a minimum of two redundant cooling trains. In response to RAI 3.2.2-1, the applicant

provided a schematic of the water circulation in the UHS system.

In Section 3.2.2.2, the applicant further stated that the maximum discharge flow from the UHS

cooling system to the cooling towers would be 26,125 gpm during normal operation and

52,250 gpm during shutdown. This flow rate reflects the recirculation of water within the cooling

system, Water would be withdrawn from Clinton Lake to make up for water lost from

evaporation and to limit the concentration of impurities in the cooling water. The applicant

stated that the cooling tower evaporation rate would normally be 411 gpm, with a maximum of

700 gprn.

The applicant stated that the maximum UHS load during normal operation would be

225x1 0' Btu/h and 411.4x1 O6 Btu/h during shutdown, with a maximum discharge temperature of

95 OF in both cases.

The applicant indicated that the UHS pond is a submerged pond created by a submerged dam

across the North Fork of Salt Creek downstream of the plant intake. This submerged pond

maintains adequate capacity for 30 days of UHS operation in case the Clinton Lake Dam fails.

This UHS pond would be shared with the existing CPS Unit 1. A baffle in the UHS pond is part

of the UHS system design for the existing unit. In response to RAI 3.2.2-2, the applicant stated

that the maintenance of the integrity of the UHS baffle is not required for the ESP facility's UHS

operation.

2.4.15.2.2 Regulatory Evaluation

In RAI 1.5-1, the staff asked the applicant to provide a comprehensive listing of the NRC

regulations applicable to its ESP SSAR. In its response to RAI 1.5-1, the applicant stated that

SSAR Section 3.2 addresses thermal discharges as required by 10 CFR 52.17(a)(1)(iv), which

states that an ESP should describe the anticipated maximum levels of thermal effluents each

facility will produce.

The stat F believes that additional applicable regulations are GDC 2 and 44, as well as 10 CFR

100.23(c:), and the applicable regulatory guides are RGs 1.27 and 1.70. However, an ESP

applicant need not demonstrate compliance with the GDC.

Acceptance criteria for this section relate to the following regulations:

* 10 CFR Parts 52 and 100 require that the evaluation of a site consider hydrological

characteristics.

* 1 ) CFR 100.23 requires, in part, that the cooling water supply be included in the siting

factors to be evaluated.

The regulations at 10 CFR Parts 52 and 100 require that the evaluation of a nuclear power plant

site consider the hydrological characteristics of the site. To satisfy the requirements of

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10 CFR Parts 52 and 100, the SSAR should describe the surface and subsurface hydrological

characteristics of the site and region. In particular, the UHS for the cooling water system may

consist of water sources affected by, among other things, site hydrological characteristics that

may reduce or limit the available supply of cooling water for safety-related SSCs. Site

hydrological characteristics that may reduce or limit the flow of cooling water include those

resulting from river blockage or diversion, tsunami runup and drawdown, and dam failure.

Meeting the requirements of 10 CFR Parts 52 and 100 provides reasonable assurance that

severe hydrological phenomena, including low-water conditions, will pose no undue risk to the

type of facility proposed for the site.

The regulation at 10 CFR 100.23 requires the evaluation of siting factors, including the cooling

water supply, for a potential nuclear power plant site. The evaluation of the emergency cooling

water supply for a nuclear power plant(s) of a specified type (or falling within a PPE) that might

be constructed on the proposed site should consider river blockages, diversion, or other failures

that may block the flow of cooling water, tsunami runup and drawdown, and dam failures.

The regulation at 10 CFR 100.23 applies to this section because the UHS for the cooling water

system consists of water sources that are subject to natural events that may reduce or limit the

available supply of cooling water (i.e., the heat sink). Natural events, such as river blockages or

diversion or other failures that may block the flow of cooling water, tsunami runup and

drawdown, and dam failures, should be conservatively estimated to assess the potential for

these characteristics to influence the design of SSCs important to safety for a nuclear power

plant(s) of a type specified by the applicant (or falling within a PPE) that might be constructed

on the proposed site. The available water supply should be sufficient to meet the needs of the

plant(s) to be located at the site; such needs may fall within a PPE (e.g., the stored water.

volume of the cooling water ponds), if an applicant uses that approach. Specifically, these

needs include the maximum essential design cooling water flow, as well as the maximum

design flow for normal plant needs at power and at shutdown.

2.4.15.2.3 Technical Evaluation

The staff reviewed the capacity requirements for the UHS pond in Section 2.4 of this SER.

In addition, the staff independently evaluated the evaporation rates estimated for the UHS

system based on the latent heat of water and the reject heat load stated in the PPE and found

the applicant's estimates to be consistent with a conservative value of consumptive water

requirements for a UHS pond.

The applicant stated that the maximum UHS load during normal operation is 411 .4x1 06 Btu/h,

with a maximum discharge temperature of 95 IF. The staff had intended to identify these

values as DSER Permit Conditions 3.2-3 and 3.2-4. However, at the ESP stage, a specific

reactor type for the ESP facility is not known. Therefore, it is also not known whether a UHS will

be required by the ESP facility. In the event that the ESP facility does require a UHS, the staff

used the PPE evaporation rate for the UHS equal to 411 gpm for 30 days to establish excess

capacity within the submerged UHS pond. As discussed in Section 2.4.8.3 of this SER, the staff

determined that the submerged UHS pond has an excess capacity of approximately 318 ac-ft.

Based on this review, the staff concluded that DSER Permit Conditions 3.2-3 and 3.2-4 are not

required.

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2.4.15.2.4 Conclusions

As set fcrth above, the applicant provided sufficient information pertaining to the NPHS to

determine that the consequences of the NPHS operation on the UHS are acceptable and should

not lead to frequent plant shutdown or frequent use of the UHS. Therefore, the staff concludes

that the applicant has met the requirements of 10 CFR 52.17(a) and 10 CFR 100.20(c).

Further, the applicant considered the most severe natural phenomena that have been

historically reported for the site and surrounding area in establishing design-basis information

for the UHS with sufficient margin for the limited accuracy, quantity, and period of time in which

the historical data have been accumulated.

2.4.16 Site Characteristics Related to Hydrology

Based on the staff review of SSAR Section 2.4, the following site characteristics should be

incorporated in any ESP that might be issued for the proposed site.

Table 2.4-7 Proposed Site Characteristics Related to Hydrology

SITE CHARACTERISTIC VALUE

Proposed Facility Boundaries Figure 2.4-15

Site Grade 735ft MSL

Highest Ground Water Elevation 733.5 ft MSL

Probable Maximum Flood (PMF) maximum 709.8 ft MSL

hydrostatic water surface elevation

Coincident Wind Wave Activity (to add to the PMF 6.4 ft

water surface elevation)

Storm Surge (to add to the PMF water surface 0.3 ft

elevation) _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _

Combined Effects Maximum Water Surface Elevation 716.5 ft MSL

Local Intense Precipitation 18.15 in. during 1 hour

Lake Suilface Icing 27.0 in.

Maximum Cumulative Degree-Days 1141.5 in Fahrenheit

Frazil and Anchor Ice The ESP site is subject to frazil and

anchor ice formation.

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Site Safety Analysis Report for

the EGC Early Site Permit

Figure 1.2-4

ESP Site Development Details

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Figure 2.4-15 The proposed facility boundary for the ESP site

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2.5 Geology, Seismology, and Geotechnical Engineering

In Section 2.5, "Geology, Seismology, and Geotechnical Engineering," of the site safety

analysis report (SSAR), the applicant described the geological, seismological, and geotechnical

engineering properties of the early site permit (ESP) site. SSAR Section 2.5.1, "Site and

Regional Geology," describes the basic geological and seismological data for the site and

region surrounding the site. SSAR Section 2.5.2, "Vibratory Ground Motions," describes the

vibratory ground motion for the ESP site through a probabilistic seismic hazard analysis (PS HA)

and dev/elops the safe-shutdown earthquake (SSE) ground motion. SSAR Section 2.5.3,

"Surface Faulting," describes the potential for surface faulting at or near the surface of the E'SP

site. SSAR Section 2.5.4, "Stability of Subsurface Materials and Foundations," presents

information on the stability of the ESP site's subsurface materials. SSAR Section 2.5.5,

"Stability of Slopes," defers the analysis of slope stability to the combined license (COL)

applical:ion. Similarly, SSAR Section 2.5.6, "Embankments and Dams," defers the reanalyses

of the Clinton Power Station (CPS) ultimate heat sink (UHS) under the updated SSE to the COL

application. Appendices A, "Geotechnical Report for the [Exelon Generation Company, LLC

(EGC)] ESP," and B, "Seismic Hazard Report for the EGC ESP," to the SSAR provide further

detail in support of each of the above sections.

Since the ESP site is located within 700 feet (ft) of the CPS site, the applicant stated in SSAR

Section 2.5 that its starting point for the characterization of the geology, seismology, and

engineering properties of the ESP site was the previous site investigations for the CPS site. As

such, the material in Section 2.5 of the ESP application focuses on any newly published

information since the publication of the CPS updated safety analysis report (USAR) in the

1970s, as well as recent geological, seismological, geophysical, and geotechnical investigations

performed for the ESP site.

The applicant also used the seismic source and ground motion models published by the Electric

Power Research Institute (EPRI) for the central and eastern United States (CEUS), uSeismic

Hazard Methodology for the Central and Eastern United States," issued in 1986. As such,

SSAR Section 2.5 focuses on those data developed since publication of the 1986 EPRI report.

Regulatory Guide (RG) 1.165, Identification and Characterization of Seismic Sources and

Determination of Safe Shutdown Earthquake Ground Motion," issued March 1997, indicates

that applicants may use the seismic source interpretations developed by Lawrence Livermore

National Laboratory (LLNL) in the "Eastern Seismic Hazard Characterization Update," published

in 1993, or the EPRI document as inputs for a site-specific analysis.

2.5.1 Site and Regional Geology

SSAR Section 2.5.1 describes the regional and site geology for the ESP site. The geologic

settings of the region and the site are presented in Section 2.5.1.1, "Regional Geology," and in

Section 2.5.1.2, "Site Geology," of the application, respectively. Additional descriptions of the

regional and site geology are presented in Chapters 2 and 5 of SSAR Appendices A and B.

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2.5.1.1 Technical Information in the Application

2.5.1.1.1 Regional Geology

SSAR Section 2.5.1.1 summarizes the regional geologic history and structural geology, with an

emphasis on the Quaternary Period. Section 2.2 of SSAR Appendix A provides additional detail

on the regional (1) physiography, (2) stratigraphy, and (3) structural geology. In addition,

Section 2.1 of SSAR Appendix B provides a description of the regional (1) tectonic setting,

(2) tectonic features, (3) prehistoric earthquakes, and (4) seismic sources. Finally,

Attachment 1 to SSAR Appendix B describes the applicant's regional paleoliquefaction

investigations. The applicant concluded that the ESP site is one of the most geologically stable

areas in the United States and that the geologic conditions at the ESP site are the same as

those at the CPS site.

Regional Phvsiographv. The applicant described the regional physiography in Section 2.2.1 of

SSAR Appendix A. The ESP site is located in the Till Plains section of the Central Lowland

physiographic province. The terrain in central Illinois is typical of the province and consists of

undulating, low-relief topography formed by the glacial drift cover, which ranges in thickness

from a few tens of feet to several hundreds of feet. The applicant stated that much of the Till

Plains section is characterized by landforms of low, commonly arcuate ridges, called moraines,

interspersed with relatively flat intermorainal areas. The development of postglacial streams

has led to the dissection of the glacial drift mantle and in some areas bedrock is exposed;

however, there are no bedrock exposures near the site area.

Regional Geologic History and Stratigraphv. The applicant described the Quaternary geologic

history and stratigraphy in SSAR Section 2.5.1.1 and Section 2.2.2 of SSAR Appendix A.

During the Quaternary (mainly Pleistocene time), continental glaciation left widespread glacial

deposits in the regional area. There were four major episodes of glaciation in the region, which

from the youngest to the oldest are the Wisconsinan, Illinoian, Kansan, and Nebraskan.

Wisconsinan deposits are found throughout the ESP site, and Illinoian deposits are present

beyond the limit of Wisconsinan deposits in northern and central Illinois. Kansan- and

Nebraskan-age glacial deposits are present at the surface and in the subsurface in areas of

Iowa, Missouri, and part of western and east-central Illinois. These Quaternary deposits consist

predominantly of glacial or glacial-derived sediments of glacial till, outwash, loess (a windblown

silt), and glacialacustrine deposits, as well as alluvium.

Reaional Structural Geology. The applicant described the structural geology in SSAR

Section 2.5.1.1 and Section 2.2.3 of SSAR Appendix A. The Quaternary glacial deposits in the

region are underlain by thick sequences of gently dipping Paleozoic sedimentary rocks. The

bedrock surface throughout Illinois is of Paleozoic age, and the Paleozoic rocks are relatively

thicker at the centers of the structural basins, such as the Illinois basin. During Paleozoic

sedimentation, several discontinuations of regional importance occurred because of the

widespread advances and retreats of the Paleozoic seas across the interior of North America.

At a depth of about 2,000 to 13,000 ft below the ground surface, the basement complex of the

Precambrian igneous and metamorphic rocks underlies the Paleozoic rocks. Throughout the

Paleozoic era, the area underwent intermittent slow subsidence and gentle uplift, which resulted

in broad regional geologic basins of gently dipping sedimentary rocks and intervening broad

arches or highs. Locally, folds and faults are superimposed on this pattern.

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Regional Tectonic Setting. The applicant described the tectonic setting in Section 2.1.1 of

SSAR Appendix B. The ESP site is located within the Illinois basin in the stable continental

region (SCR) of the North American craton. The Illinois basin is a spoon-shaped depression,

covering parts of Illinois, Indiana, and Kentucky. The basin is bounded on the north by the

Wisconsin arch, on the east by the Kankakee and Cincinnati arches, on the south by the

Mississippi embayment, and on the west by the Ozark dome and Mississippi River arch. The

east-west-trending Rough Creek-Shawneetown fault system divides the Illinois basin into two

unequal parts. The northern part of the Illinois basin is larger but shallower, a typical cratonidepression with basement elevations ranging from approximately 2,950 ft below sea level in the

northern part of the basin to 14,100 ft below sea level in southeastern Indiana. In the northern

part of the basin, Paleozoic sedimentary strata overlie the Proterozoic-age basement rocks of

the Eastern Granite-Rhyolite Province. The southern part of the Illinois basin is relatively

smaller but deeper, with about 23,000 ft of Paleozoic sedimentary rocks. The southern part Df

the basin is underlain by portions of the Reelfoot rift and Rough Creek graben, which is a rift

system that formed during late Precambrian to middle Cambrian time (800 to 500 million years

ago (mya)).

The applicant stated that the ESP site lies within a compressive midplate stress province

characterized by a relatively uniform compressive stress field with a maximum horizontal stress

oriented northeast to east-northeast. However, within this relatively uniform stress field, the

applicant cited recent studies that show a geographic shift from an east-west maximum

horizontal compressive stress at the latitude of the New Madrid seismic zone (NMSZ) to a

stress that trends just north of east in southern Illinois and Indiana.

Regional Tectonic Features. Section 2.1.2 of SSAR Appendix B describes the major geologic

structures (folds, faults, and lineaments) in the region surrounding the ESP site as follows:

* folds

- La Salle anticlinorium

- Peru monocline

- Du Quoin monocline

- Louden anticline

- Waterloo-Dupo anticline

- Farmington anticline-Avon block

- Peoria folds

* fetults

- Sandwich fault zone

- Plum River fault zone

- Centralia fault zone

- Rend Lake fault zone

- Cap au Gres faulted flexure

- St. Louis fault

- Eureka-House Springs structure

- Ste Genevieve fault zone

- Simms Mountain fault system

- Bodenschatz-Lick fault system

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- Cape Girardeau fault system

- Wabash Valley fault system (WVFS)

- Fluorspar Area fault complek (FAFC)

- Rough Creek graben faults

- Cottage Grove fault system

lineaments

- Commerce geophysical lineament (CGL)

- St. Charles lineament

- South-Central magnetic lineament

Among the above-mentioned geologic features, the structures discussed below are described

by the applicant as either (1) coinciding with recorded earthquake trends, (2) characterized by

Quaternary deformation, or (3) attributed as potential sources of paleoliquefaction during the

Quaternary. Many of these geologic features are shown below in Figure 2.5.1-1, reproduced

from Figure 2.1-3 in Appendix B to the SSAR.

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Figure 2.5.1-1 Major structural features in Illinois and neighboring States

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Folds

The regional folds that the applicant considered to-be potential'Qucternary features are the

(1) Peru monocline, (2) Du Quoin monocline, (3) Waterloo-Dupo anticline, and (4) Farmington

anticline-Avon block.

The Peru monocline is a 65-mile-long northwest trending fold belt in which the rocks dip steeply

to the southwest into the Illinois basin. The distance between the Peru monocline and the ESP

site is about 50 to 55 miles. Three earthquakes occurring in September 1972 (body wave

magnitude (mb) 4.6), September 1999 (mb 3.5), and possibly May 1881 (magnitude unknown)

are assumed to be related to this structure, and, as such, the applicant concluded that the Peru

monocline may be a reactivated Paleozoic structure.

The Du Quoin monocline, which is located about 90 to 100 miles south of the ESP site, is a

north-south trending structure, which warps Paleozoic strata downwards on its eastern flank.

Normal faults of the Dowell and Centralia fault zones are coincident with the dipping flank of the

Du Quoin monocline. The applicant cited research that postulates that the Centralia fault zone

represents extensional activation of the basement structure beneath the Du Quoin monocline,

and these two structures may connect at depth. The Du Quoin monocline and related Centralia

fault zone are considered as a potential source for an earthquake that produced middle

Holocene paleoliquefaction features in southwestern Illinois and southeastern Missouri.

The Waterloo-Dupo anticline, which is located about 130 miles southwest of the ESP site, is a

north-northwest-trending, asymmetrical anticline that may be a southern continuation of the Cap

au Gres faulted monocline, located in Missouri and Illinois. The applicant stated that the

Waterloo-Dupo anticline may be the seismic source for the paleoliquefaction features in eastern

Missouri.

The Farmington anticline-Avon block is a broad (as much as 12 miles wide), northwesttrending, low-relief structure. Weak to moderate seismicity is clustered around this structure,

which is located about 170 miles south of the ESP site.

Faults

The regional faults and fault zones that the applicant considered to be potential Quaternary

features are the (1) Centralia fault zone, (2) St. Louis fault, (3) Ste Genevieve fault zone,

(4) WVFS, and (5) FAFC.

The Centralia fault zone is a north-trending structure zone, composed of normal faults that dip

700 to 750 toward the west, with a consistent displacement of 100 to 160 ft for strata from the

upper Mississippian to Ordovician periods. The fault zone is located about 100 miles south of

the ESP site. The applicant stated that earthquakes with strike-slip focal mechanisms located

near the structural axis of the Centralia fault are probably associated with the Du Quoin

monocline.

The St. Louis fault, which is located about 130 miles from the ESP site, is a northeast-trending

fault located along the border between Missouri and Illinois. The applicant cited recent studies

which show that the St. Louis fault (1) appears to offset the Waterloo-Dupo anticline in the right2-182
lateral sense, and (2) is considered as a possible candidate for the paleoearthquake features

found in eastern Missouri.

The Ste Genevieve fault zone, which is located about 165 miles south of the ESP site, extends

for approximately 120 miles along strike from southeast Missouri into southwest Illinois. The

fault zone consists of numerous en echelon strands (separate faults having parallel but steplike

trends) and braided segments with variable deformation styles and a complex history of

reactivation. Diffuse seismicity occurs in the block between the Ste Genevieve fault zone and

Simms Mountain fault system, located in southeast Missouri, but the applicant stated that no

documented evidence for Quaternary deformation or paleoliquefaction has been observed in

the area.

The WVFS is a major zone of northeast-trending, high-angle normal and strike-slip faulting

bordering Illinois, Kentucky, and Indiana. The fault system is about 55 to 60 miles long and as

much as 30 miles wide; the closest point of the fault system is about 130 miles from the ESP,

site. The predominant normal movement along the fault system is post-Late Pennsylvanian

with a vertical offset of about 480 ft. The applicant cited studies that suggest that the WVFS

most likely developed in the early Permian by reactivation of a Precambrian rift zone that was

the northern extension of Reelfoot rift. The WVFS is located inside the Wabash

Valley/Southern Illinois seismic zone (WVSZ), a potential source for abundant paleoliquefaction

features in the region.

The FAFC includes the faults that bound the grabens and horsts within the Fluorspar mining

district. The nearest point of the fault complex is about 175 miles from the ESP site. The FAFC

is predominately a normal fault with dip-slip as much as 2460 ft. The applicant cited the results

of shallow drilling, trenching, outcrop mapping, and seismic reflection acquisition in southern

Illinois that show evidence for Quaternary-age faulting on the FAFC in the northern Mississippi

embayment.

Lineaments

Of the three regional lineaments, the applicant only considered the CGL to be a potential

Quaternary feature.

The CGI is a northeast-trending basement magnetic and gravity anomaly that extends from

northeast Arkansas to at least Vincennes, Indiana (more than 240 miles). The CGL is a

significant, continental-scale linear feature that is apparent in topography, geophysical data,

and remDte sensory imagery. Quatemary deformation and paleoliquefaction have been

associated with the CGL at several sites. These sites are all located inside the WVSZ, which is

described below. Well-developed northeast- to north-northeast-trending strike-slip faults, which

have a long-lived tectonic history, including Pleistocene and Holocene, occur over the

lineament. In addition, the applicant noted that about 16 earthquakes with magnitudes of

mb 3.0 to 5.5 have occurred on or near the lineament.

Regional Seismic Sources. Section 2.1.5 of SSAR Appendix B describes the regional seismic

sources. Rather than characterizing the seismic potential of each of the above regional tectonic

features, the applicant used the EPRI-Seismicity Owners Group (SOG) seismic hazard study,

which groups these potential sources into large areal seismic source zones. Within a 200-mile

radius of the site (or just beyond), the three major sources of potential earthquakes are (1) the

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NMSZ, (2) the WVSZ in southern Illinois and southern Indiana, and (3) the central Illinois

basin/background source. A summary of each of these three seismic source zones is

presented below. -

New Madrid Seismic Zone

The New Madrid region was the location of three earthquakes in 1811-1812, which are the

largest historical earthquakes in the CEUS. Estimates of the magnitudes of these three events

generally range between 7.3 and 8.3. The northern boundary of the source region for New

Madrid earthquakes is generally considered to lie at or just beyond the 200-mile radius of the

ESP site. The NMSZ extends about 150 miles from northeastern Arkansas into western

Tennessee and southwestern Kentucky. The applicant summarized the results of several

geological, geophysical, and seismological studies, which have been conducted to characterize

the location and extent of the likely causative faults of each of these earthquakes and to assess

the maximum magnitude and recurrence of earthquakes in this region. Figure 2.5.1-2,

reproduced from Figure 2.1-21 in Appendix B to the SSAR, shows a schematic diagram of the

NMSZ, including areas of modern seismicity and the locations of liquefaction features.

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91,000

3710 r

90,000 89,000

36'0

35°W

Light shaded area shows location of abundant sand blows and medum shaded area shows location of abundant

modern seismicity. Selected features are: LCU, Lake County uplft; RS. Reelfoct scarp; BLSL. Big Lake sunkdands;

SFSL, St. Frances sunk-lands ; BHL, Bootheel lineament; CCFZ Crittenden County fault zone.

From Crone and Wheeler (2000).

Seismic Hazards Report for the EGC ESP Site

Schematic Diagram Showing the Reelfoot Scarp and Selected Featui

in the Area of the New Madrid Seismic Zone

Figure 2.5.1-2 Schematic diagram showing the Reelfoot scarp and selected features in

the area of the NMSZ

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In Request for Additional Information (RAI) 2.5.1-1, the staff asked the applicant to clarify its

magnitude estimates for the three 1811-1812 New Madrid earthquakes. In response, the

applicant updated its magnitude estimates to include the latest research findings.

Section 2.5.1.3.1 of this safety evaluation report (SER) provides further detail on the applicant's

response to RAI 2.5.1-1 and the staff's evaluation of the applicant's response.

Seismicity within the New Madrid region is generally located along the Reelfoot rift, which is an

ancient failed rift zone that has its long axis oriented to the northeast and runs parallel to the

CGL. The applicant cited research which postulates a time-dependent model for the generation

of repeated intraplate earthquakes that incorporates a weak lower crustal zone within an elastic

lithosphere. According to this model, relaxation of this weak zone in the lower crust after

tectonic perturbations (i.e., the recession of glacial ice sheets from central North America

14,000 years ago) transfers stress to the upper crust, triggering slip on overlying faults and

generating a sequence of earthquakes that continues until the weak zone reaches its fully

relaxed state. Coseismic slip, in turn, partially reloads the lower crust, causing cyclic stress

transfer, which prolongs the relaxation process. The applicant stated that this source model is

consistent with earthquake magnitude, coseismic slip, recurrence intervals, and surface

deformation rates in the NMSZ. The applicant stated that this model is also supported by

studies that show that the removal of the Laurentide ice sheet approximately 20,000 years ago

changed the stress field in the vicinity of New Madrid, causing seismic strain rates to increase

by about three orders of magnitude. This modeling predicts that the high rate of seismic energy

release observed during the late Holocene time is likely to continue for the next few thousand

years.

The principal seismic activity within the upper Mississippi embayment is interior to the Reelfoot

rift along the NMSZ. The NMSZ consists of three principal trends of seismicity-two northeasttrending arms with a connecting northwest-trending arm. The NMSZ is considered to be a

northeast-trending, right-lateral strike-slip fault system with a compressional left-stepover zone.

Earthquakes in the NMSZ are produced by a network of intersecting faults. The applicant

identified the following fault segments within the NMSZ:

* Blytheville arch (BA)

* Blytheville fault zone

* Bootheel lineament

* New Madrid west

* New Madrid north (NN)

* Reelfoot fault (RF)

* Reelfoot south

Each of these fault segments is shown in Figure 2.1-22 of SSAR Appendix B and reproduced

below as SER Figure 2.5.1-3.

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Figure 2.5.1-3 Central fault system of NMSZ

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Based on historical accounts and geologic evidence, geologists have postulated that the

December 16, 181 1, earthquake occurred primarily along the BA, which is the southernmost

fault segment. "Similarly, geologists have concluded that the causative-fault for the January 23,

1812, earthquake is along the NN fault segment, and the February 7, 1812, earthquake

occurred on the RF, which connects the two other fault zones through the stepover region.

Geologists have determined the maximum earthquake potential of the NMSZ based largely on

the analysis of damage-intensity data and liquefaction features from the 1811-1812 earthquake

sequence. The applicant found that recent analyses favor lower magnitudes (7.5 to 8.0) for the

NMSZ, suggesting that site effects and population distribution biased earlier interpretations,

which postulated higher magnitudes (7.8 to 8.4). To determine the recurrence interval for the

maximum earthquakes in the NMSZ, geologists have used paleoliquefaction studies and the

evaluation of fault-related deformation along the Reelfoot scarp. The applicant cited

paleoliquefaction events with dates of AD 1450 + 150, AD 900 + 100, AD 490 t 50, AD 300 ±

200, and BC 1370 ± 970, based on its review of the literature. As such, the applicant concluded

that the occurrence interval of a New Madrid-type earthquake may have been as short as

200 years or as long as 800 years, with an average of about 500 years.

Wabash Valley/Southern Illinois Seismic Zone

The WVSZ is located in southeastern Illinois and southwestern Indiana to the northeast of the

NMSZ. The WVSZ is a zone of moderate seismicity, with the strongest event (moment

magnitude (Mw) 5.4) occurring in 1968 in southern Illinois. Other notable recent events

occurring in the WVSZ include a magnitude 5.0 earthquake near Lawrenceville, Illinois, in 1987

and a magnitude 4.5 earthquake in 2002 near Evansville, Indiana. Much larger earthquakes

have occurred in the WVSZ during the past 10,000 years. The applicant cited research that

demonstrates, based on paleoliquefaction data, the existence of repeated large-magnitude

(Mw 7.0 to 7.8) earthquakes in the Wabash Valley region. The applicant stated that the

causative structure for these earthquakes may be basement thrust faults beneath the Illinois

basin that coincide with an area of broad flexure in the CGL. The location of the 1968 MW-5.4

earthquake in southern Illinois supports this hypothesis. Figure 2.5.1-4, reproduced from

Figure 2.1-14 in SSAR Appendix B, shows the historical seismicity and estimated centers of the

large prehistoric earthquakes in the WVSZ.

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Figure 2.5.1-4 Historical seismicity and estimated centers of large prehistoric

earthquakes in site region

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The applicant stated that the maximum-magnitude distribution for the WVSZ is based on the

analysis of paleoliquefaction features in the vicinity of the lower Wabash Valley of southern

Illinois and Indiana. The applicant cited research showing that the largest paleoearthquake

occurred 6101 ± 200 years ago with an estimated M, range between 7.0 to 7.5. The next

largest earthquake occurred 12,000 ± 1,000 years ago with an estimated magnitude between

7.1 to 7.3. Both of these earthquakes occurred close to one another in the lower Wabash

Valley of Indiana and Illinois.

Central Illinois Basin/Background Source

In addition to the NMSZ and WVSZ, evidence from recent paleoliquefaction studies and seismic

reflection data show that significant earthquakes may occur in parts of the central Illinois basin

where there are no obvious folds or faults at the surface. The applicant stated that the location,

size, and recurrence of such events are not well constrained by available data. However,

because of the paleoliquefaction evidence, the applicant has developed a background source

zone for this region. The central Illinois basin/background source covers the area to the west

and north of the WVSZ and encompasses the ESP site. The applicant stated that one or two

prehistoric earthquakes may have occurred near Springfield, Illinois, approximately 35 miles

southwest of the ESP site (see SER Figure 2.5.1-4 above) between about 5900 to 7400 years

ago. These earthquakes were apparently large enough to generate liquefaction features, with

magnitude estimates ranging between 6.2 and 6.8. The applicant was unable to associate the

Springfield earthquakes with any known geologic structure or local seismic activity. In addition

to the Springfield events, the applicant stated that additional liquefaction features were

discovered further south near the confluence of the Shoal Creek and Kaskaskia River. The

estimated magnitude and date for this event is about 6.0 and 5700 before present (BP).

To further characterize the seismic potential of the central Illinois basin/background source, the

applicant investigated the banks of several streams (Sangamon River, Salt Creek, North Fork

of Salt Creek, and the Mackinaw River) near the ESP site for evidence of liquefaction features

resulting from strong ground motion. These paleoliquefaction investigations are described in

Attachment 1 to SSAR Appendix B. Figure 2.5.1-5, reproduced from Figure B-1 -6 in

Attachment 1 to SSAR Appendix B, shows the streams that the applicant surveyed during its

paleoliquefaction reconnaissance.

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; I I EXPLANAiON

FI.4. Silo locabton

Ni. Cminty Boundaries

La.tdo Iiertlilnd tsts ntudir

* Signifant exposure o latett Pleistocene alluvium with no

pal oliqueatlction rnod

Two lquefation(see Table B- t-5)

events widely _ Witt * tr, Oil, l9nl ss6gS SAou60cd~llvl O6 

spaced in tI m Ch , 5w(rcius -SO 6 t0on 12 0 posureo

.L.|; -: l ? dt hfrfelioe- rrf-5 it

Sit

* 1.4PO *A.. . . - Appro.Race lis, WA olatadron for

p:do-earghquatres

S.It C.k ,We~finferred esergy carnter

ON Fj.-,Sarvsyad Stream Banks

r eaclas investigated in McNulty and

0anoe - Reaches invesbgated by or

\ B rh~s-Poss,,.*y ,wo

- toot tor tlhis studyi.

wieysaedi ieVinctires, Earthsquake Reaches investigated by road

- (5,900 to 6,DO0 years BP) reconnaisance for this study.

.. esh,41, p Figure B-14

Seisrr ic Hazards Rapon for the EGC ESP Sile

Map Showing Surveyed Stream Banks and

eV , 'Evidence for Paleoliquefaction in the Site Vicinity

Figure 2.5.1-5 Map showing surveyed stream banks and evidence for paleoliquefaction in the site vicinity

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Although the applicant discovered some small liquefaction features, which suggest possible

local seismic sources, the applicant stated that these features could also be related to more

distant sources, such as the WVSZ-or NMSZ. The applicant concluded by stating the following:

Given the low rate of historical seismicity in this region, the apparent long

recurrence between events suggested by the paleoliquefaction data, and the

lack of clearly defined seismogenic structures close to the inferred energy

centers, it is unlikely that distinct seismic sources can be defined for these

paleoliquefaction events.

For the central Illinois basin/background source, the applicant stated that the results of its

paleoliquefaction investigations show that there have not been repeated moderate to large

events, comparable to the magnitude (M) 6.2 to 6.8 Springfield earthquake in the vicinity of

the ESP site, in the late Holocene time (approximately 6 to 7 thousand years). However,

because of the uncertainty in the paleoliquefaction data, the applicant stated that the range in

maximum magnitude assigned to a random earthquake in the background source should

include events comparable to that estimated for the Springfield earthquake.

In RAI 2.5.2-6, the staff asked the applicant to explain its selected paleoliquefaction study area

along the streams near the ESP site. Specifically, the staff asked the applicant why it did not

examine the streams northwest and southeast of the site as part of its study. In response, the

applicant stated that it selected its study area to supplement previous liquefaction studies along

portions of the Sangamon River, portions of Salt Creek, and similar drainages west and northwest of the site. SER Section 2.5.1.3.1 provides further detail on the applicant's response to

RAI 2.5.2-6 and the staff's evaluation of the applicant's response.

In RAI 2.5.1-4, the staff asked the applicant to provide better annotated photographs of the

liquefaction features found along the Salt Creek. In response, the applicant provided

photographs that clearly indicate the locations of the sand dikes. In RAI 2.5.1-5, the staff asked

the applicant to substantiate the reliability of its methods to determine the size and location of

paleoearthquakes based on liquefaction features. In response, the applicant demonstrated

how it used the paleoliquefaction data and analyses to characterize the regional and local

seismic potential of these paleoearthquake centers. SER Section 2.5.1.3.1 provides further

detail on the applicant's response to RAls 2.5.1-4 and 2.5.1-5 as well as the staff's evaluation of

these responses.

2.5.1.1.2 Site Geology

SSAR Section 2.5.1.2 summarizes the local geologic history and structural geology, with an

emphasis on the Quaternary Period. Section 2.2 of SSAR Appendix A provides additional detail

on the local (1) physiography, (2) stratigraphy, and (3) structural geology. In addition,

Chapter 5 of SSAR Appendix A provides a description of the site ground water conditions and

other geologic considerations, such as potential topographic depressions caused by karst

terrain and mine subsidence. Chapter 5 of SSAR Appendix A also describes regional natural

gas production and oil fields, ground water springs, landslides, and the overall geologic

suitability.

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Site Physiography. The ESP site lies within the Bloomington Ridged Plain physiographic

subsection of the Till Plains physiographic section in Central Illinois. The site is located in an

upland area ground moraine that is dissected by the Salt Creek and the North Fork of the Salt

Creek. The local relief of the uplands is about 10 ft. except near the drainage ways, and the

average elevation of the uplands is approximately 740 ft above mean sea level (msl). The

applicant concluded that the physiography of the ESP site is the same as that of the CPS site.

Site Stratigraph . The ESP site is located a few miles inside the extent of the Wisconsinan

glaciation. The surface deposits in the upland site area consist of a thin layer of loess (silt with

some fine sand) over glacial till. Other stratigraphic units beneath the glacial till include organic

silt, under which lie glacial till deposits of the 1llinoian Stage and pre-lllinoian Stage. Bedrock in

the vicinity of the ESP site is from the Bond and Modesto formations, which generally consist of

alternating bands of limestone, shale, siltstone, sandstone, and some coal seams. At the base

of the Bond formation is a layer of limestone, which corresponds to the top of the Modesto

formation (495 ft above msl). The applicant concluded that the site stratigraphy across the ESP

and CPS sites is very similar in terms of soil consistency and layering. The primary difference

between the two sites is that the depth to bedrock is approximately 50 ft deeper at the ESP site

than at the CPS site.

Site Structural Geologv. The ESP site is located in a tectonically stable area of North America.

The applicant stated that although the ESP site is within several miles of structural features,

there is no evidence of surface faulting at the site or the area surrounding the site within a

25-mile radius. In addition, the applicant stated that no evidence of faulting was observed

based on interpretations of borehole data at the ESP and CPS sites, excavations for CPS, or

during geologic reconnaissance for this study. The applicant found that although differences in

bedrock unit elevations can be attributed to structural deformation, the relatively flat-lying and

undeforned Pleistocene drift overlying the bedrock demonstrates that the stresses that would

have been responsible for the deformation have been inactive since at least 1llinoian time (-

185 to 1.28 ka). The applicant concluded that its understanding of the CPS and ESP site

structural geology and geologic history has not changed since the geology work done for the

CPS SitE!.

Site Ground Water Conditions. The applicant found that the ground water elevations at the

ESP site are consistent with those of the CPS site. As indicated by the ESP site piezometers,

the ground water generally exists in a perched water table condition a few feet below the

ground surface in the shallow Wisconsinan till soils. A downward gradient of about 20 ft in the

ground water elevation was observed by the applicant across the ESP site. SSAR

Section 2.4.13.2, "Sources," presents a detailed discussion of the hydrogeologic conditions al:

the ESP site.

Other Geologic Conditions. Chapter 5 of SSAR Appendix A covers additional geologic

conditions that the applicant investigated as part of its ESP application. These additional

geologic conditions include (1) karst terrain, (2) mine subsidence, (3) natural gas production

and oil fields, (4) ground water springs, (5) landslides, and (6) overall geologic suitability.

Karst terrain includes topographic depressions (sinkholes), caves, large springs, fluted rocks,

blind valleys, and swallow holes that develop in areas of high rock solubility and permeability.

These features have the potential to affect the foundation support for buildings and other

2-193
structures. The applicant stated that the Illinois State Geologic Survey (ISGS) identified some

areas in Illinois that are susceptible to karst development; however, the ISGS assessment of

DeWitt County found no susceptibility.

Mine subsidence is the sinking of the ground surface after the collapse of an underground

mine, which can damage overlying structures. Although ISGS has identified areas susceptible

to mine subsidence in Illinois, the applicant found no historic mines in DeWitt County. As such,

the applicant concluded that there is no potential for mine subsidence at the ESP site.

Natural gas production from organic matter in deep valleys filled with glacial material has

occurred in Illinois since the early 1900s. Five gas-producing wells are located in the western

part of DeWitt County; however, the applicant did not identify any wells near the ESP or CPS

sites and concluded that the occurrence of gas-producing strata is not a concern. The

applicant did note the locations of two oil-well fields, more than 4 miles northeast of the CPS

site, and concluded that they do not pose a hazard to the ESP site.

The Weldon Springs State Recreation Area is located about 5 miles southwest of the ESP site.

This spring originates in the near-surface Wisconsinan silty sands and gravels and discharges

to a small lake in the recreation area. The applicant stated that the recreation area will not be

impacted by ground water extraction activities in the ESP site because the ground water

springs are hydraulically separated from the ESP site by Clinton Lake and Salt Creek.

The applicant used the ISGS landslide potential map for Illinois to determine that the landslide

potential for DeWitt County is low. The only slopes near the ESP site are those associated with

Clinton Lake. These slopes are located approximately 800 ft northwest of the ESP site. The

applicant stated that they have been very stable for the past 30 years, and therefore landsliding

does not pose a hazard. In addition, the applicant concluded that the distance between the

ESP site and the slopes is such that, if landsliding were to occur, it would not extend to the ESP

site. The applicant stated that further slope stability studies may be necessary during the COL

stage in the area of the outfall pipe, if a new outfall is constructed. At the ESP stage, the--

applicant stated that it has not yet determined the need for an outfall.

Regarding the overall geologic suitability, the applicant stated that the surficial materials present

few serious problems to construction. The most common problem is poor drainage caused by

the relatively flat, dense glacial deposits.

2.5.1.2 Regulatory Evaluation

SSAR Section 2.5.1 presents information on the geological characteristics of the ESP site

region and area. The applicant stated that SSAR Section 2.5.1 addresses Title 10 of the Code

of Federal Regulations (10 CFR ), Part 52, "Early Site Permits; Standard Design Certifications;

and Combined Licenses for Nuclear Power Plants," and 10 CFR Part 100, "Reactor Site

Criteria." SSAR Sections 3.4.1 and 3.4.2 describe the applicant's compliance with the

geological and seismological requirements of 10 CFR 100.21, "Non-seismic Siting Criteria," and

10 CFR 100.23, "Geologic and Seismic Siting Criteria," respectively. In addition, in response to

RAI 1.5-1, the applicant stated that it complied with all of the regulations listed in Review

Standard (RS)-002, "Processing Applications for Early Site Permits," for each of the pertinent

SSAR sections. This statement by the applicant implies that SSAR Section 2.5.1 conforms with

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the requirements of General Design Criterion (GDC) 2, "Design Bases for Protection Against

Natural Phenomena," in Appendix A, "General Design Criteria," to 10 CFR Part 50, uDomesiic

Licensing of Production and Utilization Facilities." In SSAR Section 1.5, "USNRC Regulatory

Guides," the applicant provided a list of the RGs that it used in developing each of the SSAR

sections. For SSAR Section 2.5.1, the applicant listed RG 1.132, "Site Investigations for

FoundEtions of Nuclear Power Plants," and RG 1.165. The staff reviewed this portion of the

application for conformance with the regulatory requirements and guidance applicable to the

geological and seismological characterization of the proposed site, as identified below. The

staff notes that GDC 2 applies to this portion of the review of an ESP application only with

regard 1:o consideration of the most severe natural phenomena reported for the site (in this case

earthquakes), including margin.

In reviewing the SSAR, the staff considered the regulations at 10 CFR 52.17(a)(1)(vi) and

10 CFR 100.23(c), which require that the applicant for an ESP describe the seismic and

geologic characteristics of the proposed site. In particular, 10 CFR 100.23(c) requires that an

ESP applicant investigate the geological, seismological, and engineering characteristics of the

proposed site and its environs with sufficient scope and detail to support evaluations to estimate

the SSE ground motion and to permit adequate engineering solutions to actual or potential

geologic and seismic effects at the site. Section 2.5.1 of NUREG-0800, "Standard Review

Plan" (SRP), issued 1997; RG 1.165; and Section 2.5 of RG 1.70, 'Standard Format and

Content of Safety Analysis Reports for Nuclear Power Plants," Revision 3, issued November

1978, provide specific guidance concerning the evaluation of information characterizing the

geology and seismology of the proposed site.

2.5.1.3 Technical Evaluation

This section of the SER provides the staff's evaluation of the geological and seismological

information submitted by the applicant in SSAR Section 2.5.1. The technical information

presented in SSAR Section 2.5.1 resulted from the applicant's surface and subsurface

geological, seismological, and geotechnical investigations performed in progressively greater

detail as they moved closer to the site. Through its review, the staff determined whether the

applicant had complied with the applicable regulations and conducted its investigations with an

appropriate level of thoroughness in accordance with the four areas designated in RG 1.165,

which are based on various distances from the site (i.e., 320 km (200 mi), 40 km (25 mi), 8 krn

(5 mi), and 1 km (0.6 mi)).

SSAR Section 2.5.1 contains the geologic and seismic information gathered by the applicant in

support of the vibratory ground motion analysis and site SSE spectrum provided in SSAR

Section 2.5.2. According to RG 1.165, applicants may develop the vibratory design ground

motion for a new nuclear power plant using either the EPRI or LLNL seismic source models for

the CEUS. However, RG 1.165 recommends that applicants update the geological,

seismological, and geophysical database and evaluate any new data to determine whether

revisions to the EPRI or LLNL seismic source models are necessary. As a result, the staff

focused its review on geologic and seismic data published since the late 1980s that could

indicate a need for changes to the EPRI or LLNL seismic source models.

To thoroughly evaluate the geological and seismological information presented by the applicant,

the staff obtained the assistance of the U.S. Geological Survey (USGS). The staff and its

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USGS advisors visited the ESP site to confirm the interpretations, assumptions, and

conclusions presented by the applicant concerning potential geologic and seismic hazards.

The staff's review-ofSSAR'Section 2:5.1 focused on (1) tectonic or seismic information,

(2) nontectonic deformation information, and (3) conditions caused by human activities, with

respect to both the regional geology and site geology.

2.5.1.3.1 Regional Geology

The staff focused its review of SSAR Section 2.5.1.1 on the applicant's description of the

regional tectonics, with emphasis on the Quaternary Period, structural geology, seismology,

paleoseismology, physiography, geomorphology, stratigraphy, and geologic history within a

distance of 200 miles from the site. The applicant provided additional detail, beyond that

presented in SSAR Section 2.5.1.1, in Section 2.2 of SSAR Appendix A and Section 2.1 of

SSAR Appendix B. In addition, Attachment 1 to SSAR Appendix B describes the applicant's

regional paleoliquefaction investigations.

In SSAR Section 2.5.1.1 and Appendices A and B, the applicant described the regional

physiography, the Quaternary geologic history and stratigraphy, structural geology, and regional

tectonic setting and features. The applicant concluded that the ESP site is one of the most

geologically stable areas in the United States, and the geologic conditions at the ESP site are

the same as those at the CPS site. Based on its review of SSAR Section 2.5.1.1 and the

pertinent portions of Appendices A and B, the staff concludes that the applicant provided a

thorough and accurate description of these geologic features and characteristics in support of

the ESP application. In addition, SSAR Section 2.5.1.1 and Appendices A and B describe welldocumented geologic information, and the staff concludes that the applicant's description fulfills

the requirements of 10 CFR 52.17, "Contents of Applications," and 10 CFR 100.23.

In Section 2.1.5 of SSAR Appendix B, the applicant described the regional seismic sources.

Rather than characterizing the seismic potential of each of the regional tectonic features (folds,

faults, lineaments), the applicant used the EPRI-SOG seismic hazard study, which groups

these potential seismic sources into large areal seismic source zones. Within a 200-mile radius

of the site (or just beyond), the three major sources of potential earthquakes are (1) the NMSZ,

(2) the WVSZ in southern Illinois and Indiana, and (3) the central Illinois basin/background

source. For each of these three seismic source zones, the applicant updated the original

EPRI-SOG seismic hazard characterization. These updates are described in SSAR

Section 2.5.2 and evaluated by the staff in Section 2.5.2 of this SER.

The New Madrid region was the location of three large earthquakes in 1811-1812, which the

applicant estimated (based on its review of the geologic literature) to be between 7.0 and 8.0.

The NMSZ consists of three principal trends of seismicity-two northeast-trending arms with a

connecting northwest-trending arm. These seismicity trends coincide with what researchers

believe to be the causative faults for the three 1811-1812 earthquakes, as well as previous

earthquake sequences occurring around AD 1450 ± 150, AD 900 ± 100, AD 490 ± 50, AD 300

± 200, and BC 1370 ± 970. These three causative faults are the RF, NN fault, and New Madrid

south (NS) fault. In addition, the applicant modeled the large seismic events within the NMSZ

as characteristic earthquakes, which means that these three faults repeatedly generated

earthquakes of similar size during each of the previous earthquake sequences. In RAI 2.5.1-1,

the staff asked the applicant to evaluate the publication of Bakun and Hooper (2004), which

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estimates the magnitudes of the New Madrid earthquake sequence to be M 7.6,7.5, and 7.13.

The applicant used the preliminary magnitude estimates by Bakun and Hooper (2003, in press),

which were M 7.2, 7.1, and 7.4. In its response to RAI 2.5.1-1, the applicant stated that its

review of the recent literature as well as discussion with researchers indicated that "there still

remains uncertainty and differing views within the research community regarding the size arid

location of the 1811-12 earthquakes." Based on its review of the recent literature concerning

the magnitudes for New Madrid earthquake sequences, the applicant added two new models

(rupture sets) and revised its previous model based on the Bakun and Hooper (2003, in press)

magnitude estimates. The applicant stated that these revisions to the magnitude distributions

for characteristic New Madrid earthquakes produced approximately 3 to 4 percent higher

ground motions at the mean 104 and mean 10-5 hazard levels. Table 2.5.1-1, reproduced from

the applicant's response to RAI 2.5.1-1, provides the six different models (rupture sets) for the

New Madrid characteristic earthquakes.

Table 2.5.1-1 Updated Magnitude Distributions for Characteristic New Madrid

Earthquakes

Reelfoot

Rupture Set NS Magnitude Magnitude NN Magnitude Weight

1 7.8 7.7 7.5 0.1667

2 7.9 7.8 7.6 0.1667

3 7.6 7.8 7.5 0.2500

4 7.2 7.4 7.2 0.0833

5 7.2 7.4 7.0 0.1667

6 7.3 7.5 7.0 0.1667

The staff considers the applicant's response to RAI 2.5.1-1 to be an adequate assessment of

the latest: geologic literature concerning the magnitudes for New Madrid characteristic

earthquakes. The applicant revised its magnitudes for rupture set number 3 to reflect the

changes made by Bakun and Hooper (2004). In addition, the applicant added two new models

based on its review of the latest literature and communications with researchers. The applicant

assessed the impact of these additions and revisions by reevaluating its PSHA and found an

increase (3 to 4 percent) in the 1 Hertz (Hz) ground motion hazard curve at the mean 1 04 and

mean 105 hazard levels. However, the applicant did not incorporate this new information into

its PSHA or subsequent SSE ground motion spectrum and indicated that the ESP application

did not need to be updated as a result of its response to RAI 2.5.1-1. In Open Item 2.5.1-1, the

staff asked the applicant to incorporate this information into its PSHA or SSE and to update the

SSAR to reflect the corrected magnitude estimates. In response, the applicant updated its

source characterization of the New Madrid earthquakes including the final published

assessments of Bakun and Hooper (2004). These changes have been incorporated into the

ESP application. Therefore, the staff considers Open Item 2.5.1-1 to be resolved.

In RAls 2.5.1-3 and 2.5.1-4, the staff asked the applicant to provide an improved regional

seismicity map and better annotated photographs of the regional liquefaction features,

respectively. In response, the applicant revised Figure 2.1-13 in SSAR Appendix B and

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Figures B-1-13, B-1-14, and B-1-15 in Attachment ito SSAR Appendix B. The staff reviewed

these revised SSAR figures and concludes that they provide more detail and support for the

applicant's characterization -of the -regional seismic sources.

In RAI 2.5.1-5, the staff asked the applicant to describe, given the heterogeneous nature of the

glacial till deposits, how it used the size of paleoliquefaction features (i.e., dike width) to

estimate the locations and magnitudes of paleoearthquakes in the Wabash Valley region and

within the Illinois basin. In addition, the staff asked the applicant to account for possible

differences in the ground water level, compaction, and overburden pressures between the time

of the paleoearthquakes and the present. In response, the applicant stated that the width of

dikes provides information that can be used to estimate the level of shaking at the specific site.

The applicant used this information in conjunction with regional data on the spatial pattern and

distribution of dike size to estimate the location and magnitude of the prehistoric earthquakes.

Concerning the uniformity and quantity of susceptible sediments in the study region, the

applicant stated that deposits of latest Pleistocene and Holocene age, which have been laid

down by moderate to large streams in the CEUS, are generally moderately susceptible. Finally,

regarding how potential differences in the geoenvironment are accounted for in determining

the size of paleoearthquakes, the applicant stated that researchers have developed

recommendations for accounting for uncertainties related to these factors in analyses to back

calculate the strength of the earthquake shaking at individual sites.

The staff notes that the applicant acknowledged the uncertainties of using paleoliquefaction

analyses to determine the size and location of prehistoric earthquakes by its characterization of

these regional seismic sources. Rather than specifically using the inferred locations and

magnitudes of paleoearthquake sources, the applicant characterized the Wabash Valley and

Illinois basin/background seismic zones as large areal source zones that encompass all of the

paleoearthquake locations. In addition, the applicant assumed that the earthquakes within

these source zones can occur over large areas as part of its PSHA. The applicant also

assumed a conservative range of maximum magnitudes for both source zones. As such, the

staff concludes that the applicant has effectively used the paleoliquefaction data and analyses

to characterize the regional and local seismic potential of the Wabash Valley and Illinois

basin/background source zones.

In RAI 2.5.2-6, the staff asked the applicant to explain its selected paleoliquefaction study area

along the streams near the ESP site. Specifically, the staff asked the applicant why it did not

examine the streams northwest and southeast of the ESP site as part of the paleoliquefaction

study. In addition, the staff asked the applicant if it used other locations besides river bank

exposures to confirm the absence of liquefaction features in the vicinity of the ESP site. In

response, the applicant stated that it did not conduct reconnaissance investigations in the areas

to the northwest and southeast for both logistical and technical reasons. The applicant stated

that it selected locations along the Salt Creek, North Fork of the Salt Creek, Sangamon River,

and Mackinaw River to supplement previous liquefaction studies in this area. The applicant

determined that the Mackinaw River, in the northern part of the study area, was a good

candidate to evaluate the evidence for paleoearthquakes because of an abundance of

accessible exposures. In addition, McNulty and Obermeier (1999) previously surveyed portions

of the Sangamon River. Concerning reconnaissance of regions southeast and northwest of the

ESP site, the applicant stated that it considered coverage of these areas to be unnecessary

because of the absence of liquefaction-susceptible deposits as well as difficulties in accessing

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the drainage areas. The applicant provided the following technical rationale for its selected

study area:

Although there are regions to the northwest and southeast of the site within

25 miles of the site that have not been examined, the coverage provided by the

previous mapping and the mapping done as part of this study provides sufficient

coverage to support the conclusion that paleoearthquakes comparable to the

postulated Springfield event have not occurred within a radius of approximately

25 miles of the site post-hypsithermic time (post-6-7 ka). A moderate to large

event located within the 25-mile radius to the southeast of the site likely would

have been recorded along the examined reaches of Salt Creek and the

Sangamon River. A moderate to large event within the 25-mile radius northwest

of the site also likely would have been recorded along the examined reaches of

ithe Mackinaw River, Salt Creek, or Sugar Creek.

Regarding the confirmation of the absence of liquefaction features in the vicinity of the ESP site

at locations other than riverbank exposures, the applicant stated that it examined gravel pits in

the region southwest of the ESP site. However, the applicant stated that there are more

abundant exposures along riverbanks, and searching along riverbanks provides for a more

efficient method for covering an extensive area.

Based c n its review of the applicant's response to RAI 2.5.2-6, the staff concludes that the

applicant adequately surveyed the site area for liquefaction features. The staff concurs with the

applicant's conclusion that the few liquefaction features indicate that there has not been a

paleoearthquake comparable to the Springfield earthquake in the site area during the past 6000

to 7000 years. An earthquake of this size (M 6.2 to 6.8) would most likely have produced

liquefaction features along many of the stream banks in the site area that were examined by

the applicant. In addition, the staff finds that the applicant has conservatively modeled the

seismic potential of the site area by defining a broad areal seismic source zone (Illinois

basin/background) as part of its PSHA.

Based upon its review of SSAR Section 2.5.1.1 and the supporting appendices and

attachments, as set forth above, the staff concludes that the applicant has provided a complete

and accUrate description of the regional geology, as required by 10 CFR 52.17 and 10 CFR

100.23.

2.5.1.3.2 Site Geology

The staff focused its review of SSAR Section 2.5.1.2 on the applicant's description of the site-.

related geologic features and structure, as well as conditions caused by human activities. In

addition tb SSAR Section 2.5.1.2, the staff reviewed Chapters 2 and 5 of SSAR Appendix A,

which prcvides supporting information on the local geologic features. Based on its review of

SSAR Section 2.5.1.2, described below, the staff concludes that the applicant has provided a

thorough and accurate description of the local geology in support of the ESP application.

In SSAR Section 2.5.1.2 and Chapters 2 and 5 of SSAR Appendix A, the applicant described

the site physiography, stratigraphy, structural geology, ground water conditions, and other

geologic conditions. The ESP site is located in an upland area with a local relief of about 10 fU

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that is dissected by the Salt Creek and the North Fork of the Salt Creek. The site is located

within the extent of the Wisconsinan glaciation with surface deposits consisting of a thin layer of

loess over glacial till. The top of bedrock is about 300 ft below the ground surface. The ESP

site is located in a tectonically stable area of North America, and there is no evidence of surface

faulting at the site or in the local site area. The ESP site area is part of the Illinois/basin

background seismic source zone, which includes the presumed epicenter of the Springfield

earthquake (M 6.2 to 6.8) in central Illinois as well as the few liquefaction features that the

applicant discovered to the northeast of the site. The ground water at the ESP site exists in a

perched water table condition a few feet below the ground surface in the shallow Wisconsinan

till soils. Concerning other geologic conditions, the ESP site is not susceptible to karst

development or mine subsidence, and the landslide potential is low.

Based on its review of SSAR Section 2.5.1.2 and Chapters 2 and 5 of SSAR Appendix A, the

staff concludes that the applicant has provided an accurate and thorough description of the

local site geology as required by 10 CFR 52.17 and 10 CFR 100.23. SSAR Section 2.5.1.2 and

Chapter 2 of SSAR Appendix A accurately describe readily observable local geologic features,

and Chapter 5 of SSAR Appendix A provides an adequate description of the local site

conditions. Because of limited ground water withdrawal, the distance of any mining activity

from the site, and the absence of karst terrain, the staff concludes that there is no potential for

the effects of human activity, such as subsidence or collapse, that could compromise the safety

of the site.

2.5.1.4 Conclusions

As set forth above, the staff reviewed the geological and seismological information submitted by

the applicant in SSAR Section 2.5.1. On the basis of its review, the staff finds that the applicant

provided a thorough characterization of the geological and seismological characteristics of the

site, as required by 10 CFR 100.23. These results provide an adequate basis to conclude that

no capable tectonic sources exist in the plant site area that have the potential to cause nearsurface fault displacement. In addition, the staff concludes, as described above, that the

applicant has identified and appropriately characterized the seismic sources significant to

determining the SSE for the ESP site, in accordance with RG 1.165 and SRP Section 2.5.1,

and therefore satisfied 10 CFR 100.23(c) and GDC 2 in this respect. Based on the applicant's

geological investigations of the site vicinity and the site area, the staff concludes that the

applicant has properly characterized the site lithology, stratigraphy, geologic history, and

structural geology. The staff also concludes that there is no potential for the effects of human

activities (i.e., ground water withdrawal or mining activity) to compromise the safety of the site.

Therefore, the staff concludes that the proposed ESP site is acceptable from a geological and

seismological standpoint and meets the requirements of 10 CFR 100.23.

2.5.2 Vibratory Ground Motions

SSAR Section 2.5.2 describes the applicant's determination of the SSE ground motion at the

ESP site from possible earthquakes in the site area and region. SSAR Section 2.5.2.1,

"Seismicity," describes the earthquake catalog used for the ESP site; SSAR Section 2.5.2.2,

"Geologic Structure and Tectonic Activity," summarizes the geologic structure and tectonic

activity that could potentially result in ground motion at the ESP site; and SSAR Section 2.5.2.3,

uCorrelation of Earthquake Activity with Geologic Structure or Tectonic Province," describes the

.2-200
correlal ion of earthquake activity with geologic structures or tectonic provinces. SSAR

Section 2.5.2.4, "Maximum Earthquake Potential," describes the maximum earthquake potential

for seismic sources in the region surrounding the ESP site; SSAR Section 2.5.2.5, "Seismic

Wave Transmission Characteristics of the Site," describes the seismic wave transmission

characteristics of the site; SSAR Section 2.5.2.6, "Safe Shutdown Earthquake," provides the

SSE ground motion spectrum; and SSAR Section 2.5.2.7, "Operating Basis Earthquake,"

provides the operating-basis earthquake (OBE) ground motion spectrum.

The applicant stated that the information provided in SSAR Section 2.5.2 of the ESP application

uses the procedures recommended in RG 1.165 with certain exceptions. In addition, the

applicant has decided to use the EPRI-SOG seismic source model for the CEUS as an input for

its seismic ground motion calculations. RG 1.165 indicates that applicants may use the seismic

source interpretations developed by LLNL (1993) or EPRI as inputs for a site-specific analysis.

RG 1.1 65 also recommends a review and update, if necessary, of both the seismic source and

ground motion models used to develop the SSE ground motion for the ESP site.

To determine if an update of the 1989 EPRI-SOG seismic source and ground motion models;

was necessary, the applicant reviewed the literature published since the mid-to-late 1980s.

This literature review identified the need for changes in some of the seismic source

characterization parameters, such as maximum magnitudes and recurrence intervals. In

addition, the applicant determined that the ground motion modeling used for the 1989

EPRI-SOG seismic study needed to be updated. To assess the impact of each of these

updates on the site hazard, the applicant performed sensitivity studies.

2.5.2.1 Technical Information in the Application

2.5.2.1.1 Seismicity

SSAR Section 2.5.2.1 describes the development of a current earthquake catalog for the ES1P

site. The applicant started with the original EPRI-SOG earthquake catalog, which covers the

time period from 1777 to the beginning of 1985. To update the earthquake catalog, the

applicant: used information from the (1) National Center for Earthquake Engineering Research

(NCEER), (2) USGS, and (3) Advanced National Seismic System (ANSS), formerly the Council

of the Naltional Seismic System. Of these three catalogs, the applicant primarily used the

USGS N3tional Hazard Mapping Catalog for the period of 1985 through 1995 (Frankel, et al.,

2002) and the ANSS catalog for 1995 through June 2002. As shown in Figure 2.5.2-1,

reproduced from Figure 2.1-11 of SSAR Appendix B, a comparison of the geographic

distribution of earthquakes contained in the EPRI-SOG earthquake catalog (1777-1985) and

the earthquakes contained in the updated catalog (1985-2002) shows a very similar spatial

distribution.

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EPRI 1777-1985

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Figure 2.5.2-1 Updates to seismicity catalog

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Significant additions to the original EPRI-SOG earthquake catalog include prehistoric

earthquakes inferred from evaluation of prehistoric liquefaction information in the ESP site

region. Paleoliquefaction features are generally identified along the cut banks of streams arid

include features such as sand boils or blows, dikes, and sills that intrude into an overlying layer

of silt. By establishing the date and geographical distribution of these features, the applicant

was able to estimate the earthquake magnitude that caused the paleoliquefaction features.

Previous investigations of paleoliquefaction features at sites in the southern Illinois basin and

parts of Indiana, Illinois, and Missouri have identified a number of episodes of paleoliquefaction

that have been interpreted to have been caused by Holocene and latest Pleistocene

earthquakes with estimated M, of 6 to 7.8. The applicant stated that one set of these

paleoliquefaction features was discovered approximately 30 miles southwest of the ESP site.

These features are from an earthquake centered in the Springfield, Illinois, area that occurred

between 5900 and 7400 years ago with an estimated magnitude range of 6.2 to 6.8.

To augment the paleoliquefaction studies covering the site region, the applicant performed

additional field reconnaissance to search for additional paleoliquefaction features within a

25-30-mile radius of the ESP site. After analyzing the field reconnaissance results, the

applicant concluded that evidence for an earthquake comparable to the postulated Springfield

earthquake had not been observed in the study area. However, isolated features of midHolocer~e and latest Pleistocene age were observed in the study area and interpreted to be

seismically induced. These features were discovered 11-13 miles from the ESP site; however,

the small scale of the features and lack of evidence for similar features elsewhere in the study

area led the applicant to conclude that they arose from a distant source or from a lowmagnitude event. Additional older paleoliquefaction features were discovered 17 miles from the

ESP site. In RAI 2.5.2-6, the staff asked the applicant to explain its selected paleoliquefaction

study area along the streams near the ESP site. In response, the applicant stated that it

selected locations along the Salt Creek, Sangamon River, and Mackinaw River to supplement

previous liquefaction studies in this area. Further details of the applicant's field reconnaissance

for palecliquefaction features near the ESP site are provided in Section 2.1.4 and Attachment 1

to Appendix B to the ESP application.

As a result of the recent discoveries of prehistoric earthquakes in the site region and two recent

earthquakes in the study region (M 5.0 in 1987 east of Olney, Illinois, and M 4.5 in 2002 in

southern Indiana), the applicant determined that the range of maximum magnitudes assigned to

the site region should be increased to include events comparable to the Springfield earthquake

(M 6.2 to 6.8).

2.5.2.1.2 Geologic Structure and Tectonic Activity

SSAR Section 2.5.2.2 describes the geologic structure and activity that could result in

seismically induced vibratory ground motions at the ESP site. The applicant's evaluation of the

geologic structure and tectonic activity for the ESP site included a detailed update of the

structural features (folds and faults) within the site region. The applicant indicated that the

results of the information update on the structural features showed that the general structural

picture remains the same. Table 2.1-1 in Chapter 2 of SSAR Appendix B provides a list of the

status for each of the folds in the ESP site region. Similarly, Table 2.1-2 in Chapter 2 of SSAR

Appendix B provides a list of the status for each of the faults in the ESP site region. In addition,

each of the folds and faults are described by the applicant in Section 2.1.2 of SSAR

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Appendix B. Rather than attempting to characterize the seismic potential of each of these folds

and faults, the applicant defined broad seismic source zones that encompass many of these

structural features. These broad seismic source zones are termed areal source zones. The

staff's detailed evaluation of the seismogenic potential of the structural features is presented in

Section 2.5.1.1.1 of this SER.

Within a 200-mile radius of the site (or just beyond), the two major sources of potential

earthquakes are the NMSZ and the WVSZ in southern Illinois and southern Indiana. The New

Madrid region was the location of three earthquakes in 1811-1812, which are the largest

earthquakes recorded in the CEUS. The Wabash Valley region is a zone of elevated seismicity

in which a number of paleoearthquakes have been identified. In addition to the NMSZ and

WVSZ, evidence from recent paleoliquefaction studies and seismic reflection data show that

significant earthquakes may occur in parts of the central Illinois basin where there are no

obvious folds or faults at the surface. The applicant stated that the location, size, and

recurrence of such events are not well constrained by available data. However, because of the

paleoliquefaction evidence, the applicant developed a background source zone for this region,

referred to as the central Illinois basin background source zone.

Since the EPRI-SOG seismic study for the CEUS, several studies have focused on the NMSZ

and WVSZ. These studies include extensive paleoliquefaction investigations, acquisition and

reprocessing of shallow seismic reflection data, paleoseismic trenching and mapping

investigations, and seismological studies. These studies have used a variety of techniques to

characterize the location, magnitudes, and seismic activity rates of the NMSZ and WVSZ. A

complete description of the NMSZ and WVSZ is provided in Section 2.1 of SSAR Appendix B.

In addition, the applicant's incorporation of the new information on the NMSZ and WVSZ into its

PSHA is provided in Section 3.0 of SSAR Appendix B. The staff's evaluation of the applicant's

characterization of the NMSZ and WVSZ is contained in Section 2.5.1.1.1 of this SER; the

applicant's incorporation of the new information on these two source zones is provided below in

Section 2.5.2.1.3 of this SER.

The ESP site is located within the Illinois basin in the SCR of the North American craton, which

is characterized by low rates of historical seismicity. The Illinois basin is a spoon-shaped

depression covering parts of Illinois, Indiana, and Kentucky. The Illinois basin is bounded on

the north by the Wisconsin arch, on the east by the Kankakee and Cincinnati arches, on the

south by the Mississippi embayment, and on the west by the Ozark dome and Mississippi River

arch. Basement elevation ranges from approximately -2,950 ft in the northern end of the Illinois

basin to -14,100 ft in southeastern Indiana.

The ESP site lies within a compressive midplate stress province characterized by a relatively

uniform compressive stress field with the maximum horizontal stress oriented northeast to eastnortheast. The applicant reported that preliminary results from a global positioning system

(GPS) network in the southern Illinois basin provide evidence for present-day tectonic strain in

the WVSZ. However, given the current level of error in individual GPS observations, an

extended period of time will be required before these observations can fully characterize the

strain field and confirm the postulated tectonic motions. Recent geodetic measurements in the

NMSZ indicate that the rate of strain accumulation is below the current detection threshold.

However, the applicant concluded that these observations are not inconsistent with a model of

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seismicity in intraplate regions as a transient phenomenon localized along weak zones in the

crust.

2.5.2.1.3 Correlation of Earthquake Activity with Geologic Structure or Tectonic Province

SSAR Section 2.5.2.3 describes the evaluation of recent geological and seismological

information and how this information was used to perform a new PSHA. Chapter 3 of SSAF,

Appendix B provides a more detailed account of the incorporation of new information for the

ESP PS)HA..

The original EPRI-SOG PSHA indicated that the most significant contributors to the seismic

hazard at the ESP site are the NMSZ, the WVSZ, and the random background event in the

local source zone (central Illinois basin background source zone). SER Section 2.5.1.1.1

provides a description of each of these three seismic source zones. After evaluating recent

information on these three source zones, other potential sources in the site region, and ground

motion estimation, the applicant made the following determinations regarding (1) earthquake

recurrence rates, (2) maximum magnitudes, and (3) ground motion attenuation.

Earthquake Recurrence Rates. The applicant focused on the recurrence rates for the NMSZ,

WVSZ, and central Illinois basin background source zone since these three source zones are

the main contributors to the total seismic hazard at the ESP site. Comparing the updated

catalog (with an additional 17 years of earthquake data) to the original EPRI-SOG catalog, the

applicant concluded that the recurrence rates used for the EPRI-SOG study are still valid. In

addition to the smaller recorded events over the past 17 years, the applicant also included the

additional prehistoric events that have occurred in the three source zones as revealed by

paleoliquefaction studies. The applicant found that for the central Illinois basin and the Wabash

Valley source zones, the fit of the earthquake recurrence relationships to the recorded

seismicity envelops the rates of larger earthquakes estimated from paleoliquefaction data.

However, for the NMSZ, the applicant found that recent paleoliquefaction data provide evidence

that large-magnitude earthquakes have occurred on the NMSZ faults more frequently than the

seismicily rates specified in the EPRI-SOG source characterizations for the NMSZ.

New Madrid Seismic Zone Characteristic Earthquake Modeling

Recent seismologic, geologic, and geophysical studies have associated faults within the NMc'Z

with the three large-magnitude historical earthquakes (NM1, NM2, and NM3) that occurred

during the 1811-1812 sequence. These three faults are (1) the NS fault, (2) the NN fault, and

(3) the RF. These faults are also believed to be the causative faults for previous NMSZ

earthquake sequences occurring around AD 1450 ± 150, AD 900 ± 100, AD 490 ± 50, AD 301)

± 200, arid BC 1370 ± 970. The applicant modeled these large seismic events within the NMSOZ

as characteristic earthquakes, which means that these three faults repeatedly generated

earthquakes of similar size during each of the previous earthquake sequences. The applicant

found that these similarly sized characteristic earthquakes occur more frequently than would be

implied by extrapolation of the recurrence of low-magnitude events in the NMSZ. As such, the

applicant focused on the characterization of these characteristic large-magnitude events within

the NMS;7. The key source parameters considered by the applicant for the NMSZ are (1) the

fault source geometry, (2) characteristic earthquake magnitude, and (3) characteristic

earthquake recurrence.

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The three fault sources included in the updated characterization of the central fault system of

the NMSZ are the NS, NN, and RF. The applicant characterized the uncertainty regarding the

location and extent or length of'the causative faults that'ruptured during the 1811-1812 and

other characteristic earthquake sequences by weighting alternative fault source geometries for

each of the three fault sources of the NMSZ central fault system. These alternative geometries

affect the distance from the earthquake rupture to the ESP site. The weights assigned to each

of the alternative source geometries are based on recently published studies of the NMSZ.

Next, the applicant considered the magnitude for the characteristic earthquakes on the three

New Madrid fault sources. The uncertainty in the magnitude estimates for the 1811-1812

earthquakes is largely caused by the subjective nature of interpretations of historical accounts,

the lack of historical accounts in many areas (especially to the west of the NMSZ), and the lack

of large recent earthquakes in the eastern United States that could be used to calibrate the

intensity values from eyewitness accounts to actual ground motion values. For the ESP

application, the applicant assigned weights for the characteristic earthquake magnitudes to

each of the major faults within the central NMSZ. The magnitude estimates are weighted

based on consideration of the published values estimated from intensity data and from

estimates of rupture area for individual fault segments. For the NS fault, which is thought to be

the source for NM1, the probability distribution for the characteristic magnitude is M 7.3 (0.4),

M 7.7 (0.5), and M 8.1 (0.1). For the NN fault, which is thought to be the source for NM2, the

probability distribution for the characteristic magnitude is M 7.0 (0.45), M 7.4 (0.45), and M 7.8

(0.1). Finally, for the RF, thought to be the source of NM3, the probability distribution for the

characteristic magnitude is M 7.2 (0.2), M 7.4 (0.4), M 7.6 (0.3), and M 8.0 (0.1). For the earlier

NMSZ characteristic earthquake sequences (pre-1 811-1812), the applicant also assumed that

these sequences consisted of multiple, large-magnitude earthquakes. As such, the applicant

considered each characteristic earthquake to be the rupture of multiple (two to three) of the

NMSZ fault sources.

In RAI 2.5.2-5, the staff asked the applicant to justify its modeling of the relative frequency of

event sequences in the NMSZ. Specifically, the staff noted that Tuttle et al. (2002) concluded

that all three sources (RF, NN, and NS) ruptured in each of the three sequences, but that onethird of the time the NN rupture may have been smaller than for the 1811-12 sequence, and

one-third of the time NS may have been smaller than in 181 1-1812. Tuttle et al. (2002) also

concluded that these smaller earthquakes are at least magnitude M 7 events. This result differs

from the event sequence modeling used by the applicant for NMSZ, which does not include NN

or NS for some of the event sequences. The applicant responded to RAI 2.5.2-5 by stating that

if the size of the 1811-1812 ruptures on these faults were in the low-magnitude M 7 range (e.g.,

values estimated by Bakun and Hooper (2003)), then the size of previous ruptures would have

been below magnitude M 7. These smaller ruptures, which would be considered dependent

events, were not included in the hazard calculations as characteristic earthquakes. SER

Section 2.5.2.3.3 provides further detail on the applicant's response to RAI 2.5.2-5 as well as

the staff's evaluation of the applicant's response.

After consideration of the magnitudes for characteristic earthquakes from the NMSZ, the

applicant examined recently published studies dealing with the recurrence of the characteristic

events. The best constraints on recurrence of characteristic NMSZ events are from

paleoliquefaction studies throughout the New Madrid region and paleoseismic investigations of

the RF scarp and associated fold. Paleoseismic studies of the NMSZ have found that the fault

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system responsible for the New Madrid seismicity generated temporally clustered, very large

earthquakes in AD 900 + 100 and AD 1450 ± 150, as well as during 1811-1812. In addition,

these studies have found evidence for prehistoric sand blows that are compound structures,

resulting from multiple earthquakes closely clustered in time (i.e., earthquake sequences)

occurring around AD 490 ± 50, AD 300 ± 200, and BC 1370 ± 970. The applicant fit the time

intervals between these dates with two recurrence models, a Poissonian model and a lognormal

model. The applicant weighted each model equally. Figure 4.1-1 in SSAR Appendix B shows a

logic tree with the different recurrence models and the intervals between NMSZ characteristic

events. For example, the time intervals and weights for the Poisson model are 187 years

(0.10), 294 years (0.24), 443 years (0.31), 704 years (0.24), and 1389 years (0.10).

As stated above, the applicant concluded, based on its review of the literature, that the RF has

ruptured in each of the previous three characteristic earthquake sequences, but the NN and NS

sources may not have produced large earthquakes in all three sequences. The applicant used

these observations to set the relative frequency of event sequences in the NMSZ as (1) rupture

of all three sources (NN, RF, and NS) one-third of the time, (2) rupture of NN and RF one-third

of the time, and (3) rupture of NS and RF one-third of the time.

Maximum Magnitudes. The applicant focused on the maximum magnitude values for the

NMSZ, NVSZ, and central Illinois basin background seismic source zone, since these three

source .,ones are the main contributors to the total seismic hazard at the ESP site. For the

NMSZ, the applicant compared the maximum magnitude range used for the EPRI-SOG study,

which is 7.2 to 8.8, with the maximum magnitudes that have been published recently, which

range from 7.4 to 8.2. As a result, the applicant concluded that the recent maximum

magnitudes for the NMSZ are consistent with the EPRI-SOG experts' assessments. For the

WVSZ, the maximum magnitudes used for the EPRI-SOG study range from 5.0 to 8.0, while

recently published maximum magnitudes range from 7.0 to 7.8. Similarly, for the central Illinois

background source zone, the maximum magnitudes used for the EPRI-SOG study range frorn

4.3 to 7.13, while recently published maximum magnitudes range from 6.0 to 7.0. As a result,

the applicant concluded, as described below, that the maximum magnitude values for both the

WVSZ and the central Illinois background source zone need to be increased to reflect the

magnitudes implied by the new paleoliquefaction data.

Wabash Valley-Southern Illinois Source Zone-Maximum Magnitude Distribution

The applicant stated that the updated maximum magnitude distribution for the Wabash ValleySouthern Illinois source zone is based on recent analysis of paleoliquefaction features in the

vicinity o1 the lower Wabash Valley of southern Illinois and Indiana. The magnitude of the

largest paleoearthquake in the lower Wabash Valley (the Vincennes-Bridgeport earthquake),

which occurred 6011 ± 200 years BP, was estimated to be between 7.2 to 7.8. The next largest

earthquake occurred 12,000 + 1,000 years BP. This earthquake is estimated to be an M 7.1 lo

7.2. Both of these earthquakes were in proximity to one another and took place in the general

vicinity of the more recent and strongest historical earthquakes (M 4 to 5.5) in the lower

Wabash Valley. Based on the above information, the applicant used the following maximum

magnitude range for earthquakes in the Wabash Valley region-M 7.0 (0.1), M 7.3 (0.4), M 7.5

(0.4), and M 7.8 (0.1). The highest weight is given to the range from M 7.3 to 7.5 where most

of the magnitude estimates lie.

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Central Illinois Basin/Background Source Zone-Maximum Magnitude Distribution

The applicant stated-that evidence from-recent paleoliquefaction studies suggests-that

significant earthquakes may occur in parts of the central Illinois basin where there are no

obvious surface faults or folds. The location, size, and recurrence of these earthquakes are not

well constrained by available data. One known earthquake is the M 6.2 to 6.8 prehistoric

Springfield earthquake, located approximately 30 miles to the southwest of the ESP site. At

present, the moderate-size prehistoric earthquakes in the central Illinois basin cannot be

associated clearly with any known geologic structure, and no seismicity trends have been

observed for this region. The applicant stated that paleoliquefaction evidence suggests that

there may have been additional moderate-magnitude events in central and southern Illinois,

such as the Shoal Creek earthquake which occurred about 5700 years BP. In addition to a

'literature review, the applicant conducted its own field reconnaissance north and east of the

ESP site. Some paleoliquefaction features were discovered, but the applicant stated that the

data are too limited to provide a basis for estimating the size or location of the event or events.

The applicant also concluded that there have not been repeated moderate to large events

(comparable to the Springfield earthquake) in the vicinity of the ESP site in the latest

Pleistocene to Holocene time (6,000 to 7,000 years BP). A study of earthquakes in SCRs

conducted by EPRI in 1994 (Johnston, et al., 1994) specifically addresses the problem of

defining a maximum magnitude for regions that are characterized by the rare occurrence of

maximum earthquakes and the lack of recognized surface expression or well-defined seismicity

patterns associated with seismic sources, typical conditions over much of the CEUS. The 1994

EPRI study developed worldwide databases that could be used for assessments of maximum

magnitudes for seismic sources in the CEUS. Using the database and method found in the

1994 EPRI study, the applicant developed the following maximum magnitude range for

earthquakes in the central Illinois basin background source-M 6.2 (0.4), M 6.4 (0.3), M 6.6

(0.2), and M 6.8 (0.1).

In RAI 2.5.2-4, the staff asked the applicant to provide further detail and justification regarding

its use of the 1994 EPRI study and accompanying worldwide database of earthquakes. _.

Specifically, the staff requested the applicant to explain why its maximum magnitude for central

Illinois should not be set at 6.8 since the two largest SCR earthquakes from nonextended crust

are the Accra, Ghana, earthquake of 1862 (M 6.75 ± 0.35) and the Meeberrie, Western

Australia, earthquake of 1941 (M 6.78 + 0.25). In its response to RAI 2.5.2-4, the applicant

stated that the method developed by the 1994 EPRI study does not start from the assumption

that all SCR domains have the same maximum magnitude potential. Instead it assumes that

there are characteristics that control the maximum size of an earthquake that can occur in an

individual SCR domain, and these characteristics vary from domain to domain. SER

Section 2.5.2.3.3 provides further detail on the applicant's response to RAI 2.5.2-4 as well as

the staff's evaluation of the applicant's response.

Ground Motion Attenuation. The original EPRI-SOG study used three attenuation relationships,

developed in the mid-1980s. Since the completion of the EPRI-SOG study, estimating ground

motions in the CEUS has been the focus of considerable research. Following the guidance

provided in NUREG/CR-6372, "Recommendations for Probabilistic Seismic Hazard Analysis:

Guidance on Uncertainty and Use of Experts," prepared by the Senior Seismic Hazard Analysis

Committee, EPRI completed in 2003 a study to characterize the distribution of ground motion

prediction in the CEUS (EPRI 1008910, "CEUS Ground Motion Project: Model Development

2-208
and Resultse). For the EPRI study, a panel of six ground motion experts was assembled, arid,

during a series of workshops, the experts provided advice on the available CEUS ground

motion attenuation relationships. In addition, the experts provided information on the

approp iate criteria for evaluating the ground motion attenuation relationships. The product of

the EPRI study is a suite of ground motion relationships and associated relative weights that

represent the uncertainty in predicting median levels of ground motion. The EPRI study

grouped the selected ground motion attenuation relationships into four clusters, in which each

cluster represents a group of models based on a similar approach for ground motion modeling.

After comparing the three attenuation models used for the EPRI-SOG study with the new EFPRI

ground motion study, the applicant concluded that the recent median ground motion models are

generally consistent with two of the three older models. However, the estimates of uncertainty

or variability about the median ground motion predictions are considerably higher for the recent

ground motion attenuation relationships compiled by the recent EPRI study compared to the

uncerta nty in the ground motion used for the original EPRI-SOG study.

In RAI 2.5.2-3, the staff asked the applicant to describe how the recent EPRI ground motion

study converted the distance measure used for each of the attenuation relationships to a

common measure. Specifically, the 13 CEUS attenuation relationships selected by the EPRI

ground motion experts each use one of two different distance measures. In response to

RAI 2.5.2-3, the applicant provided a description of the method it used to convert the "pointsource" distance measure to the more commonly used "Joyner-Boore" distance measure. SER

Section 2.5.2.3.3 provides further detail on the applicant's response to RAI 2.5.2-3 as well as

the staff's evaluation of the applicant's response.

In summary, from the data obtained after the original EPRI-SOG study, the applicant concluded

the following:

(1) there are no additional specific seismic sources in the site region, (2) with the

exception of large [characteristic] earthquakes occurring on the central faults in

the NMSZ, the EPRI-SOG recurrence parameters provide a good estimate of the

current rate of seismicity in the study region, (3) the maximum magnitude

distributions for the central Illinois and Wabash Valley/Southern Illinois source

zones developed by the EPRI-SOG expert teams likely underestimate what

would be assessed give the present state-of-knowledge, and (4) current ground

motion models for the CEUS are generally consistent with the median models

used in the EPRI-SOG study. However, the aleatory variability about the median

ground motions used in the EPRI-SOG study is generally lower than current

estimates.

As a result of the above conclusions, the applicant made the following adjustments to the

source parameters and ground motion relationships as part of sensitivity tests for the seismic

hazard characterization of the ESP site:

* Set the mean return period for large characteristic earthquakes on the central faults of

the NMSZ to 500-1000 years.

* Increase the maximum magnitude distributions of the WVSZ and central Illinois sources.

2-209
* Use updated attenuation models.

After implementing the above adjustments to the seismic source characterizations and ground

motion models, the applicant concluded that the resulting seismic hazard curves are generally

higher for the ESP site. The applicant implemented each of the above adjustments individually

and then made comparisons with the earlier EPRI-SOG hazard curves for the ESP site. In

addition, the applicant implemented each of the above adjustments simultaneously and made

similar comparisons. For both cases, the applicant considered the change in the seismic

hazard levels to be significant enough to perform an updated PSHA for the ESP site.

2.5.2.1.4 Maximum Earthquake Potential

SSAR Section 2.5.2.4 presents the maximum earthquake potential for the ESP site in terms of

the controlling earthquake magnitudes and distances. The applicant determined the low- and

high-frequency controlling earthquakes by deaggregating the PSHA results at selected

probability levels. Before determining the controlling earthquakes, the applicant updated the

original EPRI-SOG PSHA using the seismic source zone adjustments and new ground motion

-modeling described above in the previous SER subsection.

PSHA Results. The applicant performed the PSHA by combining the hazard from the EPRISOG seismic sources (with updated maximum magnitude distributions) with the hazard from

the New Madrid characteristic earthquake sources. The applicant assumed that the

characteristic earthquake ruptures on the New Madrid faults rupture along the entire length of

the fault, and the closest approach of the fault to the ESP site was used as the distance to the

rupture. In addition, the applicant assumed that the characteristic earthquakes occurring on the

central New Madrid faults rupture as clustered events or as a sequence within a short time

period relative to the return period for the events.

The applicant performed PSHA calculations for peak ground acceleration (PGA) and spectral

acceleration at frequencies of 25, 10, 5, 2.5, 1, and 0.5 Hz. Following the guidance provided in

RG 1.165, the PSHA calculations were performed assuming generic hard rock site conditions

(i.e., a shear- (S-) wave velocity of 9200 ft/s). The actual local site characteristics are

incorporated in the calculation of the SSE spectrum, which uses the hard rock PSHA hazard

results as the starting point. To compare the relative contribution of each of the dominant

seismic source zones to the total hazard, the applicant computed PSHA results for the central

Illinois basin background source, Wabash Valley, and New Madrid individually. At low ground

motion levels, the distant Wabash Valley and New Madrid characteristic earthquakes produce

the highest hazard. As the ground motion level increases, the local central Illinois background

source becomes the dominant contributor to the hazard for high-frequency ground motions.

Controlling Earthquakes. To determine the low- and high-frequency controlling earthquakes for

the ESP site, the applicant followed the procedure outlined in Appendix C to RG 1.165. This

procedure involves the deaggregation of the PSHA results at a target probability level to

determine the controlling earthquake in terms of a magnitude and source-to-site distance. The

applicant chose to perform the deaggregation of the mean 104 and 1 05 PSHA hazard results.

The low- and high-frequency controlling earthquakes are shown below in Table 2.5.2-1.

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Table 2.5.2-1 High- and Low-Frequency Controlli ng Earthquakes

Hazard Magnitude (mb) Distance

Mean 10' 6.5 83 km (52 mi)

High Frequency (5 and 10 Hz)

Mean 10' 7.2 320 km (199 mi)

Low Frequency (1 and 2.5 Hz)

Mean 10-5 6.2 24 km (15 mi)

High Frequency (5 and 10 Hz)

Mean 105 7.2 320 km (199 mi)

Low Frequency (1 and 2.5 Hz)

For the high-frequency mean 1 0- hazard, the controlling earthquake is a magnitude 6.5 event

occurring at a distance of 83 km (52 mi), corresponding to an earthquake from the Wabash

Valley-southern Illinois source zone. In contrast, for the high-frequency 10-5 hazard, the

controlling earthquake has a magnitude of 6.2 at a distance of only 24 km (15 mi). This

controlling earthquake is from the nearby central Illinois background source zone. For the

low-frequency mean 10- and 10-5 hazard, the controlling earthquake has a magnitude of 7.2 at

a distance of 320 km (199 mi). This earthquake corresponds to an event in the NMSZ. The

ground motion response spectra for these controlling earthquakes are shown below in

Figure 2.5.2-2, which is reproduced from Figure 4.2-19 in SSAR Appendix B. The applicant

used the EPRI 2003 ground motion relationships to estimate the ground motion response

spectra for the controlling earthquakes.

2-211
2

10

5

ID)

I0

(a)

51

2

.5

.2

.1

.02

.01

.005

.1 .2 .5 - 1 2 5 10 20 50 130.1 .2 .5 1 2 5 10 20 50 100

Frequency (Hz) requenuy (lIz)

Seismic Hazards Report for the EGC ESP Site Fgure

Reference Earthquake (RE) Response Spectra for Mean 104 4.2-19

and Mean 104 Hazard

Figure 2.5.2-2 Reference earthquake response spectra for mean

hazard

104 and mean 1O-5

2-212
2.5.2.1.5 Seismic Wave Transmission Characteristics of the Site

SSAR Section 2.5.2.5 describes the method used by the applicant to develop the site free-field

ground motion spectrum. The hazard curves from the PSHA are defined for generic hard rock

conditions. According to the applicant, these hard rock conditions exist at the ESP site at a

depth cf several thousand feet or more below the ground surface. To determine the free-field

ground motion, the applicant (1) developed soil/rock profile models for the ESP site,

(2) selected seed earthquake time histories, and (3) performed the final site response analysis.

ESP Profile Model. The soil profile model used by the applicant for its site response analysis is

shown in SSAR Figure 2.5-3. The profile consists of a thin layer of loess underlain by

interbedded glacial tills and lacustrine (lake) deposits of Quaternary age to a depth of nearly

300 ft. For the 31 0-ft soil column at the ESP site, the applicant used the S-wave velocity (V.)

values irom its ESP geophysical surveys, which are described in SER Section 2.5.4.1.4. SER

Figure 2.5.4-5 shows the compressional- (P-) wave velocity (Vp) and V, for each of the different

soil layers to a depth of about 300 ft below the ground surface. As described in SER

Section 2.5.4.1.2, the applicant conducted cyclic testing of the ESP site soils to determine the

variation in soil shear strain modulus and material damping ratio with shearing strain amplitude.

Based on the dynamic test results, the applicant selected appropriate shear modulus and

damping curves for the ESP site.

As a result of the large range in S-wave velocities for some of the soil layers (Table 5-2 in

SSAR Appendix A) and the differences in standard penetration test (SPT) blowcount values for

ESP borings BI and B4 compared to those of B2 and B3, the staff in RAI 2.5.4-4 requested

that the applicant justify the appropriateness of using a single "average" soil column for the site

response analyses rather than including a number of different base-case soil columns. In

response to RAI 2.5.4-4, the applicant stated that it modeled the variations in S-wave velocity

and SPT blowcounts by statistically creating a large number of profiles, or realizations, and

conducting the site response analyses using these profiles. SER Section 2.5.2.3.5 provides

further detail on the applicant's response to RAI 2.5.4-4 as well as the staff's evaluation of the

applicant's response.

At a depth of approximately 300 ft is the top of the bedrock, which consists of limestone, shale,

sandstone, siltstone, and a single 1-ft-thick interval of coal. The bedrock is of Pennsylvanian

age. The applicant characterized the dynamic properties of this soil/bedrock profile during field

and laboratory testing. These dynamic properties consisted of S-wave velocity data to a depth

of 310 ft and a set of shear modulus reduction and damping data obtained from samples taken

from boreholes drilled at the ESP site. Since the V8 at a depth of 310 ft below the ESP site is

about 4000 ft/s, the applicant used nearby deep borehole VP measurements to estimate the

bedrock V, profile. The applicant assumed Vp/V ratios of 1.73 and 2, which correspond to

depths of 1900 ft and 3000 ft to reach the hard rock value of V, = 9200 ft/s. In addition, for the

sedimentary rocks below a depth of 310 ft, the applicant assumed a linear behavior during

earthquake shaking. The damping values used by the applicant for the sedimentary rocks vary

from 3.3 percent at depths ranging from 310 to 400 ft to 1.8 percent for rocks at a depth of

1200 to 1900 ft.

Once the applicant determined the appropriate soil and rock dynamic properties, it modeled the

variability present in the site data by randomizing the soil and rock S-wave velocity profiles, soil

2-213
shear modulus and damping relationships, and rock damping values. The applicant generated

60 soil/rock profiles to account for variability in the site properties.

To account for the variability in soil shear strain modulus and material damping ratio with

shearing strain amplitude, the applicant randomized the shear modulus and damping curves

used for the site response analysis. In RAI 2.5.4-7, the staff asked the applicant to explain how

these curves were used in the randomization process with respect to both the different depth

ranges and the soil types occurring within those depth ranges. In response to RAI 2.5.4-7, the

applicant stated that the computation performed for the EGC ESP project resulted in

60 modulus reduction curves and 60 material damping curves for each of the depth intervals.

The range represented by each of the 60 sets of curves is intended to cover the uncertainties in

the shape and absolute value of the modulus reduction and material damping ratio curves

resulting from a number of different effects, including the particular soil type, the stress history

for the soil, sample disturbance associated with the laboratory testing of soil samples, and

random variability that is typically observed in laboratory testing programs. SER

Section 2.5.2.3.5 provides further detail on the applicant's response to RAI 2.5.4-7 as well as

the staff's evaluation of the applicant's response.

Earthauake Time Histories. Using the controlling earthquake (low- and high-frequency)

magnitudes and distances listed above in Table 2.5.2-1, the applicant developed hard rock site

response spectra using the EPRI (2003) ground motion models and then scaled these spectra

to match the ESP site rock spectral accelerations at 1 and 2.5 Hz (low frequency) and 5 and

10 Hz (high frequency). However, instead of using these two rock response spectra to develop

the ESP site response, the applicant determined an additional three "deaggregation

earthquakes" for each controlling earthquake. These three deaggregation earthquakes

represent a more complete range of the earthquakes that contribute to the low-frequency

(1 and 2.5 Hz) and high-frequency (5 and 1 0 Hz) hazard than just a single controlling

earthquake. To illustrate, Figure 2.5.2-3, reproduced from Figure 4.1-20 in SSAR Appendix B,

shows the deaggregation results for the mean 1 04 hazard. The high-frequency controlling

earthquake has a magnitude of 6.5 and distance of 83 km (52 mi). The three high-frequency

deaggregation earthquakes at the mean 1 0- hazard level and their weights are mb = 5.7 at

15 km (0.377), mb = 6.7 at 153 km (0.322), and mb = 7.2 at 375 km (0.301). As shown below in

Table 2.5.2-2, there are three deaggregation earthquakes for each controlling earthquake.

2-214
Figure 2.5.2-3 Deaggregation results for mean 104 hazard

2-215
Table 2.5.2-2 Controlling and Deaggregation Earthquakes

Hazard Controlling Earthquake Deaggregation Earthquakes

Magnitude Magnitude

(mb) Distance (mb) Distance Weight

mean 10 4 6.5 83 km (52 mi) 5.7 15 km (9 mi) 0.377

5 and 10 Hz 6.7 153 km (95 mi) 0.322

7.2 375 km (233 mi) 0.301

mean 104 7.2 320 km (199 mi) 5.9 15 km (9 mi) 0.093

1 and 2.5 Hz 6.8 166 km (103 mi) 0.240

7.3 379 km (236 mi) 0.667

mean 10' 6.2 24 km (15 mi) 5.8 11 km (7 mi) 0.733

5 and 10 Hz 6.8 140 km (87 mi) 0.149

7.4 380 km (236 mi) 0.118

mean 10- 7.2 320 km (199 mi) 6.0 12 km (7 mi) 0.212

1 and 2.5 Hz 6.9 155 km (96 mi) 0.220

7.4 381 km (237 mi) 0.568

To determine the ESP dynamic site response, the applicant developed appropriate ground

motion or earthquake time histories for each of the 12 deaggregation earthquakes. The

applicant selected these earthquake time histories from the CEUS time history library provided

with NUREG/CR-6728, "Technical Basis for Revision of Regulatory Guidance on Design

Ground Motions: Hazard and Risk Consistent Ground Motion Spectral Guidelines." This library

contains recordings divided into magnitude and distance ranges, each containing 30 time

histories. The applicant scaled each of the 30 time histories to match the response spectrum

for the corresponding deaggregation earthquake.

Site Response Analysis. To determine the final site response, the applicant used the program

SHAKE to compute the site amplification function for each deaggregation earthquake. The

applicant paired the 60 randomized velocity profiles with the 60 sets of randomized shear

modulus and damping curves (i.e., one velocity profile with one set of modulus reduction and

damping curves). To obtain a site amplification function, the applicant divided the response

spectrum from the computed surface motion by the response spectrum from the input hard rock

motion. The applicant then computed the arithmetic mean of these 60 individual response

spectral ratios to define the mean amplification function for each deaggregation earthquake.

Figure 2.5.2-4, reproduced from Figure 4.2-23 in SSAR Appendix B, shows the computed highand low-frequency average site amplification functions for the mean 1 04 hazard level

deaggregation earthquakes. As shown in Figure 2.5.2-4, the ESP site subsurface amplifies the

input hard rock motion over the fairly wide frequency range of 0.5 to 10 Hz, with the maximum

amplification of 3.3 at a frequency of 1.7 Hz. The thick line shown in Figure 2.5.2-4 is the final

site amplification function for each controlling earthquake and represents the weighted average

of the amplification functions for the associated deaggregation earthquakes. The weights,

listed above in Table 2.5.2-2, represent the relative contribution of earthquakes represented by

2-216
10.

2

5-10 Hz RE

---- DEL

.2 - DEM

-x DEH

-Weighted Average

.1 . }....

10

5

C.)

---- DEL

.2 - - DEM

x DEH .

-We~ightedl Average

.1 ., , . . ..... .. ..

.2 .0 1 2 5 10 20 50 100

Fr-eq2u wR (Hz)

Seismic Hazards Report for the EGC ESP Site Figure

Mean Site Amplification Functions for Deaggregation Earthquakes and Weighted 4.2-23

Avetage Site Amplification Functions for Reference Earthquakes for Mean IO' Hazard

Figure. 2.5.2-4 Mean site amplification functions for deaggregation earthquakes and

weighted average-site amplification functionsforreferenceearthquakesAforameanl

hazard

2-217
the deaggregation earthquakes to the hazard at the appropriate spectral frequency and hazard

level.

The applicant determined the final soil surface spectra for the ESP site by scaling the rockcontrolling earthquake spectra by the mean site amplification functions. These spectra are

shown below in Figure 2.5.2-5, reproduced from Figure 4.2-26 in SSAR Appendix B. The

applicant enveloped the low- and high-frequency soil surface spectra with smooth envelope

spectra, as shown in Figure 2.5.2-5.

2-218
22

.2

.5

.e-4 mean hazard 0-5 mean hazard

F RE! -- -- H R

/-' * on Lr RE. ,'- Sod LF RLar

- Soil Envelope - Soil wve-ope

.005 .1 .2 .5 1 2 5 10 20 50 1C0.1 .2 .5 1 2 5 1C 20 50 10D

FrequelenytI (Hz) Frequency (hz)

Seismic Hazards Report for the EGC ESP Site Figure

Rock Reference Earthquake Spectra Scaled by Weighted Average Site 4.2-26

Amplification Functions and Soil Envelope Spectra

Figure 2.5.2-5 Rock reference earthquake spectra scaled by weighted average site

amplification functions and soil envelope spectra

2-219
2.5.2.1.6 Safe-Shutdown Earthquake

The method for determining the SSE for a site, as described in RG 1.165, is based on the use

of a reference probability (R,). The basis for the procedure in RG 1.165 and the determination

of the reference probability is that existing nuclear power plants do not represent an undue risk

to the health and safety of the public. As such, using existing plants as a reference, RG 1.165

recommends a procedure to determine the seismic design basis for future plants. The

reference probability is the average probability of exceeding the SSE ground motion at 5 and

10 Hz using either the 1993 LLNL PSHA or the 1989 EPRI PSHA. A reference probability level

was calculated for 29 nuclear power plant sites in the CEUS, and the median reference

probability for these 29 sites, using median hazard results, is 10i5 per year. A similar value was

obtained using both the 1993 LLNL and 1989 EPRI PSHAs; therefore, RG 1.165 endorses both

the LLNL and EPRI PSHA results as being suitable for seismic hazard estimation for future

siting. Concerning the Rp value, in SSAR Section 2.5.4.9, "Earthquake Design Basis," the

applicant stated the following:

These probabilities [Rp] were computed using ground motion models developed

in the mid-to-late 1980's. As discussed in Regulatory Position 3 in Regulatory

Guide 1.165, significant changes to the overall database for assessing seismic

hazard in the CEUS warrants a change in the reference probability. The

availability of the recently developed EPRI ground motion characterization for the

CEUS (EPRI, 2003) represents a significant advancement in the seismic hazard

database for the CEUS. Appendix B of Regulatory Guide 1.165 discusses that

selection of another reference probability may be appropriate, such as one

founded on risk-based considerations. That is the approach taken for

developing the EGC ESP SSE design ground motions.

Rather than updating Rp and using the methodology described in RG 1.165 to determine the

SSE ground motion, the applicant chose to use a different approach, which is described in the

American Society of Civil Engineers (ASCE)/Structural Engineering Institute (SEI)

Standard 43-05, Seismic Design Criteria for Structures, Systems, and Components in Nuclear

Facilities and Commentary." This new approach is referred to as a "performance-based"

approach. The performance-based approach sets a goal or target of a mean annual frequency

of 1 O' of unacceptable performance of nuclear structures, systems, and components (SSCs)

as a result of seismically initiated events. Specifically, the performance-based approach is

intended to achieve a mean 10-5 risk per year of core damage caused by seismic initiators.

This safety performance goal is based on assuming a target 104 mean annual risk of core

damage caused by all accident initiators and the assumption that seismic initiators contribute

about 10 percent of the risk of core damage posed by all accident initiators.

To determine the SSE that achieves the annual performance goal of 1 0'5, the performancebased approach scales the site-specific mean 1 04 uniform hazard response spectrum (UHRS),

shown above in Figure 2.5.2-5, by a design factor (DF):

2-220
SSE = UHRSO1V x DF (2.5.2-1)

where

DF = Max(DFI, DF2)

and

DFi = 1.0

DF2 = 0.6(AR) 0.8

The amDlitude ratio, AR, is given by the ratio of 1 05 UHRS and 10 4 UHRS spectral

accelerations for each spectral frequency. As shown in the above equations, the minimum

value of DF for each spectral frequency is 1.0, which implies that the SSE will be equivalent to

the 10-4UHRS or higher, depending on the amplitude ratio. Table 2.5.2-3 shows the applicant's

computation of the horizontal SSE using the two UHRS spectra and the DF for a select number

of spectral frequency values.

Table 2.5.2-3 Computation of the Horizontal SSE Spectrum for the ESP Site

Spectral 104 Mean 10,5 Mean

Frequency (Hz) UHRS (g) UHRS (g) DF2 DF Horiz. SSE (g)

0.1 0.0129 0.0412 1.519 1.511 0.0196

0.5 0.1400 0.4160 1.434 1.434 0.2007

1.0 0.2970 0.8020 1.328 1.328 0.3945

2.5 0.6382 1.2561 1.031 1.031 0.6582

5.0 0.6570 1.2149 0.981 1.600 0.6570

10.0 0.5864 1.1065 0.997 1.079 0.6002

20.0 0.4599 0.7862 0.921 1.000 0.4599

50.0 0.3200 0.5791 0.914 1.000 0.3200

100.0 (PGA) 0.2660 0.4895 0.977 1.000 0.2660

Figure 2.5.2-6 shows the soil surface 104 (green line) and 105 (red line) mean UHRS and the

applicani's performance-based SSE spectrum (black line). As shown in Figure 2.5.2-6 and

above in Table 2.5.2-3, the final performance-based SSE is approximately equivalent to the 1 04

UHRS for spectral frequencies above 2.5 Hz.

2-221
1.4

1.2

G 1.0 -

Aos

0 2

0.8

0.1 1 1o 100

Frequency (Hz)

Figure 2.5.2-6 Comparison of performance-based SSE spectrum

for the ESP site and the mean 1O4 and 10-5 UHRS

2-222
In RAI 2.5.2-1 (a), the staff asked the applicant to justify the selection of the site-specific mean

1 04 UHRS as the appropriate starting point for determining the final SSE. In response to

RAI 2.5.2-1 (a), the applicant stated that the "design amplitude required to achieve the

performance goal at each structural period can be calculated starting from the mean 104

annual probability level of the seismic hazard spectrum in the free field at the ground surface, or

from the 1 5 annual probability level, or from any intermediate probability level." The applicant

explained that it selected a 10,4 annual probability level as the starting point based on the

precedent set in ASCE/SEI Standard 43-05.

In RAI 2.5.2-1 (b), the staff asked the applicant to demonstrate that the SSE envelops the sitespecific: response spectra from the controlling earthquakes at the reference probability level

(median 1 o5 per year) recommended by RG 1.165 or to justify why this approach was not used

to determine the SSE. In response to RAI 2.5.2-1 (b), the applicant stated that it did not rely on

the site-specific response spectra from the controlling earthquakes at the hazard reference

probability level of median 0-5 per year to determine the site-specific SSE. Instead, the

applicant used the performance-based approach in ASCE/SEI Standard 43-05 to determine the

site-specific SSE.

In RAI 2.5.2-1(c), the staff asked the applicant to justify using SSC seismic fragility informatiDn,

before the selection of a reactor design, to determine the site SSE. In response to

RAI 2.5.2-1 (c), the applicant stated that the performance-based approach "combines a

conservative characterization of equipment/structure performance with ground motion hazard to

establish risk-consistent SSEs, rather than only hazard-consistent ground shaking, as occurs

using the hazard reference probability approach in Appendix B of RG 1.165."

2.5.2.1.5.1 Derivation of Performance-Based Approach

In RAI 2.5.2-7(b), the staff asked the applicant to provide the derivation of the DF

(Equation 2.5.2-1) used to achieve the target performance goal of mean 1 5S per year.

Using the applicant's response to RAI 2.5.2-7(b), supplemented by a review of ASCE/SEI

Standard 43-05, NUREG/CR-6728, and papers by R.P. Kennedy ("Overview of Methods for

Seismic PRA and Margins Analysis Including Recent Innovations," dated August 1999, and

"Establishing Seismic Design Criteria to Achieve an Acceptable Seismic Margin," dated AugList

1997), the staff derived the equations and assumptions underlying the performance-based

approach. The following SER subsections describe this derivation.

Seismic Hazard Curves. In order to achieve a site SSE that meets the target performance

level, the performance-based approach stipulates both the site seismic hazard characteristics

as well Es the fragility characteristics of nuclear SSCs. The site seismic hazard characteristics

are quantified by the PSHA seismic hazard curves and UHRS that cover a broad range of

natural frequencies. Figure 2.5.2-7 below shows the mean seismic hazard curves on a log-log

scale for the frequencies of 1, 2.5, 5, and 10 Hz for the EGC ESP site. These four seismic

hazard curves indicate the mean annual rate of exceedance for different values of spectral

acceleration (Sa) for each of the four natural frequencies. Specifically, these curves show the

annual probability that the Sa exceeds a particular acceleration value for each of the seismic

sources surrounding the ESP site. The hazard curves are developed by identifying and

characterizing each seismic source in terms of magnitude recurrence and location as well as

2-223
determining the ground motion at the site resulting from each source. SER Section 2.5.2.1.4

provides a complete description of the applicant's PSHA results for the ESP site.

0.1

/.)

0

Ca

o 0.01

GC.)

0

CZ)

m 0.001

0

.0

0

.; 0.0001

c

le-05

le-06 +-

0.01 0.1 1

Acceleration (g) [log scale]

Figure 2.5.2-7 Four mean seismic hazard curves (1 Hz, 2.5 Hz, 5 Hz, and 10 Hz) for EGC

ESP site plotted on a log-log scale. Dashed lines indicate annual probability of

exceedance intervals of 104 per year and 10-5 per year.

2-224
Seismic Fragility. The performance-based approach uses the standard assumption that the

seismic fragility of nuclear SSCs can be modeled using a lognormal distribution. The probability

density function (PDF) for the lognormal distribution is given by

fc(a;fpC)= '__ exp- - a 0> (2.5.2-2)

where it and care the mean and standard deviation, respectively, of the related normal random

variable X = In(C). In the area of seismic fragility or capacity, l is used rather than oto dencte

the stardard deviation. Figure 2.5.2-8 shows lognormal probability density functions for a

specified , and four different ,fvalues from 0.3 to 0.6, which is the typical range of standard

deviations for nuclear SSCs based on seismic probabilistic risk assessment (PRA) studies. The

probability that a lognormally distributed random variable C is less than or equal to some

specified value a is given by the cumulative distribution function (CDF)

P(C < a) = Fc (a;,u,/J) = 4 in al (2.5.2-3)

where 4' denotes the standardized normal distribution with a zero mean and standard deviation

of one Fz(z, 0, 1). Seismic fragility curves are based on the lognormal CDF and express the

probability of failure as a function of spectral acceleration or other ground motion parameter.

Figure 2.5.2-9 shows seismic fragility curves for a specified u and four different fi values from

0.3 to 0.6. Important quantile values such as the median and lower and upper bounds are

shown on the lognormal PDF and CDF curves, respectively, in Figures 2.5.2-10 and 2.5.2-1 1.

The 1 -percent quantile value is defined as the high-confidence-low-probability-of-failure

(HCLPFa point and represents the seismic capacity corresponding to a 1 -percent mean

probability of failure. Quantile values (Cq) for the lognormal distribution are given by

Cq =exp(er+ Zqf) (2.5.2-4)

where Z4 are quantile values from the standard normal distribution with a zero mean and

standard deviation of one.

2-225
1.2- .

1.1 1

930Seismic Fragility

"O Lognormal PDF, f(a)

for g=0.44 g

0.7

0.6 - I 12340.4

~0.I

0O.4 / f3=0.5

03

~0.2 3-6

0.1 /

0.0-

0 12 3 4 5

Acceleration (g)

Figure 2.5.2-8 Lognormal PDF for different values of the lognormal standard deviation

value, fi

2-226
1.0

0.9 /

ISI 0. ,

0.7

CZ)

~0.4

lismic Lalgit ~V005frag

~0.4

I //Acce Seaismi Er(gt)ure

value,,8./ CD Lognormal sue omdltesimc fra)iiyo S

2-227
1.0 -

- 0.9 0 -

0 0.8 -

c:

e 0.7 -

.)

Z 0.6 -

c.)

' 0.5 c

O, 0.4- ._

-D

J 0.3 - 0

(14

.i 0.2-

0.1 -

. . . . . . . . . . . . . . . . . . .

Seismic Fragility

Lognormal PDF, f(a)

with gN0.4 4 g and P=0.4

HCLPF (Cqol)=0.61 g

lower bound (Co5)=0.80 g

median (C 5 J)71.55 g

mean (gLN)=1. 6 8 g

upper bound (C9 5 )=2.99 g

C.50

mean

i! ~I\ f.

IC.95

0.0 . . . . . i . . . . . . . . . . . .

0 I

I . . . . 1

2 3

Acceleration (g)

4 5

Figure 2.5.2-10 Significant parameter and quantile values for lognormal PDF, including

the HCLPF value

2-228
1.0- C '.'

0.9 -

.3 /.Seismic Fragilp Curve

U T Lognormal CDFF(a)

0.'7 w ith g=0.44 g and P=0.4

HCLPF (C01)=0.61 g

0.6 mlower bound (C0 ,D)=0.80 g O 0.6 mean /median (Cs)=1.55g

mean(gLN)=1 *

68 g

/upper bound (C9)=2.99 g z .'j...C.-s ...... --l '......._...

c) 1

0._

0.3

0.2

0.1

0.0 . .....

0 1 2 3 4 5

Acceleration (g)

Figure 2.5.2-11 Significant parameter and quantile values for lognormal CDF, including

the HCLPF value

2-229
Risk Integral. The starting point for the performance-based method is the risk integral, which is

an application of the law of total probability:

n

P(B) = E P(BI Ai )P(Ai) (2.5.2-5)

i=,

where P(B) and P(A3) denote the probabilities of events B and A,, P(BJA,) denotes the

conditional probability of event B given that event Ai has occurred, and n is the total number of

possibilities for event A, (the probabilities of which sum to unity).

When A is instead a continuous non-negative random variable, the law of total probability is

expressed as

P(B) = | P(BJ A = a)fA (a)da (2.5.2-6)

0

where fA(a) is the PDF for A.

Letting B denote failure (in a year), A denote the ground motion amplitude (demand), and C

denote SSC seismic capacity (in terms of ground motion amplitude), the continuous expression

of the law of total probability can also be expressed as

P(B) = J P(BI C = a)fc (a)da (2.5.2-7)

0

where fc(a) is the lognormal seismic capacity PDF given by Equation 2.5.2-2 above.

Recognizing that SSC failure (event B) can be expressed as event A greater than event C (i.e.,

demand greater than capacity), the conditional probability P(BIC = a) can be rewritten as

P(BI C = a) = P(A > Cl C = a) = P(A > a) = H(a) (2.5.2-8)

where H(a) is the site seismic hazard curve. Combining the above two equations gives the risk

integral, which forms the basis for the performance-based approach,

PFT = J H(a)fC(a)da . (2.5.2-9)

where 'a' represents ground motion amplitude, Pm. is the target performance goal (1 0-5), H(a) is

one of the mean seismic hazard curves for the site (see Figure 2.5.2-7) and fc(a) is the seismic

SSC fragility curve expressed in terms of a lognormal PDF. In words, the risk integral states

that the annual probability of failure PFT is equal to the product of (1) the annual probability that

the ground motion amplitude, or seismic demand, exceeds 'a' and (2) the probability (within the

2-230
differential da) that the seismic fragility equals 'a, summed (or integrated) over all possible

values of 'a'.

To determine the SSE spectral acceleration value that achieves the target performance goal

(PFT) of I0-5, the mean (,u) in the fragility lognormal PDF (Equation 2.5.2-2) can be written in

terms oi the HCLPFcapacity using Equation 2.5.2-4 above:

/1= InCq - Zqi8= InC.O - Z~OO= InHCLPF+ 2.326,6 (2.5.2-10)

Making :his substitution provides an expression for the seismic fragility PDF in terms of the

HCLPF'capacity and the standard deviation, f. The HCLPFcapacity can then be written in

terms of the SSE by assuming that the HCLPFseismic capacity of SSCs will exceed the SSE

ground motion by a seismic margin, M;

HCLPF

Ms SSE (2.5.2-11)

The seismic fragility lognormal PDF then becomes:

.fc1(a) = 1[ Ina - (InSSEx M, + 2.326,f)2} (2.5.2-12)

Substituting this expression for the fragility PDF into the risk integral (Equation 2.5.2-9) enables

the determination of the SSE value that achieves the target performance goal of 10'5. Figure

2.5.2-12 shows the EGC ESP seismic hazard curve for a natural frequency of 5 Hz along with

the seismic fragility PDF, assuming specific values for the SSE, seismic margin (M.), and

standard deviation(8). Figure 2.5.2-13 shows the product of the seismic hazard and fragility

curves. The spectral acceleration value that gives an area of 10-5 under the curve in

Figure 2.5.2-13 is the value of the SSE for the natural frequency of 5 Hz.

2-231
0.10

0.09-

0.08 l

CZ 0.07-

0.06 -

0

0.05

0.04

0.03

0.02 /Seismic Fragility PDF (pN=0. 44 g and 1=0.4)

0.01 5z I- Hazard Curve

0.00-

0.0 0.2 0.4 0.6 0.8 1.0

Acceleration (g)

Figure 2.5.2-12 EGC ESP 5-Hz mean seismic hazard curve and seismic fragility curve in

terms of the lognormal PDF

2-232
0.001

0.0301 Area unider 'urve-I.uuxjU -

1 e-05

1 e-06

1 e-07

le-08 \

I e--09

le-10 -.

0 1 2 3 4 5

Acceleration (g)

Figure 2.5.2-13 Product of EGC ESP 5-Hz mean seismic hazard curve and seismic

fragility curve. Spectral acceleration value that gives an area of 10i5 under the curve is

the SSE for 5 Hz.

2-233
Risk Equation. Rather than using the direct numerical integration approach, illustrated above,

to determine the SSE that achieves the target performance goal for each natural frequency, the

developers of the performance-based approach assume a functional form for the hazard curve,

H(a). As shown previously in Figure 2.5.2-7, the seismic hazard curves are very close to linear

in logarithmic space between the exceedance probabilities of 104 and 1 5O. Assuming a linear

hazard curve in logarithmic space implies that the hazard curve can be expressed as

log H(a) = b + m log a (2.5.2-13)

where b and m are the intercept and slope, respectively, between the exceedance probabilities

of 1 04 and 1 0'5 per year and the slope, m, as given by

log 10-5 - log 10-4 -1

loga 2 -logal log AR (2.5.2-14)

with AR =a2 . The equation for the hazard curve, H(a), is then given by

H(a) = 1 0 ba gAR =a gA (2.5.2-15)

with k = 1 0b. Assuming this functional form for the hazard curve allows for a closed-form

solution of the risk integral:

______ lIn a --(1nSSE x M, .2f~l

PFT = f-lka )g a/ Cexp{ [ J da (2.5.2-1 6)

This closed-form solution is obtained by making the substitution x = Ina, which reduces the

risk integral to the form

fJZ(x) exp(cx)dx (2.5.2-17)

where c = ,%ogAR is a constant and Z(x) is the PDF for a normal random variable with mean

= I In(SSE x M,) + 2.326f, and standard deviation fi. The solution to the risk integral is then

given by

exp{ + . 2c} (2.5.2-18)

2-234
and solving for the SSE after substituting back in for pu and c gives

SSE= I t(2.5.2-19)

where

g(fAR) A ) |-2.326l ' 1 A J 1 9(8 AR ex log A. +2 * og ARJ

Since k and AR are given by the intercept and slope of the hazard curve, respectively, only

values for the seismic margin (Me) and standard deviation of the seismic fragility (I) must be

assumed. As shown above in Equation 2.5.2-15, the SSE decreases as the seismic margin

increases. For this application of the performance-based approach, the seismic margin is

assumed to be unity, and as such HCLPF= SSE for each SSC. A value for the standard

deviation of the seismic fragility, A, must also be assumed in order to determine the SSE.

Based on empirical evidence from past seismic PRA studies, the applicant stated that the range

of anticipated I values is 0.3 to 0.6. For this application of the performance-based approach, fi

is assumed to be 0.4.

Rather ihan using Equation 2.5.2-19 above to determine the SSE value that achieves the target

performance goal, the developers of the performance-based approach use the simpler

expression given previously in Equation 2.5.2-1, which is repeated here for convenience:

SSE = UHRSO1 4 x DF

where LIHRS 104 is the uniform hazard spectral acceleration value for an exceedance probability

of 1 04 per year and DF is the design factor. Substituting this expression for the SSE into

Equation 2.5.2-19 above shows that DF is given by

k XUHRSA

DF L U 10 4 g(f AR) (2.5.2-20)

Since the numerator of the ratio within the brackets is simply equal to PREF, which is 10i, the DF

becomes

1 =M pR og5A

DIF = MSREFT ~i (2.5.2-21)

2-235
Substituting M, = 1, PFT = 10 5 and pREF = 1 0-4 results in a function for DFthat depends only on

the amplitude ratio AR and ,8. Rather than use this exact equation for DF, ASCE/SEI

Standard 43-05 uses a close approximation given by Equation 2.5.2-1 above and repeated

below for convenience:

DF = max[O.6 x (AR ) 8,i0]-.

Figure 2.5.2-14 shows a comparison between the "exact" DF(Equation 2.5.2-21) and the

approximate DF(Equation 2.5.2-1). The approximate DFas a function of AR is larger than the

exact DF, which is a function of both AR and ,6 except for IJ=0.3.

2-236
2.4

2.2-

DF-max[0.6AR 0 8 , 1.01

2.0

1.8

1.6

03

Vl.4

1.2

0.8

0.6

1.5 2.0 2.5 3.0 3.5 4.0 4.5

Amplitude Ratio (AR)

Figure 2.5.2-14 Comparison of exact and approximate DF. Exact DFvaries with both .AR

and a, while approximate DFdepends only on AR.

2-237
2.5.2.1.6.2 Target Annual Performance Goal

In RAI 2.5.2:7(a),-the staff asked the applicant to justify the selection of the mean annual

frequency of 1 0- as the safety performance target for the unacceptable performance of

Category I SSCs as a result of seismically initiated events. In response to RAI 2.5.2-7(a), the

applicant stated that the primary basis for the target 10i5 annual performance goal is from the

results of seismic PRAs of 25 nuclear power plants (NUREG-1742, "Perspectives Gained from

the IPEEE Program"), which show the median value for the mean seismic core damage

frequency (SCDF) to be 1.2x10-5. In addition, the applicant stated the following:

The approach described in Section 2.5.2 of the EGC ESP SSAR is based on the

recently approved ASCE/SEI Standard 43-05, Seismic Design Criteria for

Structures, Systems, and Components in Nuclear Facilities and Commentary.

This standard uses a mean 1 0.5 probability per year of "unacceptable

performance of nuclear structures, systems, and components as a result of

seismically initiated events" for nuclear power plants. As noted subsequently in

this response, the quantitative goal of this performance-based approach is to

achieve an annual frequency of seismically induced core damage frequency

([S]CDF) that is 10 5 or lower, when conservatively estimated by calculating the

annual frequency of onset of significant inelastic deformation (FOSID) of

structures, systems, and components (SSCs).

Justification for the use of mean 10 5 per year as an appropriate performance

goal is based on work that was published in 2002 as NUREG-1 742, as

summarized below.

The selection of mean 10-5 annual frequency of exceedance as an

appropriate performance goal for generic models of SSCs is based on

the results from seismic probabilistic risk assessments (PRA) that were

performed for 25 operating nuclear facilities using an SSE ground motion

spectrum. These PRAs achieved an annual mean [S]CDF of 10' or

higher for seismic core damage for 50 percent of the operating power

plants. The computed results were provided previously in the response

to RAI 2.5.2-1. The summary table shows that a mean 10`5 annual

frequency of core damage from seismic events corresponds to

50 percent of U.S. nuclear power plants where a full seismic PRA has

been performed.

The annual frequency of onset of significant inelastic deformation

(FOSID) of structures, systems and components is generally much less

than failure of the SSC. Failure results in large inelastic

deformations-leading to loss of containment or other unacceptable

performance. As long as the SSCs remain essentially elastic in their

performance-or have limited inelastic response-performance during

the seismic event is considered acceptable. It is generally recognized

that [seismic] core damage frequency ([S]CDF) is typically less than the

highest SSC failure frequency-indicating that by using [S]CDF as a

basis for design, the approach is conservative relative to other SSCs.

2-238
By following the ASCE/SEI Standard 43-05 method, the target

performance goal annual frequency is achieved so long as the seismic

demand and structural capacity evaluations have sufficient conservatism

to achieve both of the following:

- Less than approximately a 1 percent probability of unacceptable

performance for the SSE, and

- Less than approximately a 10 percent probability of unacceptable

performance for a ground motion equal to 150 percent of the SSE.

Plants reviewed and approved using the USNRC Standard Review Plan

guidelines have achieved at least these levels of conservatism.

The mean 10'5 annual frequency of core damage represents a means for

achieving safe plant design. Safe plant design is the underlying goal of

developing the selected SSE spectrum as reflected in the first paragraph in

10 CFR 100.23:

This section sets forth the principle geologic and seismic

considerations that guide the Commission in its

evaluations of the suitability of a proposed site and

adequacy of the design bases established in consideration

of the geologic and seismic characteristics of the proposed

site, such that there is a reasonable assurance that a

nuclear power plant can be constructed and operated at

the proposed site without undue risk to the health and

safety of the public

The requirement for no undue risk is met by determining an SSE

spectrum that results in a plant that is as safe as the safest plants

currently operating. The results of the seismic PRA analyses

summarized above indicate that this objective is satisfied for a mean 1 0'

frequency.

In summary, the applicant made four main points in response to RAI 2.5.2-7(a) in order to

justify the value of mean 1 O'5 per year as an appropriate performance goal:

(1) The results from seismic PRAs, which were performed for 25 nuclear facilities, show an

annual mean SCDF of 1 0' or higher for 50 percent of the operating power plants.

(2) Setting the performance goal of 1O's to be equivalent to the annual FOSID of SSCs is

conservative since the seismic demand resulting in the onset of significant inelastic

deformation is less than that for failure of the SSC.

(3) The target 10-5 annual performance goal is achieved so long as seismic demand and

structural capacity evaluations have sufficient conservatism, which is inherent for plants

reviewed and approved using the SRP guidelines.

2-239
(4) The target 1 O5 annual performance goal results in a plant that is as safe as the plants

currently operating, as shown by the seismic PRAs.

The primary basis for the target 10 5 annual performance goal is from the results of seismic

PRAs of 25 nuclear power plants (NUREG-1 742), which show the median value for the mean

SCDF to be 1.2x10O5. Figure 2.5.2-15 below shows the results of the seismic PRAs from

NUREG-1 742 in terms of mean ground motion recurrence interval, which is the inverse of mean

SCDF. Mean ground motion recurrence intervals for seismic core damage based on the

seismic PRA results of 25 nuclear power plants vary from 4,000 to 5,263,158 years. In

comparison, the FOSID value in terms of mean ground motion recurrence interval is set at

100,000 years for the performance-based approach.

2-240
l e+07 -:

le+06

0

0

0

0

0

0

1-

._

E

1)

c)

Performance Target (FOSID)

100000 - Median Seismic Core Damage Frequency 25 Plants

9 NUREG-1742 (2001)

0

19

0

0

0

10000 -:

1000 -

Figure 2.5.2-15 Seismic core damage in terms of mean ground motion recurrence

interval for 25 nuclear power plants. For comparison, FOSID is also shown.

2-241
2.5.2.1.6.3 Vertical SSE

To compute the vertical SSE, the applicant used the vertical-to-horizontal (V/H) response

spectral ratios provided in NUREG/CR-6728. The V/H response spectral ratios given in

NUREG/CR-6728 are CEUS hard rock site conditions and depend on the PGA value of the

horizontal SSE spectrum. For the ESP site, the V/H ratios used by the applicant are based on

having a PGA less than 0.5g. The vertical SSE spectrum is given by multiplying the horizontal

SSE spectrum by the V/H ratios. The applicant also considered the effects of the ESP site soil

conditions on the vertical ground motions by using ground motion models that provide vertical

motions for soil conditions. The applicant used a magnitude 6.4 earthquake at source-to-site

distance of 15 km ( 9 mi) as input to the ground motion models. This magnitude and distance

roughly correspond to the high-frequency controlling earthquake.

2.5.2.1.6.4 Design Response Spectrum

In SSAR Section 3.4.1.4.3, "Seismology," the applicant compared the horizontal SSE for the

ESP site with the RG 1.60, "Design Response Spectra for Seismic Design of Nuclear Power

Plants," design response spectrum (DRS) anchored to a PGA of 0.3g at 33 Hz, which is the

DRS used by many of the current reactor designs. The applicant noted that the ESP SSE is

lower than the RG 1.60 DRS except at frequencies between 16 and 50 Hz. The applicant

stated that these exceedances are considered acceptable based on high-frequency evaluations

discussed in a 1993 EPRI study, uAnalysis of High-Frequency Seismic Effects." The 1993 EPRI

study recommends reduction factors for ground motion at 10 Hz and above because of the

higher incoherence of high-frequency ground motion compared to low-frequency ground

motion. These reduction factors are 10 percent for ground motion at a frequency of 10 Hz and

increase to 20 percent for ground motion frequencies of 25 Hz and larger. The applicant stated

that its ESP SSE, after applying the reduction factors, is completely enveloped by the RG 1.60

DRS. The applicant concluded by stating that the high-frequency exceedances of the RG 1.60

DRS by the ESP SSE are not significant, which indicates that the "EGC ESP site is suitable for

any design based on the RG 1.60 DRS." This is discussed further in SER Section 2.5.2.3.6.4.

Figure 2.5.2-16 shows the horizontal and vertical SSEs as well as the RG 1.60 DRS anchored

to a PGA of 0.3g.

2-242
1.4

1.2

co1.0

0 .

0.6-

0.4-

0.2

0.0-

0.1 1 10 100

Frequency (Hz)

Figure 2.5.2-16 EGC ESP horizontal and vertical ESP SSE as well as the RG 1.60 DRS;

anchored at 0.3g

2-243
2.5.2.1.7 Operating-Basis Earthquake

SSAR Section 2;5.2.7Tstates that the applicant did not-determine the OBE as part of the ESP

application.

2.5.2.2 Regulatory Evaluation

SSAR Section 2.5.2 presents the applicant's determination of ground motion at the ESP site

from possible earthquakes that might occur in the site region and beyond. In SSAR

Section 1.5, the applicant stated that it developed the geological and seismological information

used to determine the seismic hazard in accordance with regulations listed in Section 2.5.2 of

RS-002, which include 10 CFR 50.34, "Content of Applications; Technical Information,"

Appendix S, "Earthquake Engineering Criteria for Nuclear Power Plants," to 10 CFR Part 50,

and 10 CFR 100.23. The applicant further stated in SSAR Section 1.5 that it developed this

information in accordance with the guidance presented in RG 1 .165. The staff reviewed this

portion of the application for conformance with the regulatory requirements and guidance

applicable to the determination of the SSE ground motion for the ESP site, as identified below.

The staff notes that the application of Appendix S to 10 CFR Part 50 in an ESP review, as

referenced in 10 CFR 1 00.23(d)(1), is limited to defining the minimum SSE for design.

In its application review, the staff considered the regulatory requirements of 10 CFR

52.1 7(a)(1 )(vi) and 10 CFR 100.23(c) and (d), which require that the applicant for an ESP

describe the seismic and geologic characteristics of the proposed site. In particular, 10 CFR

100.23(c) requires that an ESP applicant investigate the geological, seismological, and

engineering characteristics of the proposed site and its environs with sufficient scope and detail

to support estimates of the SSE ground motion, and to permit adequate engineering solutions

to actual or potential geologic and seismic effects at the proposed site. In addition, 10 CFR

100.23(d) states that the SSE ground motion for the site is characterized by both horizontal and

vertical free-field ground motion response spectra at the free ground surface. Section 2.5.2 of

RS-002 provides guidance concerning the evaluation of the proposed SSE ground motion, and

RG 1.165 provides guidance regarding the use of PSHA to address the uncertainties inherent in

the estimation of ground motion at the ESP site.

2.5.2.3 Technical Evaluation

This section of the SER provides the staff's evaluation of the seismological, geological, and

geotechnical investigations the applicant conducted to determine the SSE ground motion for the

ESP site. The technical information presented in SSAR Section 2.5.2 resulted from the

applicant's surface and subsurface geological, seismological, and geotechnical investigations

performed in progressively greater detail as they moved closer to the ESP site. The SSE is

based upon a detailed evaluation of earthquake potential, taking into account regional and local

geology, Quaternary tectonics, seismicity, and specific geotechnical characteristics of the site's

subsurface materials.

SSAR Section 2.5.2 characterizes the ground motions at the ESP site from possible

earthquakes that might occur in the site region and beyond to determine the site SSE spectrum.

The SSE represents the design earthquake ground motion at the site and the vibratory ground

motion for which certain nuclear power plant SSCs must be designed to remain functional.

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Accorcing to RG 1.165, applicants may develop the vibratory design ground motion for a new

nuclear power plant using either the EPRI or LLNL PSHAs for the CEUS. However, RG 1.165

recommends that applicants perform geological, seismological, and geophysical investigations

and evaluate any relevant research to determine whether revisions to the EPRI or LLNL PSHA

databases are necessary. As a result, the staff focused its review on geologic and seismic data

published since the late 1980s that could indicate a need for changes to the EPRI or LLNL

PSHAs.

2.5.2.3.1 Seismicity

The staff focused its review of SSAR Section 2.5.2.1 on the adequacy of the applicant's

description of the historical record of earthquakes in the region. The earthquake catalog used

in the criginal EPRI-SOG analysis is complete through 1984. To update the earthquake

catalog, the applicant used information from NCEER, USGS, and ANSS. Next, the applicant

compared the geographic distribution of earthquakes contained in the EPRI-SOG earthquake

catalog (1777-1985) and the earthquakes in the updated catalog (1985-2002). The applicant

stated that it found a very similar spatial distribution between the earthquake epicenters for Ihe

two tim a periods.

In addition to updating the EPRI-SOG earthquake catalog with more recent events, the

applicant also added prehistoric earthquakes to the catalog, inferred from the evaluation of

prehistoric liquefaction information in the ESP site region. These additions include earthquakes

from the NMSZ, Wabash Valley-southern Illinois source zone, and the central Illinois

basin/background source zone. The most notable addition to the catalog is the Springfield

earthquake whose magnitude and location are inferred from paleoliquefaction features

discovered approximately 30 miles southwest of the ESP site. These features are from an

earthquake centered in the Springfield, Illinois, area that occurred between 5900 and

7400 years ago with an estimated magnitude range of 6.2 to 6.8.

The applicant also conducted paleoliquefaction studies to search for paleoliquefaction features

within a 25-30-mile radius of the ESP site. After analyzing the field reconnaissance results, the

applicant concluded that evidence for an earthquake comparable to the Springfield earthquake

had not been observed in the study area. The applicant did discover some small-scale

liquefaction features of probable mid-to-early Holocene age; however, these features were not

widespread and likely resulted from a low-magnitude event. In RAI 2.5.2-6, the staff asked tile

applicant to explain its selected paleoliquefaction study area along the streams near the ESF'

site. In response, the applicant stated that it selected locations along the Salt Creek,

Sangamon River, and Mackinaw River to supplement previous liquefaction studies in this area.

SER Section 2.5.1.3.1 provides a complete description of RAI 2.5.2-6 and the staff's evaluation

of the applicant's response.

Because the applicant used the EPRI-SOG seismicity catalog, which is part of the 1989 EPRI

seismic hazard study that the NRC endorsed, the staff concludes that the seismicity catalog

used by the applicant is complete and accurate for the time period 1777-1985. The staff

compared the applicant's update of the regional seismicity catalog with its own listing of recent

earthquakes and, as a result, concurs with the applicant's assertion that the rate of seismic

activity has not increased in the ESP site region since 1985. In addition, the staff reviewed the

paleoearthquakes that the applicant added to its earthquake catalog based on evidence from

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paleoliquefaction features discovered in the NMSZ, WVSZ, and central Illinois seismic zone.

The staff concludes that the earthquake catalog used by the applicant is complete and provides

a conservative estimate of earthquake magnitudes and locations for the ESP site region.

2.5.2.3.2 Geologic Structure and Tectonic Activity

The staff focused its review of SSAR Section 2.5.2.2 on the applicant's characterization of

potential seismic sources in the region surrounding the ESP site. As part of its evaluation of the

geologic structure and tectonic activity for the ESP site, the applicant performed a detailed

update of the structural features (folds and faults) within the site region. The applicant

concluded that the results of the information update on the structure features show that the

general structural picture remains the same. Chapter 2 of SSAR Appendix B provides a

description of each of the folds and faults surrounding the ESP site. Rather than attempting to

characterize the seismic potential of these folds and faults, the applicant defined broad seismic

source zones that encompass these structural features. Within a 200-mile radius of the site (or

just beyond), the two major sources of potential earthquakes are the NMSZ and WVSZ. In

addition to the NMSZ and WVSZ, evidence from recent paleoliquefaction studies indicates that

significant earthquakes have occurred in the central Illinois basin, where there are no obvious

folds or faults at the surface. Although the size, location, and recurrence of such events are

not well constrained, the applicant developed a background source zone for this region,

referred to as the central Illinois basin background source zone. The staff's evaluation of the

applicant's characterization of these areal seismic sources for its PSHA is provided in SER

Section 2.5.2.3.3.

In addition to evaluating regional structural folds and faults, the applicant also evaluated the

regional tectonic setting for the ESP site using the most recent results from a GPS network in

southern Illinois. The applicant reported that given the current level of error in individual GPS

observations, an extended period of time will be required before these observations can fully

characterize the regional strain field. The applicant also found that recent geodetic

measurements in the NMSZ indicate that the rate of strain accumulation is below the current

detection threshold; however, these observations are not inconsistent with a model of seismicity

in intraplate regions occurring along weak zones in the crust.

The staff reviewed the applicant's description of the individual structural features (folds and

faults) for completeness and accuracy. SER Section 2.5.1.3.1 provides the staff's review of the

applicant's description. The staff concurs with the applicant's decision to use large areal

seismic source zones rather than attempting to characterize the seismic potential of each of the

regional structural features. Both the LLNL and EPRI PSHA seismic source models, endorsed

by RG 1.165, use this approach. As described in SER Section 2.5.2.3.3, the applicant updated

the EPRI-SOG source model for its PSHA for the ESP site.

2.5.2.3.3 Correlation of Earthquake Activity with Geologic Structure or Tectonic Province

The staff focused its review of SSAR Section 2.5.2.3 on the applicant's updating of the original

EPRI-SOG seismic source and ground motion models for its PSHA for the ESP site. The

applicant based its update on an evaluation of recent geological and seismological information.

The specific areas that the applicant focused on for each of the three major seismic source

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zones (NMSZ, WVSZ, and central Illinois) are earthquake recurrence rates, maximum

magnitudes, and ground motion attenuation.

Earthquake Recurrence Rates. The applicant compared the updated seismicity catalog with an

additional 17 years of earthquake data to the original EPRI-SOG catalog and found that the

recurrence rates used for the EPRI-SOG study are still valid. In addition to the smaller

recorded events over the past 17 years, the applicant also added earthquakes that have

occurred in the three source zones as revealed by paleoliquefaction studies. The applicant

found that for the central Illinois basin and the WVSZ, the fit of earthquake recurrence

relationships to the recorded seismicity envelops the rates of larger earthquakes estimated from

paleoliquefaction data. However, for the NMSZ, the applicant found that recent

paleoliquefaction data provide evidence that large-magnitude earthquakes have occurred on

NMSZ faults more frequently than the seismicity rates specified in the EPRI-SOG source

characterizations for NMSZ.

As described in SER Section 2.5.2.1.3, the applicant used the characteristic earthquake model

for the occurrence of large earthquakes in the NMSZ. The characteristic earthquake model

states that certain fault segments tend to move by approximately the same distance in each

earthquake, implying that individual faults repeatedly generate earthquakes of similar size at or

near their maximum magnitude. For the NMSZ, the three fault sources that the applicant

modeled with the characteristic approach are the NS fault, NN fault, and RF. Based on the

characteristic earthquake model, these three faults within the NMSZ have repeatedly generated

similar sized earthquakes during each of the previous NMSZ earthquake sequences, including

the most recent 1811-1812 sequence. The best constraints on recurrence of characteristic

NMSZ events are from paleoliquefaction studies throughout the New Madrid seismic region and

paleoseismic investigations of the RF scarp and associated fold. Based on these studies,

researchers have found that NMSZ characteristic earthquake sequences have occurred around

AD 145() ± 150, AD 900 ± 100, AD 490 ± 50, AD 300 ± 200, and BC 1370 ± 970, in addition lo

the recent 1811-1812 sequence. The applicant fit the recurrence intervals between these

dates with two recurrence models, a Poissonian model and a lognormal model, weighing each

model equally. In addition, for each of these NMSZ earthquake sequences, the applicant

determined, based on its review of the literature, that the RF has ruptured in each of the

previous sequences but the NN and NS sources may not have produced large earthquakes ii

all three sequences. The applicant used these observations to set the relative frequency of

event sequences in the NMSZ as (1) rupture of all three sources (NN, RF, and NS) one-third of

the time, (2) rupture of NN and RF one-third of the time, and (3) rupture of NS and RF one-third

of the time.

In RAI 2.5.2-5, the staff asked the applicant to justify its modeling of the relative frequency of

event sequences in the NMSZ. Specifically, the staff noted that Tuttle et al. (2002) concluded

that all three sources (RF, NN, and NS) ruptured in each of the three sequences, but that onethird of the time the NN rupture may have been smaller than for the 1811-1812 sequence, arid

one-third of the time NS may have been smaller than in 1811-1812. Tuttle et al. (2002) also

concluded that these smaller earthquakes are at least magnitude 7 events. This result differs

from the event sequence modeling used by the applicant for NMSZ, which does not include NN

or NS for some of the event sequences. The applicant responded to RAI 2.5.2-5 by stating the

following:

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For the seismic source model developed for the New Madrid characteristic

earthquakes in Appendix B of the EGC ESP SSAR, Figure 6 of Tuttle et al.

(2002) was used to infer that previous ruptures of the New Madrid North and

New Madrid South faults may have been approximately one magnitude unit

smaller than the estimated site of the 1811-1812 ruptures. The magnitudes for

the 1811-1812 sequence shown on Figure 6 of Tuttle et al. (2002) were those

developed by Johnston (1996). The information presented on Figure 6 of Tuttle

et al. (2002) was used to infer the relative size of ruptures of the New Madrid

North and New Madrid South faults in the 1450 and 900 sequences compared to

the 1811-1812 ruptures. Thus, if the size of the 1811-1812 ruptures on these

faults were in the low magnitude M 7 range (e.g., values estimated by Bakun and

Hooper, 2003), then the size of previous ruptures would have been below

magnitude M 7. These smaller ruptures, which would be considered dependent

events, were not included in the hazard calculations as characteristic

earthquakes. The rupture model developed for the New Madrid characteristic

earthquake sources in the EGC ESP Application consisted of three possible

sequences, each occurring with a relative frequency of 1/3. One sequence

consisted of full ruptures of all three New Madrid faults; one sequence consisted

of full rupture of the New Madrid North and Reelfoot thrust faults, with the rupture

of the New Madrid South fault being approximately one magnitude unit smaller

than the 1811 rupture (this smaller dependent event was not included in

calculating the hazard); and one sequence consisted of the full rupture of the

New Madrid South and Reelfoot thrust faults, with the rupture of the New Madrid

North fault being approximately one magnitude unit smaller than the 1811

rupture (this smaller dependent event was not included in calculating the

hazard).

For two of the three NMSZ earthquake sequence models, the applicant considered either the

NN or NS a smaller dependent event and, as such, did not include this smaller event for its

calculation of the hazard. Dependent events are generally considered to be aftershocks of the

main event, and, although dependent events can cause significant damage, a PSHA is

intended to evaluate the hazard from discrete, independent releases of seismic energy.

Therefore, dependent events are removed from the seismicity database before calculating the

final PSHA hazard curves. However, the difference in magnitude between the three

earthquakes in the NMSZ sequences is uncertain; therefore, the applicant's decision to identify

either the NN or NS as smaller dependent events (for two of the three sequences) and not

include them in the hazard calculation is questionable. In its response to RAI 2.5.2-5, the

applicant stated that it discussed its NMSZ event sequence modeling with Dr. Tuttle since the

model is based on an interpretation of Figure 6 of Tuttle et al. (2002). The applicant stated the

following regarding its discussion with Dr. Tuttle:

In addition, recent discussions with Dr. Tuttle indicate that she considers that the

difference between the size of the 1811-1812 earthquakes and those of the 900

and 1450 sequences are likely to be smaller than what was portrayed in Figure 6

of Tuttle et al. (2002). Consequently, a revised model for New Madrid

sequences was developed consisting of two alternative models for earthquake

sequences. In Model A, all ruptures are similar in size to the 181 1-1812

earthquakes. Model B is similar to the model used in PSHA for the EGC ESP

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Application in that 1/3 of the sequences contain a smaller rupture of the New

Madrid North fault and 1/3 of the sequences contain a smaller rupture of the New

Madrid South fault. However, the difference in magnitude from the 1811-1812

ruptures was set to be no more than Y magnitude unit, and no ruptures were

allowed to be less than M 7. In addition, all three earthquakes were included in

the hazard calculation in all rupture sequences. Model A (always full ruptures)

was given a weight of 2/3 and Model B a weight of 1/3 based on Dr. Tuttle's

expression of the difficulties in estimating the size of the pre 1811-1812 ruptures

and her judgment that the difference between the rupture sizes was likely

smaller than that proposed in Tuttle et al. (2002). The hazard resulting from this

revised model for rupture sequences combined with the updated magnitude

distribution (response to RAI 2.5.1-1) is shown on the curves labeled "Revised

magnitudes and sequences" on Figure 2.5.2-5-1. These results produce

approximately 9 to 10 percent higher ground motions at the mean 1 04 and mean

10'5 hazard levels.

The staff reviewed the Tuttle et al. (2002) paper and found that the authors' "preferred

interpretation of prehistoric sand blows" is that "at least two earthquakes occurred in A.D. 1450

and A.D. 900 that were similar in size and location to the largest 1811-1812 earthquakes."

Based on this statement, the staff concurs with the applicant's revised modeling as described

above in response to RAI 2.5.2-5. The staff notes that the applicant found that the hazard

resulting from this revised model for rupture sequences combined with the updated magnitude

distribution (response to RAI 2.5.1-1) produce approximately 9 to 10 percent higher ground

motions at the mean 10'4 and mean 10-5 hazard levels. In summary, regarding the updated

information for the NMSZ (magnitude distribution for rupture sets and ruptures sequence

models), the applicant stated the following in its response to RAI 2.5.2-5:

The assessment of the size of the 1811-1812 earthquakes and the likely

scenarios for future ruptures continues to be an area of active research, and

thus it is possible that the assessments presented in the ESP Application will

undergo future evolution. It is expected, however, that the effects of these

changes will be on the order of those presented in the sensitivity analyses

presented in this response, and the calculated 1-Hz ground motions

corresponding to the mean hazard in the 1 0-4and 1 05 range will vary from those

presented in the ESP Application by plus or minus 10 percent or less. A revision

to the EGC ESP Application, therefore, is not warranted at this time.

The stafi considers the applicant's rationale for not updating its seismic hazard characterization

of the NMSZ to be inadequate. In response to the staff's RAls, the applicant has updated both

the magnitudes for the NMSZ characteristic earthquake rupture sets (RAI 2.5.1-1) and rupture

sequence modeling (RAI 2.5.2-5). However, for both updates, the applicant only performed

limited sensitivity analyses and did not update either its PSHA or SSE. The staff considers both

of these updates to the NMSZ characteristic earthquake modeling to be of sufficient importance

to justify updating both the PSHA and SSE for the ESP site. In Open Item 2.5.1-1, the staff

asked the applicant to incorporate this newer information into its PSHA or SSE and to update

the SSAR to reflect the corrected magnitude estimates and rupture sequence modeling. In

response, the applicant updated its source characterization of the New Madrid earthquakes,

including both the magnitudes for the NMSZ characteristic earthquake rupture sets and rupture

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sequence modeling. These changes have been incorporated into Revision 1 of the ESP

application. Therefore, the staff considers Open Item 2.5.1-1 to be resolved.

In conclusion, as described above, the staff concurs with the applicant's decision to incorporate

the characteristic earthquake model for the large NMSZ earthquakes into the original

EPRI-SOG model. In addition, the staff concurs with the applicant's use of the most recent

models for the NMSZ rupture sequences.

Maximum Magnitudes. The applicant focused on the maximum magnitude values for the

NMSZ, WVSZ, and central Illinois background seismic source zone, since these three zones

are the main contributors to the total seismic hazard at the ESP site. For the NMSZ, the

applicant concluded that the maximum magnitudes used for the EPRI-SOG model (7.2 to 8.8)

are consistent with the more recent maximum magnitude evaluations (7.4 to 8.2). For the

WVSZ, the maximum magnitudes range from 5.0 to 8.0, while recently published maximum

magnitudes range from 7.0 to 7.8. Similarly, for the central Illinois background source zone, the

maximum magnitudes used for the EPRI-SOG model range from 4.3 to 7.6, while recently

published maximum magnitudes range from 6.0 to 7.0. As a result, the applicant concluded

that the maximum magnitude values for both the WVSZ and central Illinois source zone need to

be increased to reflect the magnitudes implied by recent paleoliquefaction studies.

The staff reviewed the NMSZ, WVSZ, and central Illinois source zone maximum magnitudes

used by the applicant for its PSHA for the ESP site. The staff concurs with the applicant's

conclusion that the EPRI-SOG maximum magnitudes for the NMSZ adequately cover the range

of magnitudes estimated from recent geologic investigations, as described above. For the

WVSZ, the staff reviewed the revised maximum magnitude range used by the applicant to

verify its consistency with recent paleoliquefaction studies. The magnitude of the largest

paleoearthquake in the lower Wabash Valley (the Vincennes-Bridgeport earthquake), which

occurred 6011 ± 200 years ago, was estimated to be between 7.2 to 7.8. The next largest

earthquake in the WVSZ has an estimated magnitude of about 7.1 to 7.2 and occurred 12,000

t 1,000 years ago. The applicant used the following maximum magnitude range for the

Wabash Valley region-M 7.0 (0.1), M 7.3 (0.4), M 7.5 (0.4), and M 7.8 (0.1). Based on the

magnitudes of these two paleoearthquakes, the staff considers that the applicant's maximum

magnitude range and weighting are appropriate for the WVSZ.

For its update of the maximum magnitudes of the central Illinois basin/background source zone,

the applicant used a 1994 EPRI study that specifically addresses the problem-of defining a

maximum magnitude for seismic source regions that are characterized by the rare occurrence

of maximum earthquakes without well-defined seismicity patterns associated with seismic

sources. The 1994 EPRI study developed worldwide databases that could be used for

assessments of maximum magnitudes for seismic sources in the CEUS. Using the database

and method found in the 1994 EPRI study, the applicant developed the following maximum

magnitude range for earthquakes in the central Illinois source zone-M 6.2 (0.4), M 6.4 (0.3),

M 6.6 (0.2), and M 6.8 (0.1). This range of maximum magnitudes is strongly influenced by the

estimated M 6.2 to 6.8 Springfield earthquake, which occurred about 6000 years ago about

30 miles to the southwest of the ESP site. In RAI 2.5.2-4, the staff asked the applicant to

provide further detail and justification regarding its use of the 1994 EPRI study and

accompanying worldwide database of earthquakes. Specifically, the staff requested the

applicant to explain why its maximum magnitude for central Illinois should not be set at 6.8

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since the two largest SCR earthquakes from nonextended crust are the Accra, Ghana,

earthquake of 1862 (M 6.75 ± 0.35) and the Meeberrie, Western Australia, earthquake of 1941

(M 6.7E8 ± 0.25). In its response to RAI 2.5.2-4, the applicant stated the following regarding its

use of ihe 1994 EPRI study and its maximum magnitude for central Illinois:

The EPRI-SOG assessments of seismic source characteristics in the CEUS did

not start with the assumption that maximum magnitude is the same throughout

the region or even throughout regions with similar characteristics. The

EPRI-SOG assessments of maximum magnitude for the central Illinois source

zone needed to be updated because of new information-the discovery of the

Springfield paleo-earthquake. This update could have been performed using the

EPRI-SOG approach-expert elicitation, but this would require a major study

comparable to the EPRI-SOG program. As an alternative, the Johnston et al.

4:1994) Bayesian approach [1994 EPRI study] was used. The Johnston et al.

:1994) Bayesian approach was developed as part of a study specifically focused

on the assessment of maximum magnitudes in Stable Continental Regions

(SCR). It provides a quantitative approach based on evaluation of a worldwide

database of SCR earthquakes and crustal domains. This approach provides a

reasonable method for assessing the uncertainty in maximum magnitude.

The Bayesian approach for estimating maximum magnitude developed by

Johnston et al. (1994) does not start from the assumption that all SCR domains

have the same maximum magnitude. Instead it assumes that there are

characteristics that control the maximum size of an earthquake that can occur in

an individual SCR domain and these characteristics vary from domain to domain,

just as the maximum size of earthquakes varies for other source types (e.g.,

plate-boundary faults, subduction zones). The statistical analysis presented in

Chapter 5 of Johnston et al. (1994) explored the utility of using the

characteristics of the SCR domains as predictors of maximum magnitude. The

first step in the process was the development of "super domains" by "pooling" the

data for domains that "cannot, with the information available, be considered

different." The primary objective of pooling was to increase the earthquake

sample size for a given super domain to provide a more constrained estimate of

maximum magnitude. The resulting super domains were distinguishable from

each other using the tectonic, geologic, and seismologic information gathered as

part of the project. The prior distribution from Johnston et al. (1994) used in the

EGC ESP probabilistic seismic hazard analysis (PSHA) assessment of maximum

magnitude for central Illinois was based on grouping all of the 15 non-extended

dust super domains and estimating the statistics of the maximum magnitudes of

that group of domains. These 15 super domains all had the common

characteristic of non-extended crust, but differ in other characteristics that may

or may not be related to differences in maximum magnitude, such as crustal age,

state of stress, and orientation of stress relative to structure. The Johnston et al.

(1994) analysis did not assume that all of the non-extended crust super domains

are identical, and thus would have the same maximum magnitude.

Using the EPRI (1994) approach, the applicant developed the maximum magnitude distribution

described above (M 6.2 (0.4), M 6.4 (0.3), M 6.6 (0.2), and M 6.8 (0.1)), with a mean maximum

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magnitude of 6.65. As requested by the staff in RAI 2.5.2-4, the applicant compared the 10-Hz

spectral acceleration hazard curves for the ESP site using its maximum magnitude distribution

for centralIllinois versus a'single fixed value of a maximum magnitude equal to 6.8. The

applicant found that the two maximum magnitude distributions yield nearly the same hazard,

with the single value of M 6.8 maximum magnitude producing approximately only 2 to 3 percent

higher ground motions at the mean 104 and mean 10-5 hazard levels.

To determine the adequacy of the maximum magnitude distribution used by the applicant for

the central Illinois seismic source zone, the staff reviewed the 1994 EPRI study and,

specifically, the Bayesian analysis recommended by the study. The Bayesian approach to

assessing maximum magnitude is derived from the statistical analysis of the SCR global

earthquake database (prior distribution) in combination with local or regional earthquakes (e.g.,

the Springfield earthquake). The prior magnitude distribution, based on the global earthquake

database, is combined with information (the sample likelihood function for maximum magnitude)

specific to the regional seismic source of interest, and the final product is a probabilistic

distribution (posterior distribution) of maximum magnitude that incorporates uncertainties in the

assessment. The Bayesian analysis used by the applicant for the central Illinois maximum

magnitude produces a posterior distribution of maximum magnitude having a modal value of

M 6.5 and a mean of M 6.7. This mean maximum magnitude is close to the value (M 6.8) used

by the USGS for its national hazard maps and also to the magnitudes of the two largest

earthquakes globally observed (Ghana and Australia) in nonextended SCR domains, similar to

the central Illinois source zone. The staff notes, as described above by the applicant, that the

difference between these two maximum magnitudes (M 6.7 and 6.8) is insignificant, producing

only 2 to 3 percent higher ground motions at the mean 1 O' and mean 1 0' hazard levels. The

staff also notes, based on its review of the global earthquake database used by the 1994 EPRI

study, that no nonextended SCR domain has had a historical earthquake of M 7.0 or larger.

Although this observation from the historical record of SCR seismicity is based on a small time

sample of one to a few centuries, the historical record includes all known SCR earthquakes. In

addition, there are no tectonic processes that affect SCRs and operate fast enough to undercut

the assumption that the SCR seismicity of a few centuries before the SCR historical record

likely looks much like the historical record itself. As such, the 1994 EPRI global database for

SCR earthquakes provides a first-order description of how SCR crust behaves seismically in

the present millennium or so of the present plate-tectonic cycle. In summary, the staff

concludes that the applicant's use of the global SCR earthquake database in combination with

paleoliquefaction data for the central Illinois source zone results in an adequate characterization

of the maximum magnitude distribution of the central Illinois seismic source zone.

In conclusion, as described above, the staff concurs with the applicant's decision to increase

the maximum magnitude distributions of the WVSZ and central Illinois source zone.

Ground Motion Attenuation. As described in SSAR Section 2.5.2.3, the original EPRI-SOG

study used three attenuation relationships, developed in the mid 1980s. Since the completion

of the EPRI-SOG study, estimating ground motions in the CEUS has been the focus of

considerable research. The applicant used the expert-elicitation guidance in NUREG/CR-6372

to characterize the distribution of ground motion prediction for the CEUS. This study and the

resulting CEUS ground motion attenuation relationships are described in an EPRI 2003

publication. The EPRI study grouped the selected ground motion attenuation relationships into

four clusters, in which each cluster represents a group of models based on a similar approach

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for ground motion modeling. After comparing the three attenuation models used for the

EPRI-';OG study with the new EPRI ground motion study, the applicant concluded that the

recent median ground motion models are generally consistent with two of the three older

models. However, the estimates of uncertainty or variability about the median ground motion

predict ons are considerably higher for the recent ground motion attenuation relationships

compiled by the recent EPRI study compared to the uncertainty in the ground motion used f r

the original EPRI-SOG study. Therefore, the applicant decided to use the updated attenuation

models.

In RAI 2.5.2-3, the staff asked the applicant to describe how the recent EPRI ground motion

study converted the distance measure used for each of the attenuation relationships to a

common measure. Specifically, the 13 CEUS attenuation relationships selected by the EPRI

ground motion experts each use one of two different distance measures. In response to

RAI 2.5.2-3, the applicant provided a description of the method it used to convert the "pointsource" distance measure to the more commonly used Joyner-Boore distance measure. In

EPRI ground motion clusters 1, 2, and 4, all but two of the individual models (Frankel et al.,

1996; and Atkinson and Boore, 1995) use the Joyner-Boore distance, which is the closest

distance from the site to the surface projection of the fault rupture in kilometers. The other two

ground model attenuation relationships use the hypocentral distance, which is the distance from

the site to the earthquake focus in kilometers. To convert the point-source distance to the

Joyner-Boore distance, the applicant described the following method:

These two relationships [Frankel et al. (1996) and Atkinson and Boore (1995)]

were converted to Joyner-Boore distance by simulating a data set in terms of

moment magnitude and Joyner-Boore distance and fitting this simulated data

set. At a given Joyner-Boore distance, earthquake point source depths were

simulated for a range of magnitudes using the point-source depth distributions

for the CEUS proposed by Silva et al. (2002). These consist of lognormal

distributions with the parameters listed in the following table.

Point-Source Depth Distribution Parameters (from Silva et al. 2002)

Magnitude Minimum Depth Median Depth Maximum Depth %in(D)

4.5 2 km (1 mi) 6 km (4 mi) 15 km (9 mi) 0.6

5.0 2 km (1 mi) 6 km (4 mi) 15 km (9 mi) 0.6

5.5 2 km (1 mi) 6 km (4 mi) 15 km (9 mi) 0.6

6.0 3 km (2 mi) 7 km (4 mi) 17 km (11 mi) 0.6

6.5 4 km (2.5 mi) 8 km (5 mi) 20 km (12 mi) 0.6

7.0 4.5 km (2.8 mi) 9 km (5.6 mi) 20 km (12 mi) 0.6

7.5 5 km (3 mi) 10 km (6 mi) 20 km (12 mi) 0.6

8.0 5 km (3 mi) 10 km (6 mi) 20 km (12 mi) 0.6

8.5 5 km (3 mi) 10 km (6 mi) 20 km (12 mi) 0.6

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For each simulation, the depth and the Joyner-Boore distance were used to

compute the corresponding point source distance. The median ground motion

for the given magnitude and point source distance were then computed using the

Frankel et al. (1996) and Atkinson and Boore (1995) relationships. The resulting

simulated data sets were then fit with an appropriate functional form to provide

ground motion relationships in terms of moment magnitude and Joyner-Boore

distance consistent with the other relationships in Clusters 1 and 2.

In Open Item 2.5.2-1, the staff requested further clarification regarding the EPRI study's

distance conversion process. In response, the applicant provided a detailed description of the

distance conversion process used in the EPRI CEUS ground motion model. Specifically, the

staff asked for clarification on the process used to convert Joyner-Boore distance to

hypocentral distance so that the two attenuation relationships based on hypocentral distance

can be combined with the relationships based on Joyner-Boore distance. In response, the

applicant provided a detailed description of the distance-conversion process for the two

attenuation relationships (Atkinson and Boore, 1995; and Frankel et al., 1996). The staff's

review of the distance-conversion process determined that the EPRI (2003) implementation

process provides a smooth variation with distance and results in somewhat higher median

ground motions only at very small values of Joyner-Boore distance. Therefore, the staff

considers Open Item 2.5.2-1 to be resolved.

The ESP applicant for the North Anna, Virginia, site also used the EPRI 2003 ground motion

study for its PSHA. Many of the staff's RAls and the open item related to the updated EPRI

CEUS ground motion modeling are described in Section 2.5.2 of the staff's final SER for North

Anna (ADAMS Accession No. ML051610246). After reviewing the North Anna ESP applicant's

responses to the staff's RAls and open item, the staff concluded that Dominion had adequately

resolved each of the staff's concerns with regard to the development by EPRI of new ground

motion models for the CEUS.

2.5.2.3.4 Maximum Earthquake Potential

The staff focused its review of SSAR Section 2.5.2.4 on the ESP site controlling earthquakes

determined by the applicant after completion of its PSHA. The applicant determined the lowand high-frequency controlling earthquakes by deaggregating the PSHA results at selected

probability levels. Before determining the controlling earthquakes, the applicant updated the

original EPRI-SOG PSHA using the seismic source zone adjustments and new ground motion

modeling described above in the previous SER subsection.

PSHA Results. The applicant performed PSHA calculations for PGA and spectral acceleration

at frequencies of 25, 10, 5, 2.5, 1, and 0.5 Hz. Following the guidance provided in RG 1.165,

the PSHA calculations were performed assuming generic hard rock site conditions (i.e., an

S-wave velocity of 9200 ft/s). The actual local site characteristics are incorporated in the

calculation of the SSE spectrum, which uses the hard rock PSHA hazard results as the starting

point.

Controlling Earthquakes. To determine the low- and high-frequency controlling earthquakes for

the ESP site, the applicant followed the procedure outlined in Appendix C to RG 1.165. This

procedure involves the deaggregation of the PSHA results at a target probability level to

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determine the controlling earthquake in terms of a magnitude and source-to-site distance. The

applicant chose to perform the deaggregation of the mean 104 and 10'5 PSHA hazard results.

The lov- and high-frequency controlling earthquakes are shown above in Table 2.5.2-1 in S ER

Section 2.5.2.1.4. For the high-frequency mean 10- hazard, the controlling earthquake is a

magnitude 6.5 event occurring at a distance of 83 km (52 mi), corresponding to an earthquake

from the WVSZ. In contrast, forthe high-frequency 1O0 hazard, the controlling earthquake has

a magnitude of 6.2 at a distance of only 24 km (15 mi). This controlling earthquake

corresponds to the Springfield earthquake from the central Illinois background source zone.

For the low-frequency mean 1 0-4 and 1 05 hazard, the controlling earthquake has a magnitude

of 7.2 at a distance of 320 km (199 mi). This earthquake corresponds to an event in the NMSZ.

Based on its review of the ESP site controlling earthquake magnitudes and distances, the staff

concludes that the applicant's PSHA adequately characterized the overall seismic hazard of the

ESP site. The staff also concludes that the applicant's controlling earthquakes for the ESP site

(magnitude of 6.2 at 24 km (15 mi), magnitude 6.5 at 83 km (52 mi), and magnitude of 7.2 al:

320 km (199 mi)) are generally consistent with both the historical earthquake record and

paleoliquefaction studies in the NMSZ, WVSZ, and central Illinois seismic source zone. In

addition, the staff finds that the ground motions developed by the applicant from the controlling

earthquakes (see SER Figure 2.5.2-2) are consistent with the most recent CEUS ground

motion evaluations. Accordingly, the staff concludes that the applicant followed the guidance in

RG 1.165 for evaluating the regional earthquake potential and determining the ground motion

resulting from the controlling earthquakes.

2.5.2.3.5 Seismic Wave Transmission Characteristics of the Site

The staff focused its review of SSAR Section 2.5.2.4 on the method used by the applicant to

develop the site free-field ground motion spectrum. The hazard curves from the PSHA are

defined for generic hard rock conditions. According to the applicant, these hard rock conditions

exist at the ESP site at a depth of several thousand feet or more below the ground surface. To

determine the free-field ground motion, the applicant performed a site response analysis.

The staff reviewed the applicant's analysis to ensure that it accurately incorporates the local site

properties and conditions as well as their uncertainties. The applicant developed 60 different

randomized soiVrock columns in order to model the uncertainties in the soil/rock properties,

such as Si-wave velocity, density, shear modulus, and damping. The applicant determined

these soil/rock properties through its field explorations and laboratory tests, which are described

in SER Section 2.5.4.

Based on the large range in S-wave velocities for some of the soil layers (Table 5-2 of SSAR

Appendix A) and the differences in SPT blowcount values for ESP borings B1 and B4

compared to those of B2 and B3, the staff in RAI 2.5.4-4 requested that the applicant justify tle

appropriateness of using a single "average" soil column for the site response analyses rather

than including a number of different base-case soil columns. In response to RAI 2.5.4-4, the

applicant stated that the variations in S-wave velocity and SPT blowcounts result from "changes

in the depositional conditions during formation of the soil profile and the geologic history of the

site following deposition." The applicant further stated that for the ESP site, the geologic history

includes the advance and retreat of a substantial thickness of ice during the last ice age. This

ice loaded the material located below approximately 50 ft, which led to very dense or hard soil

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conditions (i.e., overconsolidation) by the ice load. Because of the ice loading, the variability of

the soil existing below 50 ft after initial formation has been reduced. In contrast, the applicant

reported thatthe soil in the-upper-50 ft was formed by fluvial (river) and aeolian (wind)

processes, resulting in more variability both vertically and horizontally.

Regarding the modeling of this variability in soil properties, the applicant stated the following:

In recognition of the natural variability of the soil, the standard approach for site

response analyses is to account for the likely variation in soil layering and soil

properties within a specific layer by considering different combinations of soil

property and soil profile conditions that could exist at a site. One method for

evaluating these variations is by manually creating independent soil columns, as

suggested in the RAI. The alternative that was taken during the EGC ESP site

ground motion response studies was to statistically create a large number of

profiles, or realizations, and conduct the site response analyses using these

profiles.

The applicant concluded its response to RAI 2.5.4-4 by stating that the randomization process

used to develop the transfer functions at the ESP site allows the uncertainty in soil layering and

soil properties to be considered during the evaluation of site response effects.

The staff reviewed the applicant's response and found that the large variability in strength and

stiffness of the site soils, as demonstrated by the S-wave velocities and SPT blowcounts from

the relatively few borings taken at the EGC ESP site, indicates a potentially large epistemic

uncertainty in site profiles that cannot easily be captured directly by the randomization process.

In Open Item 2.5.2-2, the staff asked the applicant to further justify using only a single site

velocity model to account for the variability in strength and stiffness of the site soils. In

response, the applicant indicated that the soils in the upper 60 ft of the site will be removed

during plant construction and replaced by engineering fill. Since the fill material will be placed

under consistent compaction and gradation controls, the variability in shear wave velocity of the

engineered fill will be significantly lower than that of the in situ soils. As such, the staff

considers Open Item 2.5.2-2 to be resolved.

To account for the variability in soil shear strain modulus and material damping ratio with

shearing strain amplitude, the applicant randomized the shear modulus and damping curves

used for the site response analysis. In RAI 2.5.4-7, the staff asked the applicant to explain how

these curves were used in the randomization process with respect to both the different depth

ranges and the soil types occurring within those depth ranges. For example, the soil boring

logs indicated that some soils are clays and some soils are silty sands over the same particular

depth range. In response to RAI 2.5.4-7, the applicant stated that the modulus and material

damping curves are primarily dependent on the depth range and not on the material type. The

applicant stated that this is consistent with the development of the EPRI modulus reductions

and material damping curves (EPRI, 1993), in which the standardized curves are based only on

depth interval, thereby avoiding the need to link the modulus reduction curves and damping

curves to the soil boring log. The applicant further stated that the independence of the modulus

reductions and material damping curves from the specific soil type is based on laboratory tests

that show that the primary variable contributing to the variation in shape and absolute value of

the modulus reduction and material damping curves is the depth of the soil below the ground

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surface, which is an indication of the effective confining pressure on the soil sample. With

regard to other variables that may affect the shape and magnitude of the modulus reduction

and material damping curves, the applicant stated the following:

Since there is evidence that the type of soil also has some effect on the shape

and magnitude of the modulus reduction and material damping curves-though it

can be considered a secondary effect-a range of unique modulus reduction and

material damping curves is computed within each depth interval (i.e., 0 to 20, 21

to 50, 51 to 120, etc.) through the randomization process. The computation

performed for the EGC ESP project resulted in 60 modulus reduction curves and

'30 material damping curves with each of the five depth intervals. The range

represented by each of the 60 sets of curves is intended to cover the

uncertainties in the shape and absolute value of the modulus reduction and

material damping ratio curves resulting from a number of different effects,

including the particular soil type, the stress history for the soil, sample

disturbance associated with the laboratory testing of soil samples, and random

variability that is typically observed in laboratory testing programs.

In summary, the applicant stated that the randomization process for modulus reduction and

material damping curves, as well as the low-strain S-wave velocity and thickness profiles,

results in combinations of soil stiffness and damping conditions that account for the possible

variations in soil type, soil layer thickness, and dynamic soil properties for the EGC ESP site.

In RAI 2.5.4-7, the staff also asked the applicant to explain why it did not incorporate the

1 5-percent damping cutoff as recommended in SRP Section 3.7.2 and to provide clarification

regarding its use of high strain values in the randomization process. In response, the applicant

stated that the 15-percent damping in SRP Section 3.7.2 pertains to soil-structure interaction

(SSI) problems and not to free-field, site response analyses. The applicant also stated that

there is no evidence in laboratory testing programs that material damping should be capped at

15 percent. Regarding the effect of using a 15-percent damping cutoff for the ESP site, the

applicant: stated the following:

For a stiff site such as occurs at the EGC ESP Site, the 15 percent cutoff is

expected to have little effect except perhaps in the shallowest soil layers, where

the shear modulus is lowest. Where soils are relatively stiff and peak ground

acceleration only moderate, such as occurs at the EGC ESP Site, the equivalent

shearing strains will often be low enough that damping ratios do not exceed

15 percent. Only the upper 50 feet or so of soil profile at the EGC ESP site,

where the shear modulus is reduced, could the site response potentially be

affected by the damping cutoff.

However, to support the response to this RAI, a series of supplemental computer

runs were conducted using the low-strain shear wave velocity profile, the SHAKE

program, and modulus reduction curves as discussed in the EGC ESP SSAR.

For these supplemental analyses, the material damping curves in the EPRI soil

model were capped at 15 percent. The results of a representative set of these

analyses were compared to the mean transfer functions shown in Figures 4.2-23

and 4.2-24 from Appendix B of the EGC ESP SSAR. This comparison indicated

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that the 15 percent damping cap results in no more that a 2 percent increase in

the transfer function for the 10-5 hazard level motions and much less for the

10-4 hazard level motions for the EGC ESP Site. These effects are considered

negligible.

In summary, in its response to RAI 2.5.4-7, the applicant indicated that using the EPRI 1993

shear modulus and material damping curves (EPRI TR-102293, "Guidelines for Determining

Design Basis Ground Motions") eliminates the need to associate particular laboratory results for

individual soil layers in the response calculations. However, the staff notes, as indicated in the

plots included in the SSAR, that the difference between nonlinear material models for sandy

soils as compared to clayey soils can be significant for high strain levels. As a result, this

difference in soil type may result in more than just a secondary effect. The response

calculations performed for the EGC ESP site only considered the material models associated

with sandy soils. The potential existence of high-plasticity index clay soils at the site is not

discussed to a significant extent in the applicant's response.

Regarding the issue related to the 15-percent damping cutoff, the applicant stated that the

guideline of the 15-percent damping cutoff in SRP Section 3.7.2 pertains to the SSI problem,

but not the site response calculation. This is not acceptable to the staff, because the

15-percent cutoff limit for hysteretic damping mentioned in the SRP is not restricted to SSI

analyses only, but is associated with the one-dimensional free-field calculations typically

performed before the SSI analyses. The purpose of this restriction acknowledges the fact that

at these high strain levels associated with the laboratory tests, the assumption of steady-state

behavior is questionable. Therefore, the staff's position has been that excessively high

damping values are not appropriate for site response calculations. The applicant stated that

the use of the 15-percent damping cutoff in the calculation causes the surface design motions

to increase by about 2 percent.

In Open Item 2.5.2-3, the staff asked the applicant to address the impact of plastic clay soils at

the site on the assumption of the independence of the modulus reductions and material

damping curves from the specific soil type. In response, the applicant presented plots of

Atterberg Limit data for the various soils of the site that demonstrate that these soils are silts

and sandy silts of low plasticity. Since the applicant has demonstrated that the site soils have

low plasticity, the staff concludes that this portion of Open Item 2.5.2-3 is resolved.

In Open Item 2.5.2-3, the staff also asked the applicant to implement the 15-percent damping

cutoff in its free-field, site response analyses. In response, the applicant performed new site

response calculations using the 15-percent damping cutoff and used these results for

computation of the SSE. These changes have been incorporated into Revision 1 of the ESP

application. Since the applicant has incorporated the 15 percent damping cutoff in its free-field,

site response analyses, the staff considers this issue and Open Item 2.5.2-3 to be resolved.

To determine the ESP dynamic site response, the applicant developed appropriate ground

motion or earthquake time histories for several (12) deaggregation earthquakes, which

correspond to the low- and high-frequency controlling earthquakes shown above in

Table 2.5.2-2. The applicant selected matching earthquake time histories for each of the

deaggregation earthquakes from the CEUS time history library provided with NUREG/CR-6728.

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As part of its review of the applicant's site response analysis, the staff verified that the

deaggregation earthquake magnitudes and distances adequately characterized the local and

regional seismic hazard for the ESP site. The three deaggregation earthquakes corresponding

to each controlling earthquake represent lower, middle, and higher magnitude earthquakes

appropriate for the ESP site. Specifically, the lower magnitude deaggregation earthquake (\ =

5.7-6.0 at R = 11-15 km (9 mi)) corresponds to a local earthquake occurring in the central

Illinois source zone, the middle magnitude deaggregation earthquake (M = 6.7-6.9 at R =

140-166 km (103 mi)) corresponds to an earthquake in the Wabash Valley-southern Illinois

region, and the upper magnitude deaggregation earthquake (M 7.2-7.4 at R = 375-381 km

(237 mi)) corresponds to a New Madrid earthquake.

To determine the final site response, the applicant used the program SHAKE to compute the

site amplification function for each of the deaggregation earthquakes. The applicant paired the

60 randomized velocity profiles with the 60 sets of randomized shear modulus and damping

curves (i.e., one velocity profile with one set of modulus reduction and damping curves). To

obtain a site amplification function, the applicant divided the response spectrum from the

computed surface motion by the response spectrum from the input hard rock motion. The

applicant then computed the arithmetic mean of these 60 individual response spectral ratios to

define the mean amplification function for each deaggregation earthquake.

The results of the applicant's site response analysis show that the ESP site subsurface

amplifies the input hard rock motion over the fairly wide frequency range of 0.5 to 10 Hz, with

the maximum amplification of 3.3 at a frequency of 1.7 Hz. The final site amplification function

for each controlling earthquake represents the weighted average of the amplification functions

for the associated deaggregation earthquakes. The weights (see SER Table 2.5.2-2) represent

the relative contribution of earthquakes represented by the deaggregation earthquakes to thE

hazard at the appropriate spectral frequency and hazard level. The applicant determined the

final soil surface spectra for the ESP site by scaling the rock controlling earthquake spectra by

the mean site amplification functions.

In summary, the staff concludes that based on its review of SSAR Section 2.5.2.5, as described

above, the applicant's site response analysis adequately incorporates the effects of the local

site properties and their uncertainties into the determination of the ESP free-field SSE, as

required by 10 CFR 100.23.

2.5.2.3.6 Safe-Shutdown Earthquake

The staff focused its review of SSAR Section 2.5.2.6 on the method used by the applicant to

determine the SSE ground motion spectra (horizontal and vertical) for the ESP site. Rather

than developing the SSE as recommended by RG 1.165, the applicant used a new method

called the! performance-based approach. The performance-based approach, which is described

in ASCE/SEI Standard 43-05, sets a target of a mean annual frequency of 10-5 of unacceptable

performance of Category I nuclear SSCs as a result of seismically initiated events. This safety

performance target, PFT, is based on assuming (1) a target 1 0 mean annual risk of core

damage from all accident initiators and (2) that seismic initiators contribute about 10 percent cf

the risk of core damage posed by all accident initiators. To determine the SSE that achieves

the annual performance goal of 10 5, the performance-based approach scales the site-specific:

mean 10-' UHRS, determined in the previous section, by a DF. The equations for the SSE and

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DF are provided in SER Section 2.5.2.1.6. As shown previously in Table 2.5.2-3, a DF is

determined for several spectral frequencies in order to create the final SSE.

In RAI 2.5.2-1 (a), the staff asked the applicant to justify the selection of the site-specific mean

10- UHRS as the appropriate starting point for determining the final SSE. In response to

RAI 2.5.2-1 (a), the applicant stated the following:

[The] design amplitude required to achieve the performance goal at each

structural period can be calculated starting from the mean 10- annual probability

level of the seismic hazard spectrum in the free field at the ground surface, or

from the 10 5 annual probability level, or from any intermediate probability level.

The design factor on the spectrum associated with each of these probability

levels would be different, but they all would lead to the same SSE.

The applicant explained that it selected a 1 0- annual probability level as the starting point

based on the precedent set in ASCE/SEI Standard 43-05. After reviewing the derivation of the

equations used by the performance-based approach to achieve an SSE that meets the target

performance goal (see SER Section 2.5.2.1.6.1), the staff was able to verify the applicant's

assertion that using a 104 annual probability level as the starting point is an arbitrary choice.

In RAI 2.5.2-1 (b), the staff asked the applicant to demonstrate that the SSE envelops the sitespecific response spectra from the controlling earthquakes at the reference probability level

(median 10'5 per year) recommended by RG 1.165 or to justify why this approach was not used

to determine the SSE. In response to RAI 2.5.2-1 (b), the applicant stated the following:

The EGC ESP does not rely on the site-specific response spectra from the

controlling earthquakes at the hazard reference probability level of median 1 05

per year to determine the site-specific SSE. Instead, the ASCE/SEI

Standard 43-05 is implemented to determine the site-specific SSE. Application

of the ASCE/SEI Standard results in site-specific ground motions that are riskconsistent with the median of the mean seismic-induced core damage

frequencies ([S]CDFs) [1.2 x 10-5] determined from probabilistic risk

assessments (PRAs) of existing nuclear power plants, which the Commission

has determined to be adequately safe.

Regarding the method recommended in RG 1.165 for determining the SSE, the applicant stated

the following:

Studies carried out in 2003 and 2004 during the ESP Application process have

found that the current understanding of seismic sources and ground motion

models within the central and eastern United States may result in a significant

increase in seismic hazard at some sites. These changes in seismic hazard

indicate a need to update the reference probability given in RG 1.165 to account

for new ground motion models, new seismic source information, and better site

response adjustments.

After reviewing the alternatives, EGC has concluded that a re-evaluation of the

hazard reference probability in Appendix B of RG 1.165 would not achieve the

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regulatory stability sought by RG 1.165 and necessary for EGC to proceed with

their current ESP Application or any future ESP application(s). Relative to

overall industry needs, a revision to the current reference probability based on

seismic information available in 2004 would remain valid only until new

information becomes available on seismic sources near one or more of the

29 sites, or when new information becomes available on ground motion

attenuation models. On a site-specific basis, EGC does not support

development of an SSE using a reference probability that is not based on the

latest seismic hazard information. Moreover, advances in technologies for

determining site-specific SSEs since the late 1980s together with advances in

JRC's regulation implementation policies, specifically the implementation of the

Commission's Risk-informed Regulation Policy, support the need for updating

Ihe guidance contained in RG 1.165 to comply with the current state of the

practice (e.g., ASCE SEI methodology). This generic action is outside the scope

of the EGC ESP submittal.

The stall acknowledges that the reference probability currently recommended in RG 1 .165

(median 10i5 per year), which is the average probability of exceeding the SSE ground motion at

5 Hz and 10 Hz using either the 1993 LLNL PSHA or the 1989 EPRI-SOG PSHA, needs to be

updated to more adequately represent current seismic hazard information. RG 1.165 endorses

both the original LLNL and EPRI-SOG PSHAs; however, it also recommends updating the

seismic source characterizations and ground motion models if they differ significantly from the

original LLNL or EPRI models. RG 1.165 also states that the staff will review proposals for

revised reference probability values on a case-by-case basis. The most important criterion for

evaluating the acceptability of either the RG 1.165 approach with a revised reference probability

or a new approach, such as the performance-based approach, is the suitability, with respect lo

the geological and seismological setting of the specific site, of the final SSE ground motion

spectra resulting from either approach. Specifically, as required by 10 CFR 100.23, the SSE

must provide a design-basis ground motion that adequately reflects the seismic characteristics

of the proposed site. As described below in Open Item 2.5.2-4, the staff has concluded that the

SSE for lthe ESP site satisfies this requirement.

In RAI 2.5.2-1 (c), the staff asked the applicant to justify using SSC seismic fragility information,

before the selection of a reactor design, to determine the site SSE. In response to

RAI 2.5.2-1 (c), the applicant stated that the performance-based approach "combines a

conservative characterization of equipment/structure performance with ground motion hazard to

establish risk-consistent SSEs, rather than only hazard-consistent ground shaking, as occurs

using the hazard reference probability approach in Appendix B of RG 1.165." As described in

SER Section 2.5.2.1.6.1 in the derivation of the equations and assumptions underlying the

performance-based approach, the two parameters used by the performance-based approach to

model SSC seismic fragility are the HCLPFand variability Ai. Since the actual HCLPFseismic

capacity vraries for different SSCs, the performance-based approach quantifies this value in

terms of the SSE ground motion level and a required seismic margin (Equation 2.5.2-11).

Following the recommendations of ASCE/SEI 43-05, the applicant selected a value of one for

the seismic margin. As shown by Equation 2.5.2-19 in SER Section 2.5.2.1.6.1, a margin (M3)

of unity is a conservative choice since larger margins would result in a smaller SSE value. A

margin of one implies that HCLPF= SSE for each SSC. This is a conservative assumption

since designers will typically be more cautious than to design the HCLPF seismic capacity to

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barely resist the SSE ground motion. Assuming a smaller seismic margin (i.e., of unity) is

equivalent to assuming that the seismic design criteria are less stringent, and hence a larger

(more conservative) SSE ground motion will be used. For the ,/value, which varies from 0.3 to

0.6, the applicant used 0.4. This assumed value for ,f is discussed below as part of Open

Item 2.5.2-5.

2.5.2.3.6.1 Derivation of the Performance-Based Approach

In RAI 2.5.2-7(b), the staff asked the applicant to provide the details of the derivation of the DF

that, when multiplied by the mean 10i UHRS, achieves an SSE that meets the target

performance goal of 10-5. In response to RAI 2.5.2-7(b) the applicant provided an explanation

of the performance-based method, including the important assumptions and derivations (see

SER Section 2.5.2.1.6.1 for the complete derivation). The staff's review of the underlying

assumptions and equations used for the performance-based approach resulted in further

questions concerning the following assumptions:

* the assumption of a linear hazard equation H(a) in logarithmic space and, specifically,

the determination of the slope of the hazard equation, -1/log(AR), between only the 104

and 10-5 interval

* the assumption that the seismic capacity variability 3 is 0.40

* the definition of unacceptable performance as the 'onset of significant inelastic

deformation" (OSID) or "exceedance of essentially elastic behavior"

* the stability of the target performance goal 10 5 since this value is from seismic PRAs

that used the original EPRI-SOG source models and ground motion estimates

* the applicability of the target performance goal 1 05 for advanced reactor designs that

may differ considerably from current light-water reactors (LWRs)

* the consistency between the seismic design criteria in NUREG-0800 and ASCE/SEI

Standard 43-05

In Open Item 2.5.2-5, the staff requested clarification and further information from the applicant

regarding each of the six issues outlined above. The applicant's response and the staff's

evaluation are provided below.

Linear Hazard Equation. In Open Item 2.5.2-5(a), the staff asked the applicant to justify the

assumption of a linear hazard curve in logarithmic space (see Equation 2.5.2-13 and

Figure 2.5.2-7) and the appropriateness of solely using the 104 to 10,5 interval to determine the

amplitude ratio AR and, as such, the DF. In response, the applicant stated the following:

In developing the design factor, DF, the seismic hazard curve was approximated

by a power law which results in a linear hazard curve when plotted on a log-log

plot. Seismic hazard curves are close to linear when plotted on a log-log plot.

However, they are not perfectly linear. They always curve downward with

decreasing hazard exceedance frequency. Thus AR reduces as the hazard

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exceedance frequency is reduced. In other words, an AR computed over the

range of hazard exceedance frequencies from 1x1 04/yr to 1 x1 05/yr will be larger

than that computed over the l x1 05/yr to 1 x1 0-6/yr range.

In addition, the applicant stated that "based upon several hundred rigorous convolutions of

hazard and fragility curves, it has been found that PFr is dominated by the portion of the fragility

curve between about the 1% failure probability capacity C,% and the 70% failure probability

capacity Co%" (see Figure 2.5.2-11 for an illustration of this portion of the fragility curve). The

applicant also compared SSE values obtained by direct integration of the risk integral

(Equation 2.5.2-9), which uses the entire hazard and fragility curves, versus the those obtained

by using the risk equation (Equation 2.5.2-1), which assumes a linear hazard curve in log-log

space between the exceedance frequencies of 1x104/yr to 1x10 5/yr. Comparing the two

results, the applicant stated, "one can see that the use of the approximate power law hazard

curve introduces a slight, but generally negligible, conservative bias for the computed PFT."

To verify the acceptability of assuming a linear hazard curve in log-log space between the

exceedance frequencies of 1 x1 04/yr to 1 x1 05/yr to determine the SSE via the risk equation As

opposed to direct convolution of the risk integral, the staff requested four hazard curves frorm

the applicant. Figure 2.5.2-7 above shows these four hazard curves (1 Hz, 2.5 Hz, 5 Hz, and

10 Hz). The staff then compared the SSE values using these two approaches (i.e., "direct

integration" and "risk equation"), which are shown below in Table 2.5.2-4. For both approaches,

the staff assumed f = 0.4 and a performance target of mean 1 x1 05/yr.

Table 2.5.2-4 Comparison of Performance-Based SSE Values

SSE

NatUral Frequency (Hz) Risk Integral (g) Risk Equation (g)

1.0 0.3366 0.3945

2.5 0.5737 0.6582

5.0 0.6043 0.6570

10.0 0.5591 0.5864

Since the seismic hazard curves have a slight downward curvature, as illustrated in

Figure 2.5.2-7, assuming a linear fit results in slightly higher exceedance values and, as a

result, slightly higher SSE values, as illustrated above in Table 2.5.2-4. Therefore, the staff

concludes that the applicant's use of the approximate power law hazard curve is slightly

conservative and therefore acceptable.

Seismic (caoacitv Standard Deviation. In Open Item 2.5.2-5(b), the staff asked the applicant to

justify why a fvalue of 0.4 was used and show how the DF varies with different fivalues over

the range of amplitude ratios (AR). In response, the applicant stated that the developers of the

performance-based approach considered / values between 0.3 and 0.6 and AR values between

1.5 and 4.5 when developing Equation 2.5.2-1 for DF. Regarding /Jvalues, the applicant stated

that "the results for ,/ of 0.4 and 0.5 were weighted more heavily than those for / of 0.3 and 0.6

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because the fragility /3 values are most likely in the 0.4 and 0.5 range and /3 of 0.3 and 0.6 are

considered to be extreme low and high values, respectively."

As shown previously in Figure 2.5.2-14 in Section 2.5.2.1.6.1, the DF recommended in

ASCE/SEI 43-05 (Equation 2.5.2-1) is slightly unconservative for /3=0.3 and conservative for

larger flof 0.4 to 0.6. To evaluate the significance of the range of /3values on the DF, the staff

determined the unacceptable performance frequency values (PFT) for the performance-based

SSE values for four natural frequency values 1, 2.5, 5, and 10 Hz. The applicant determined

the four performance-based SSE values shown below in Table 2.5.2-5 using the performancebased approach as described in ASCE/SEI 43-05, which assumes a / value of 0.4 and a target

performance goal of lx1 05/yr. The staff used the four hazard curves provided by the applicant

to determine PF. via direct integration of the risk integral (Equation 2.5.2-9) for /3 ranging from

0.3 to 0.6. As shown below in Table 2.5.2-5, the PFrvalues for /3=0.3 are only slightly larger

than the target value of 1 x1 0 5/yr.

Table 2.5.2-5 Unacceptable Performance Frequency Values for /3 from 0.3 to 0.6

a I PFr*10-s/yr

Freq (Hz) SSE (g) /3=0.3 3 =0.4 /3=0.5 /3=0.6

1.0 0.3945 1.08 0.95 0.70 0.55

2.5 0.6582 1.05 0.97 0.73 0.59

5.0 0.6670 1.03 0.96 0.71 0.58

10.0 0.5864 1.02 0.91 0.65 0.52

Since the PFr values for /3=0.3 are only slightly larger than the target performance goal of 1 0-5/yr

and fragility /3values of 0.3 are not common for SSCs, the staff concludes that the applicant's

assumption that /3=0.4 for determining the SSE is acceptable.

Onset of Significant Inelastic Deformation. In Open Item 2.5.2-5(c), the staff asked the

applicant to clarify the meaning of "onset of significant inelastic deformation" (OSID),

specifically the words "onset" and "significant," OSID with regard to the failure of SSCs and core

damage, and the relationship of OSID to "essentially elastic" behavior. In response, the

applicant stated that OSID means that "localized inelasticity might occur at stress

concentrations, [but] the overall seismic response (deformations) will be essentially the same as

those computed by [a] linear elastic demand analysis." The applicant also stated that in

ASCE/SEI 43-05 essentially elastic behavior (or OSID) is achieved by requiring that the seismic

demand computed by sufficiently conservative linear elastic analysis is less than the

conservative code-specified allowable seismic capacity (without an "inelastic factor" by which

the linear elastic demand can exceed the code capacity). Generally there is less than a

2 percent probability of large inelastic deformation if the actual demand reaches the code

capacity (as discussed in the commentary of ASCE/SEI 43-05).

Based on the applicant's response, the staff has determined that OSID is just beyond the

occurrence of insignificant (or localized) inelastic deformation, and in this way corresponds to

"essentially elastic behavior." As such, OSID of an SSC can be expected to occur well before

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seismically induced core damage, resulting in much larger frequencies of OSID than SCDF

values. In fact, as implied by the applicant's definition, OSID occurs before SSC 'Iailure,"

where the term failure refers to impaired functionality. To further demonstrate that the

frequency of OSID is larger than SCDF, the staff used the four EGC ESP hazard curves (1, 2.5,

5, and 10 Hz) to calculate SCDF values for each of the four performance-based SSE values. In

performing this calculation of SCDF, the staff used the risk integral equation (Equation 2.5.2-9)

with the complete range of expected /3 values (0.3 to 0.6) and assumed that the seismic margin

(M.) against core damage is 1.67 for new standard plant designs as specified in staff

requirements memorandum (SRM), dated July 21, 1993, on SECY 93-087. As shown in

Table 2.5.2-6 below, SCDF values for the four natural frequencies and P values vary from

0.08x1 0 5

/yr to 0.32x1 0-5/yr.

Table 2.5.2-6 SCDF Values for Clinton Performance-Based SSE

I I SCDF *10- 5/yr

Freq (Hz) SSE (g) 4=0.3 /3=0.4 4=0.5 = 0.6

1.0 0.3945 0.32 0.28 0.20 0.16

2.5 0.6582 0.20 0.18 0.13 0.11

5.') 0.6570 0.16 0.15 0.11 0.10

10.0 0.5864 0.11 0.12 0.09 0.08

For comparison, NUREG-1 742 shows, based on the results of seismic PRAs of 25 nuclear

power plants, that the median value for the mean core damage frequency is 1.2x1 0'5/yr.

Therefore, by setting the target performance goal, Pf-T, to be a FOSID value of lx10 5/yr, the

resulting SSE computed using the ASCE/SEI 43-05 methodology provides SCDF values that

are substantially lower than those for most of the 25 nuclear power plants provided in

NUREG-1742. Figure 2.5.2-15 in SER Section 2.5.2.1.6.1 shows the results of the seismic

PRAs frcm NUREG-1 742 in terms of mean ground motion recurrence interval, which is the

inverse cf mean SCDF. Figure 2.5.2-17, below, shows these same results and adds the values

computed above in Table 2.5.2-5 for the EGC ESP site. For the natural frequencies of 5 and

10 Hz and for 4 values of 0.4 and 0.5, SCDF is about l x1 06

/yr for the EGC ESP performancebased SS E, which is about 10 times lower than the median of the mean SCDF for the

25 nuclear power plants in NUREG-1 742.

In conclusion, the staff has determined that there is a significant difference between OSID,

which is set at 1 05/yr as the target performance goal, and seismic core damage. This result

follows from assuming that the seismic margin against core damage is 1.67 as specified in

SRM, dated July 21, 1993, on SECY 93-087.

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I e+07 -:

0

0

1-4

0.

0)

r.)

a.)

CZ

Ie+06 -

100000 -.

EGCESP Seismic CDFiforPBse SSE.

anid aHCTYF Marin of 1;67Ad-9i:,.,t,,';"

0

0

0

0

Performance Target (FOSID)

Median Seismic CDF

25 Plants

NUREG-1742 (2001)

0

0

0

0

10000 -

1000 -

Figure 2.5.2-17 Seismic core damage in terms of mean ground motion recurrence

interval for EGC ESP site and 25 nuclear power plants. For comparison, FOSID is also

shown.

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Stability of Target Performance Goal. In Open Item 2.5.2-5(d), the staff asked the applicant to

justify the long-term stability of the target performance goal 1x1 Q.5 in comparison to the hazardbased approach (reference probability) in RG 1.165, as both values are based on PSHAs for

several CEUS nuclear sites. In response, the applicant stated the following:

Although Regulatory Guide 1.165 was officially issued in early 1997, the

guidance is based on late 1980s to early 1990s technologies. EGC recognized

that the reference probability approach of Regulatory Guide 1.165 does not

provide the regulatory stability that was originally intended and expected, as it is

inherently unstable with the updating of the input parameters for PSHAs for

CEUS sites. Updating the PSHAs at CEUS sites changes the basis upon which

the reference probability was established and a new reference probability must

be established. The performance-based criterion on the other hand, remains

unchanged by updating the PSHAs, even though the site-specific SSE ground

motion will reflect the updated PSHA results. The method provides uniform

performance across sites and thus provides performance consistency and

regulatory stability.

Although the target FOSID value of 1 x105/yr is based on the mean SCDF of 1.2x105/yr from

the seismic PRAs of 25 nuclear power plants, as described above and in NUREG-1 742, the

applicant stated that the performance-based criterion "remains unchanged by updating the

PSHAs." Since the target performance criterion (i.e., the FOSID value of 1 x105/yr) produces an

SSE for the EGC ESP site that adequately reflects the regional and local seismic hazards (see

Open Item 2.5.2-4 below) and this performance criterion will remain fixed, the staff finds that the

performance-based approach is an adequately stable method.

A2plica ilitv of Target Performance Goal. In Open Item 2.5.2-5(e), the staff asked the applicant

to justify the use of the target performance goal of 1 x1 05/yr for advanced reactor designs,

which may differ considerably from current LWRs. As described above in the applicant's

response to RAI 2.5.2-7(a), the target performance goal is based on seismic PRAs for current

LWRs. Iln its response, the applicant stated that the performance-based approach sets the

target performance goal of 1x105/yr to be equal to the FOSID for SSCs. Furthermore, the

applicant stated that the "onset of significant inelastic deformation of an SSC does not

correspond to Seismic-induced Core Damage particularly for an advanced reactor design with

redundant safety features."

Regardless of the advanced reactor design, in SRM, dated July 21, 1993, on SECY 93-087, the

Commission approved the use of 1.67 times the design basis SSE for a margin-type

assessment of seismic events. Using this criterion, the staff calculated SCDF values for the

EGC ESP SSE, as described above in Table 2.5.2-5, that range from 0.18 to 0.09x1 05/yr for

natural frequencies 2.5, 5, and 10 Hz and ,6equal to 0.4 and 0.5. Based on these results, the

staff concludes that the applicant's use of 1x10'5/yr as the target performance goal results in an

SSE for the EGC ESP site that is adequately conservative.

Comparison of NUREG-0800 and ASCE/SEI 43-05. In Open Item 2.5.2-5(f), the staff asked

the applicant to clarify how the design criteria in ASCE/SEI Standard 43-05 are similar enough

to the seismic criteria in NUREG-0800 such that SSCs designed following NUREG-0800 wou'd

also achieve a 1 percent or lower probability of unacceptable performance. In response, the

2-267
applicant stated that the seismic design criteria in ASCE/SEI Standard 43-05 for Seismic

Design Category SDC-5D are nearly identical to the NRC SRP (NUREG-0800), RGs, and

professional design codes and standards referenced therein. The staff compared the two

design standards and found that the differences between the seismic demand criteria in

ASCE/SEI Standard 43-05 and the SRP are sufficiently small that SSCs designed following the

SRP will also achieve a 1 percent or lower probability of unacceptable performance for the

design-basis earthquake ground motion.

In conclusion, after extensive review, the staff finds that the performance-based approach is an

advancement over the solely hazard-based reference probability approach recommended in

RG 1.165. The performance-based approach uses not only the seismic hazard characterization

of the site from the PSHA, but also basic seismic fragility SSC modeling in order to obtain an

SSE that directly targets a structural performance frequency value. The staff concludes that

the applicant targeted a sufficiently low value (1xi 0-5/yr), which it set to be equivalent to FOSID,

such that the resulting performance-based SSE achieves an SCDF that is about 10 times

smaller (1 xi 0-6/yr) than the median of the mean SCDF for the 25 nuclear power plants in

NUREG-1742. Therefore, the staff considers Open Item 2.5.2-5 to be resolved.

2.5.2.3.6.2 Target Annual Performance Goal

In RAI 2.5.2-7(a), the staff asked the applicant to justify the selection of the mean annual

frequency of 1 5- as the safety performance target for the unacceptable performance of

Category I SSCs as a result of seismically initiated events. In response to RAI 2.5.2-7(a), the

applicant made the following four main points:

(1) The results from seismic PRAs, which were performed for 25 nuclear facilities, show an

annual mean SCDF of 10-5 or higher for seismic core damage for 50 percent of the

operating power plants.

(2) Setting the performance goal of 1O5 to be equivalent to the annual FOSID of SSCs is

conservative since the seismic demand resulting in the onset of significant inelastic

deformation is less than that for failure of the SSC.

(3) The target 10'5 annual performance goal is achieved so long as seismic demand and

structural capacity evaluations have sufficient conservatism, which is inherent for plants

reviewed and approved using the SRP guidelines.

(4) The target 10 5 annual performance goal results in a plant that is as safe as the plants

currently operating, as shown by the seismic PRAs.

The primary basis for the target 10'5 annual performance goal is from the results of seismic

PRAs of 25 nuclear power plants (NUREG-1 742), which show the median value for the mean

SCDF to be 1 .2x1 O5. The results of the seismic PRAs in terms of mean ground motion

recurrence interval, which is the inverse of SCDF, are shown above in Figure 2.5.2-17. Since

the target 10 5 annual performance goal and the accompanying performance-based approach

for determining the SSE constitute a major departure from the hazard-based approach currently

recommended by RG 1.165, in addition to focusing on the underlying assumptions of the

performance-based approach (see Open Item 2.5.2-5 above) the staff also focused on the

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results of its application to the EGC ESP site. To determine the appropriateness of the target

1 05 annual performance goal and performance-based approach for the EGC ESP site, the staff

reviewed the applicant's final SSE to ensure that it adequately reflects the regional and local

seismic hazards surrounding the ESP site.

As shown previously in SER Section 2.5.2.1.6, the final SSE using the performance-based

approach is calculated by multiplying the DF and 1 0- surface UHRS. Since, by definition, the

DF is al: least 1.0, the final SSE ground motion spectrum will be at least the 1 04 UHRS and

higher, depending on the value of the amplitude ratio (AR) for the 1 Wand 10' hazard curves.

For the EGC ESP site, the DF values from 2.5 to 100 Hz are very close to 1.0, implying that the

final SSE, while meeting the target 105 annual performance goal, is close to the 1O4 surface

UHRS. This result is shown by Figure 2.5.2-6 in SER Section 2.5.2.1.6, which shows the 104

and 10 " surface UHRS along with the final SSE.

The high-frequency and low-frequency controlling earthquakes that provide the largest

contribution to these two hazard levels (1 0-4and 10 5) for the ESP site were shown previously in

SER Section 2.5.2.1.4. This table is repeated below for convenience.

Table 2.5.2-7 High- and Low-Frequency Controlling Earthquakes

Hazard Magnitude (mb) Distance

Mean 1 O' 6.5 83 km (52 mi)

High Frequency (5 and 10 Hz)

Mean 104 7.2 320 km (199 mi)

Low Frequency (1 and 2.5 Hz)

Mean 105 6.2 24 km (15 mi)

High Frequency (5 and 10 Hz)

Mean 105 7.2 320 km (199 mi)

Low Frequency (1 and 2.5 Hz)

Because the performance-based SSE is close to the 10- surface UHRS, the corresponding

controlling earthquakes for the ESP site are M, 6.5 at 83 km (52 mi) (high frequency) and mb

7.2 at 320 km (199 mi) (low frequency). These two earthquakes correspond to events in the

WVSZ and NMSZ, respectively. Both of these events are somewhat distant from the ESP site.

In contrast, the mean 1 05 high-frequency controlling earthquake (mb 6.2 at 24 km (15 mi))

represents a local earthquake from the central Illinois seismic zone.

The seismic hazard for the central Illinois basin/background source zone, which encompasses

the ESP site, is dominated by the Springfield earthquake. Paleoliquefaction studies in the area

have found evidence that one or, more likely, two prehistoric earthquakes occurred 5900 to

7400 years ago near Springfield, Illinois, approximately 37 mi southwest of the ESP site

(McNulty and Obermeier, 1999). These earthquakes were large enough to generate

liquefaction features, with magnitude estimates ranging between 6.2 and 6.8 for the larger

event and at least 5.5 for the second event. In addition to the Springfield events, geologists

have discovered paleoliquefaction features further south near Shoal Creek. The estimated

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magnitude and date for this event is about 6.5 and 5700 years BP. In addition to the above

liquefaction features, the applicant also found smaller liquefaction features along the banks of

streams closer to the ESP site. Finally, a magnitude 5.4 earthquake occurred in 1968 in the

Illinois basin.

In Open Item 2.5.2-4, the staff asked the applicant to demonstrate that the SSE developed

using the performance-based approach adequately reflects the local seismic hazard from the

central Illinois basin/background source zone. In response, the applicant stated the following:

The Springfield earthquake represents an event near the largest size expected

to occur in the source zone [Central Illinois basin/background source zone] and

at a relatively large distance (approximately 60 km epicentral distance).

Because there is no concentration of seismicity at Springfield, there is no peak in

the magnitude-distance distribution of earthquake frequencies at that distance,

and earthquakes of comparable size can occur closer to the site. Because

earthquakes smaller than the Springfield earthquake occur much more

frequently, they have a larger contribution to the hazard. As a result, the

procedure outlined in Regulatory Guide 1.165 would not identify the Springfield

earthquake as a controlling earthquake. In addition, it would not appear as a

peak (mode) in the magnitude-distance de-aggregation of the hazard.

In addition, the applicant directly compared the rock UHRS1, 4, which is slightly smaller than the

SSE, and estimated ground motions for the Springfield event. Using the EPRI (2004) ground

motion attenuation models, assuming the estimated energy center for the Springfield event to

be the earthquake epicenter, and earthquake magnitudes and weights of M 6.2 (0.4), M 6.4

(0.3), M 6.6 (0.2), and M 6.8 (0.1), the applicant determined response spectra (median and 84t

percentile) ground motion for comparison with the rock UHRS,

1 4. The results of this

comparison show that the rock UHRSG4 1 envelops both the median and 84t percentile ground

motion from the Springfield earthquake at the ESP site. The scale factors to match the

UHRSc4 at an average of 5 and 10 Hz spectral frequencies are 1.67 for the median and -1.20

for the 84' percentile.

The applicant also used the latest relationships for estimating the magnitude of prehistoric

earthquakes based on the distribution of associated paleoliquefaction features to refine its

magnitude estimates for the Springfield earthquake. The applicant used the relationship

developed by Olson et al. (2005 in press) to estimate a magnitude of M 6.3 for the Springfield

earthquake, which is consistent with the higher weight given to lower magnitudes in the

distribution developed for the Springfield earthquake. The applicant then calculated ground

motion response spectra from a magnitude 6.3 at 60 km for comparison with the UHRSIG4.

Figure 2.5.2-18, which is reproduced from Figure 2.5.2-4-12 from the applicant's response to

Open Item 2.5.2-4, shows these comparisons of the ground motion estimates for the Springfield

earthquake and the UHRS,104.

2-270
M 6.2 to 6.8 at 60km

Median spectrum scale factor = 1.67

84th% scale factor = 1.20

M 6.3 at 60 km

Median spectrum scale factor = 1.91

84th% scale factor = 1.31 1 1 l , . . . ............ . . . . . . ... ... . . . . . . .

rr . . . ......

la

0

-

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Frequency (Hz) Frequency (Hz)

Figure 2.5.2-18 Comparison of UHRSo> with estimated ground motion response spectra for the Springfield earthquake

2-271
To characterize the seismic hazards for the ESP site, including the controlling earthquake

magnitudes and distances, the applicant used the guidance provided in RG 1.165. SER

Sections 2.5.2;1 through 2.5.2.5 fully describe the results of this characterization. The applicant

departed from RG 1.165 in the use of the performance-based approach for the ESP site to

determine the final SSE. The staff has determined, as described above in Section 2.5.2.3.6.1,

that the performance-based approach used by the applicant results in an SSE that is

adequately conservative based on SCDF values of about 1x106/yr. In addition, based on its

review of the applicant's response to Open Item 2.5.2-4, the staff concludes that the SSE

adequately represents both the regional and local seismic hazards for the ESP site. This

conclusion is based on the applicant's comparison of the estimated ground motion from the

largest known prehistoric local event (Springfield earthquake) and the UHRS,04, which is

slightly smaller than the SSE. This comparison shows that the SSE envelops the best

estimates for the ground motion from the most severe local event. Therefore, the staff

considers Open Item 2.5.2-4 to be resolved.

2.5.2.3.6.3 Vertical Safe-Shutdown Earthquake

To compute the vertical SSE, the applicant used the V/H response spectral ratios provided in

NUREG/CR-6728. The V/H response spectral ratios given in NUREG/CR-6728 are CEUS hard

rock site conditions and depend on the PGA value of the horizontal SSE spectrum. For the

ESP site, the V/H ratios used by the applicant are based on having a PGA less than 0.5g. The

vertical SSE spectrum is given by multiplying the horizontal SSE spectrum by the V/H ratios.

The applicant also considered the effects of the ESP site soil conditions on the vertical ground

motions by using ground motion models that provide vertical motions for soil conditions. The

applicant used a magnitude 6.4 earthquake at source-to-site distance of 15 km ( 9 mi) as input

to the ground motion models. This magnitude and distance roughly correspond to the highfrequency controlling earthquake.

To verify the adequacy of the V/H SSE ratios used by the applicant, the staff evaluated both the

V/H ratios provided in NUREG/CR-6728 and the applicant's consideration of the local site

effects on the vertical ground motions. The V/H ratios provided in NUREG/CR-6728 take into

account the effects of magnitude, source distance, and local site conditions and are based on

earthquake strong motion data. Previous regulatory guidance (RG 1.60 and NUREG/CR-0098)

recommended that the V/H ratio be fixed at 2/3 independent of ground motion frequency,

earthquake magnitude, distance, and local site conditions. To incorporate the effect of the local

site conditions on the vertical ground motions, the applicant used a magnitude 6.4 at a sourceto-site distance of 15 km. Based on its review of the V/H ratios provided in NUREG/CR-6728

and the applicant's use of a representative local controlling earthquake, the staff concludes that

the V/H ratios used by the applicant are adequate for the EGC ESP site. The staff notes that

for higher frequencies (20 Hz and above), the vertical SSE is larger than the horizontal SSE.

2.5.2.3.6.4 Design Response Spectrum

In SSAR Section 3.4.1.4.3, the applicant compared the horizontal performance-based SSE for

the ESP site with the RG 1.60 DRS anchored to a PGA of 0.3g at 33 Hz, which is the DRS used

by many of the current reactor designs. The applicant noted that the ESP SSE is lower than

the RG 1.60 DRS except at frequencies between 15 and 65 Hz. However, after applying the

high-frequency reduction factors recommended in a 1993 EPRI study, the ESP SSE is

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completely enveloped by the RG 1.60 DRS. The applicant concluded by stating that the highfrequency exceedances by the ESP SSE in relation to the RG 1.60 DRS are not significant,

which indicates that the "EGC ESP site is suitable for any design based on the RG 1.60 DR.S."

Regarding the applicant's above conclusion, the staff has determined that its evaluation of ESP

applications will not include a comparison of the site-specific SSE with generic DRS, which may

or may not be used by the COL applicant. The staff's review of the acceptance of the final USE

is based on whether the SSE ground motion adequately reflects the local and regional seismic

hazard and not on a comparison of the SSE with DRS. In addition, the staff is currently

discussing the suitability of high-frequency ground motion reduction factors, similar to those in

EPRI 1 993, with industry representatives. Therefore, the staff rejects the applicant's conclusion

that the ESP site, after the application of the high-frequency reduction factors, is suitable for

any design based on the RG 1.60 DRS.

2.5.2.4 Conclusions

As set forth above, the staff reviewed the seismological information submitted by the applicant

in SSAR Section 2.5.2. On the basis of its review of SSAR Section 2.5.2 and the applicant's

responses to the RAls, the staff finds that the applicant has provided a thorough

characterization of the seismic sources surrounding the site, as required by 10 CFR 100.23. In

addition, the staff finds that the applicant has adequately addressed the uncertainties inherent

in the characterization of these seismic sources through a PSHA, and that this PSHA follows

the guidance provided in RG 1.165. The staff concludes that the controlling earthquakes and

associai:ed ground motion derived from the applicant's PSHA are consistent with the

seismogenic region surrounding the ESP site. In addition, the staff finds that the applicant's

SSE, which was developed using the performance-based approach, adequately represents the

regional and local seismic hazards and accurately includes the effects of the local ESP

subsurface properties. After extensive review, the staff concludes that the performance-based

approach is an advancement over the solely hazard-based reference probability approach

recommended in RG 1.165. The performance-based approach uses not only the seismic

hazard characterization of the site from the PSHA but also basic seismic fragility SSC modeling

in order to obtain an SSE that directly targets a structural performance frequency value. The

staff concludes that the proposed ESP site is acceptable from a geologic and seismologic

standpoint and meets the requirements of 10 CFR 100.23.

2.5.3 Surface Faulting

SSAR Section 2.5.3 describes the potential for surface faulting at the ESP site. The information

presented by the applicant in SSAR Section 2.5.3 is supplemented in Chapter 5 of SSAR

Appendix B.

2.5.3.1 Technical Information in the Application

2.5.3.1.1 Surface Faulting Investigations

Geologic Evidence for Surface Deformation. To investigate the potential for surface faulting or

fold deformation at the ESP site, the applicant constructed a site-specific geologic cross section

based on the site borehole data. The applicant found that irregularities in the upper units of

glacial till are not reflected in the older, underlying bedrock units. In particular, the contact

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between the top of bedrock (300 ft below ground surface) and the overlying glacial till is flatlying across the entire site. As a result, the applicant concluded that there is no potential for

surface faulting or fold deformation at the ESP site.

Earthquakes Associated with Capable Tectonic Sources. As a result of its geologic

investigations, the applicant concluded that there have been no historically reported

earthquakes within 25 miles of the site that can reasonably be associated with a local geologic

structure. At greater distances from the ESP site, historical earthquakes have been postulated

to be associated with geologic faults. At approximately 50 miles from the ESP site, a group of

small earthquakes has been postulated for the northern part of the Peru monocline. Other

seismic activity within the WVSZ, over 100 miles from the ESP site, has been correlated with

the CGL. In addition, the applicant noted that a spatial association of seismicity has been

attributed to the Du Quoin monocline and Centralia fault zone in south-central Illinois. Each of

these geologic structures is described in SER Section 2.5.1.1.1. Rather than characterizing the

seismic potential of each of the above regional geologic structures, the applicant used the

EPRI-SOG seismic hazard study, which groups these potential sources into large areal seismic

sources zones.

Ages of Most Recent Deformation. To search for evidence of nearby prehistoric earthquakes,

the applicant conducted extensive paleoliquefaction investigations along the banks of several

streams near the ESP site. The applicant stated that the results of these investigations suggest

that no repeated moderate to large events (comparable to the postulated M 6.2 to 6.8

Springfield earthquake) occurred in the site vicinity since the late Pleistocene (2 mya) that

would indicate a capable tectonic structure within 25 miles of the ESP site. The applicant found

only a small number of paleoliquefaction features and concluded that there was not sufficient

information to estimate an earthquake location or magnitude. Although the applicant was

unable to attribute these local paleoliquefaction features to a specific earthquake or geologic

structure, the seismic activity of the area was characterized as a background areal seismic

source zone, referred to as the central Illinois basin/background source. The central Illinois

basin/background source encompasses the ESP site area and is modeled as part of the

applicant's PSHA. The applicant's paleoliquefaction investigations and the central Illinois

basin/background source are further described in SER Section 2.5.1.1.1.

RelationshiD of Tectonic Structures in the Site Area to Regional Tectonic Structures. Within a

25-mi radius of the ESP site, the applicant found no evidence of geologic faults. Based on its

search of the geologic literature, the applicant noted that folds within the La Salle anticlinorium

(series of anticlines) do lie within the 25-mile radius. However, the applicant stated that there is

no evidence for tectonic surface deformation that is associated with this series of anticlines

within 25 miles of the site.

Characterization of Capable Tectonic Sources. The applicant stated that it found no capable

tectonic sources within 25 miles of the site.

Designation of Zones of Quaternary Deformation in Site Region. The applicant stated that the

licensee's previous geologic investigations for the CPS site found no evidence of capable

faulting. For the ESP application, the applicant conducted paleoliquefaction investigations

along the banks of local streams, as described above and in SER Section 2.5.1.1.1. The

applicant stated that the results of these paleoliquefaction investigations revealed evidence for

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possible seismic ground shaking associated with prehistoric earthquakes. However, the

applicant found no evidence for tectonic Quaternary faulting or surface deformation during its

field reconnaissance along the selected rivers. In addition, the applicant found no evidence for

Quaternary deformation in the site region in the recent geologic literature.

Potential for Surface Tectonic Deformation. The applicant stated that the original investigations

for the UPS site as well as its own investigations for the ESP site found no evidence for surface

faulting or deformation that would pose a hazard to the ESP site.

2.5.3.2 Regulatory Evaluation

SSAR Section 2.5.3 describes the applicant's evaluation of the potential for surface deformation

that could affect the site. The applicant did not state which regulations SSAR Section 2.5.3

addressed; however, in response to RAI 1.5-1, the applicant stated that it complied with all cf

the regulations listed in RS-002. This statement by the applicant implies that SSAR

Section 2.5.3 conforms to the requirements of GDC 2 of Appendix A to 10 CFR Part 50,

Appendix S to 10 CFR Part 50, and 10 CFR 100.23. In SSAR Table 1.5-1, the applicant stated

that it d veloped the geological, seismological, and geophysical information used to evaluate

the potential for surface deformation in accordance with the guidance presented in RG 1.1 65.

The staff reviewed this portion of the application for conformance with the regulatory

requirements and guidance applicable to determining the potential for near-surface tectonic and

nontectonic deformation, as identified below. The staff notes that application of Appendix S in

this portion of an ESP review, as referenced in 10 CFR 100.23(d), is limited to characterizing

the potential for surface deformation as a basis for design.

In its review of the application, the staff considered the regulatory requirements in 10 CFR

1 00.23(d)(2), which state that an applicant for an ESP must determine the potential for surface

tectonic and nontectonic deformations. SRP Section 2.5.3 and RG 1.165 provide specific

guidance concerning the evaluation of information characterizing the potential for surface

deformation, including the geological, seismological, and geophysical data that the applicant

needs to provide to establish the potential for surface deformation.

2.5.3.3 Technical Evaluation

This section of the SER provides the staff's evaluation of the seismological, geological, and

geophysical investigations carried out by the applicant to address the potential for surface

deformation that could affect the site. The technical information presented in SSAR

Section :2.5.3 resulted from the applicant's surface and subsurface investigations performed in

progressively greater detail as they moved closer to the ESP site. Through its review, the staff

determined whether the applicant complied with the applicable regulations and whether the

applicant conducted its investigations with an appropriate level of thoroughness.

In order to thoroughly evaluate the surface faulting investigations performed by the applicant,

the staff sought the assistance of USGS. The staff and its USGS advisors visited the ESP site

and met with the applicant to assist in confirming the interpretations, assumptions, and

conclusions presented by the applicant concerning potential surface deformation. Specific

areas of review during the staff's site visit included the applicant's geological investigations, with

an emphasis on the applicant's paleoliquefaction reconnaissance of local streams. In addition,

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the staff reviewed the applicant's conclusions concerning the association of earthquakes with

capable tectonic sources, the ages of most deformation, the relationship of local area tectonic

structures to regional tectonic structures, the characterization of capable tectonic sources, the

designation of zones of Quaternary deformation, and the potential for surface tectonic

deformation.

As a result of its geologic investigations, the applicant found no potential for surface faulting or

fold deformation at the ESP site. In addition, the applicant was unable to associate any of the

historically reported earthquakes within 25 miles of the site with local geologic structures.

Rather than characterizing the seismic potential of the known geologic folds and faults in the

region, the applicant used the EPRI-SOG seismic hazard study, which groups these potential

sources into large areal seismic source zones. The EPRI-SOG seismic hazard study is

endorsed by RG 1.165 as an acceptable method for evaluating the seismic hazard for CEUS

sites. The staff concurs with the applicant's characterization of the regional and local seismic

sources as broad areal source zones. Within these source zones, earthquakes are modeled as

occurring over a large area as part of the applicant's PSHA. The ESP site is located within the

Illinois basin/background seismic source zone.

To search for evidence of nearby prehistoric earthquakes, the applicant conducted extensive

paleoliquefaction investigations along the banks of several streams near the ESP site. The

applicant found only a small number of paleoliquefaction features and concluded that there is

insufficient information to estimate a location or magnitude for the prehistoric earthquake which

caused these features. The staff concurs with the applicant's conclusion that the results of

these paleoliquefaction investigations imply that no repeated moderate to large earthquakes

comparable to the Springfield earthquake (M 6.2 to 6.8) occurred in the site vicinity during the

past 6,700 to 7,000 years.

Based on its review of SSAR Section 2.5.3, as well as the supporting information in Chapter 5

of SSAR Appendix B, the staff concludes that the applicant adequately investigated the

potential for surface faulting in the site area as required by 10 CFR 100.23. The staff

concludes that the applicant performed extensive field investigations and concurs with the

applicant's conclusion that there are no capable faults within the site area. The applicant noted

that folds within the La Salle anticlinorium do lie within 25 miles of the site; however, the staff

concurs with the applicant's statement that there is no evidence for tectonic surface

deformation that is associated with this series of anticlines. Based on its site visit and its review

of SSAR Section 2.5.3, as set forth above, the staff concurs with the applicant's conclusion that

there are no capable tectonic sources within 25 miles of the site that would cause surface

deformation in the site area.

2.5.3.4 Conclusions

In its review of the geological and seismological aspects of the ESP site, the staff considered

the pertinent information gathered by the applicant during the regional and site-specific

geological, seismological, and geophysical investigations. As a result of this review, described

above, the staff concludes that the applicant performed its investigations in accordance with

10 CFR 100.23 and RG 1.165 and provided an adequate basis to establish that no capable

tectonic sources exist in the site vicinity that would cause surface deformation in the site area.

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The staff concludes that the site is suitable from the perspective of tectonic surface deformation

and meets the requirements of 10 CFR 100.23.

2.5.4 Stability of Subsurface Materials and Foundations

SSAR Section 2.5.4 presents the applicant's evaluation of the stability of subsurface materials

that underlie the ESP site. Section 2.5.4.1, "Geologic Features," presents a brief description of

the sutsurface geology; Section 2.5.4.2, "Properties of Subsurface Materials," describes the

engineering properties of the subsurface materials; Section 2.5.4.3, "Explorations," describes

the subsurface explorations performed by the applicant; and Section 2.5.4.4, "Geophysical

Surveys," describes the geophysical surveys performed by the applicant to determine the Swave velocity of the soil and rock beneath the ESP site. Section 2.5.4.5, "Excavation and

Backfill ." describes the excavation and backfill work for the CPS site; Section 2.5.4.6,

"Groundwater Conditions," describes the local ground water conditions; Section 2.5.4.7,

"Response of Soil and Rock to Dynamic Loading," defers the evaluation of SSI to the COL

stage; Section 2.5.4.8, "Liquefaction Potential," describes the applicant's evaluation of

liquefaction potential; and Section 2.5.4.9 describes the applicant's use of the new

performance-based approach for determining the SSE. Sections 2.5.4.10, "Static Stability,"

through 2.5.4.14, "Construction Notes," describe analyses and evaluations that the applicant

has deferred to the COL stage.

2.5.4.1 Technical Information in the Application

2.5.4.1.1 Geologic Features

SSAR Section 2.5.4.1 states that the geologic features at the ESP site and CPS site are very

similar. The subsurface geology at the ESP site consists of nearly 300 ft of hard or dense soil

overlying rock. Other than the uppermost 50 feet, the soils have been overridden during past

glaciations. As shown in Figure 2.5.4-1, reproduced from Figure 5.1-1 in SSAR Appendix B,

there are seven primary soil layers at the ESP site.

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WESI r

KX .

_ _________ ._ __- ------- __

.~- - - - - - - - - - - - - - - - - --.- - -;-_.- .cn

East - West Cross Section

Log

I

e. 11

ond

0'=tC w ~ . _ d . 0

Li . ' m 1__Tb~ *f

I' * C C , * C k A W ___ C z ._

OC,,u_ b-aMC...vbl_ -

" - - C - - _ e

I

ji oCC CCC&C-C.C..C.CC~.~..C~.......... .

n3= CCC, d_,.

.

~dOe Cw * II Z O sl;7 r.Wd I 11r

Seismic Hlazards Report for the EGC ESP Site Figure

Site-Specific Gieologic Cross Section (from SSAR, Appendix A, 2003) 5.1-1

Figure 2.5.4-1 Site-specific geologic cross section

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Each of these soil layers is mainly composed of silts and clays with some sand and gravel. The

applicant stated that the boundaries between each of the soil layers is relatively horizontal and

each layer is consistent in its thickness and contents. The ground water table beneath the ESP

site is located approximately 30 ft below the surface, and the applicant stated that there are no

geologic hazards such as karst terrain or underground mine openings underlying the site.

SSAR Sections 2.5.1.1 and 2.5.1.2 provide a complete description of the regional and site

geologic features for the ESP site. These two SSAR sections are supplemented by additional

background information in SSAR Appendices A and B. Section 2.5.1.3 of this SER contains the

staff's technical evaluation of the applicant's description and characterization of the regional

and site geology.

2.5;4.1..2 Properties of Subsurface Materials

SSAR Section 2.5.4.2 states that the applicant established the engineering properties of the

subsurface materials at the ESP site through field and laboratory measurements and by

drawing upon the extensive database of information that was developed for the CPS site. The

properties measured by the applicant include strength, consolidation, dynamic/cyclic, and other

physical test results from soil samples recovered from the ESP site. The applicant stated that it

determined these properties from the ground surface to the top of rock, located nearly 300 ft

below the ground surface. Based on its field and laboratory measurements, the applicant

reached the following conclusions regarding the properties of subsurface materials existing at

the ESP site:

* The physical property tests indicate that the soil profile consists primarily of low-plasticity

silts and clays. Sands and occasionally gravels are found in the predominantly finegrained soil profile.

* Results of the compressibility and strength tests indicate that the soil has low

compressibility and very high strength. Unconfined compressive strengths vary from

1 to 15 tons per square ft (tsf), unconsolidated undrained strengths vary from 2 to 9 tsf,

and the effective strength friction angle from a consolidated undrained triaxial test is

32.6 degrees.

* The modulus and damping properties of soil from resonant column/cyclic torsion shear

tests indicate that the low-strain S-wave velocity of samples ranges from approximately

800 ft per second (fps) to over 2000 fps, depending on the specific layer from which the

soil sample was obtained. Low-strain material damping ratios for the same samples

vary from approximately 5 percent to less than 1 percent. The changes in shear

modulus and material damping ratios with the level of shearing strain are consistent with

published modulus and damping characteristics of low-plasticity soils.

The applicant stated that the purpose of the ESP site laboratory testing program was to show

that the properties of the ESP site are similar to those reported in the CPS USAR. By showing

the similarity between the two sites, the applicant was able to utilize the extensive soil

properties database in the CPS USAR to augment the information it collected for the ESP site.

The scope of the soil testing reported in the CPS USAR includes (1) strength tests on soil and

rock, (2) dynamic tests on soil samples such as cyclic triaxial and resonant column tests,

(3) tests to determine soil type, settlement potential, and dewatering requirements, (4) chemical

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tests on ground water samples, (5) strength tests on excavated soils, and (6) liquefaction tests.

The applicant compared the soil classification, strength, and consolidation test results from the

ESP and CPS sites and concluded that soil conditions at the two sites are consistent.

Specifically, the applicant obtained similar average values of water content, density, strength,

and compressibility from soil sampled at similar depths from each site. In RAI 2.5.4-1, the staff

asked the applicant to describe its criteria for assessing whether the differences in the soil

properties for the ESP and CPS sites were significant enough to warrant additional soil

exploration. In response to RAI 2.5.4-1, the applicant stated that it used both visual and

quantitative criteria to assess the similarity between the soils underlying the two sites. The

applicant stated that it would have conducted additional explorations if it had encountered

significant differences in the soil properties between the two sites. SER Section 2.5.4.3.2

provides a complete description of the applicant's response to RAI 2.5.4-1 as well as the staff's

evaluation of this response.

The applicant conducted cyclic testing of the ESP site soils to determine the variation in shear

modulus and material damping ratio with shearing strain amplitude. These dynamic properties

are necessary to construct shear modulus and damping curves in order to determine the

response of the site to the SSE ground motion. The applicant was unable to make a

comparison between its cyclic test results for the ESP and CPS sites because significant

advances in resonant column/cyclic torsional shear tests have occurred since the licensee

conducted cyclic tests on soils from the CPS site. Since it had conducted only six sets of

resonant column/cyclic torsional shear tests, the applicant decided to use the EPRI shear

modulus and damping curves (EPRI 1993) for its site response analyses. As justification for

this approach, the applicant stated the following:

The rationale for using the EPRI curves rather than the EGC ESP Site data was

that a much larger database was used to develop the EPRI curves and,

therefore, average EPRI results are expected to be representative of conditions

at the EGC ESP Site if an extensive dynamic testing program had been

conducted. It is important to note that the dynamic test results for the EGC ESP

Site are very consistent with the EPRI curves, indicating that use of the EPRI

curves is acceptable.

Figures 2.5.4-2 and 2.5.4-3, reproduced from Figures 5-20 and 5-21 in SSAR Appendix A,

show a comparison of the EPRI and ESP site cyclic test results.

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|Geotechnical Report for the EGC Early Site Pernfit

G/Gmax Plot Resonant Column and I Cyclic Torsion Test Results 1.2

08

B 04

02

Legend

-A--

--

.4.

- 4 -

V& DFbo PIlO(VMic endW OdXy, 199t)

VO D for Pl - 1S (Vuctic nd Docrry. 1991)

Cboy Pi t 10 20 (Sun et dI. I OM98

Cloy (S"d and Sun, 1989)

Sample A- 33 At deph - Rsonant Colmn

Sample A -33 It depth - Cycle Torilon

Sample B - 4<1 5 t depth Resonnt Colmn

Sample B - 41.5 t depth .. Cycic Tornion

Sample C - 1 It depth - Cyclc To'nkn Sample C -171 It depth - Resonant Cdumn

Sempl D -11 - 5 dapth - Rason.nt Coiumn

Semphe0 - 11 5Itdpth - Cydk Torion

Smp E - 20itf depth - Resonant Cdounn

S mple E - 208 t depth - Cyclic Torsion Snpleh F - 242 t depth -Rnonent Colunn

Sample F -242 * depth - Cydkic Torsion

Note:

Pl for EGC; ESP so-Istlypicemly 10

0 _

. O.00MI 0.0001 0.991 0.01 0.1

Shearing Strain AmplItude, y, (percent)

10

Figure 2.5.4-2 GIGmax plot resonant column and cyclic torsion test results

2-28i
Geotechnical Report for the EGC Early Site Permit

Figure 5-21

Material Damping Plot

Resonant Column and Cyclic Torsion Test Results

Legend

V &D fo Pi0 Vuceic CndOdgy. 199t)

V & D rOr PlI 15 Mcoic nd Dobtry 1991)

3t_ ,. - - City- Lower Bound (Sun er o. 19E9) . I - Clay. Average Bound (Sin et *1., 1998)

.9 ... Clay . Upper Bound (Sun et el, 1999)

A ,Cl.y (Idus. 19901

.. SampVIA- 33 tdepdh- Resonant Column

X - -. , So.p" A- 33 It dephh-Cycic Torsion

. Ar g* , ' Sample B-41t5 Idepth-Rasonant Cdumn

SnpbB-41 S ampl 5Odepth ..CyclikTorson

. * Sampe C- 1719 depth - Cyclru Torsion

. , -* Somple 0 - 1196 depth .Resonnt Cloumn z .- fla Sample D -115 It depth - Cyclic Torslon

/ +' / .*- SomplE -20Etd epth-Reson.utCol.m

1 .6. Sample E-20 tdeplh-Cyclic Torsion rE// 9 .4. Samp F - 242 * drpth -R wmt Cdbmn I 1- ! ;; ' . . 4 . Sample F - 242 I dplth Cyclic Torsion

Nude o ;rx Ndo

PIlafo EOC ESP soils typlcally 10

0.00001 0.0001 0.00 0.01 0.1 1 10

Shearing Straln Amplitude, y, (percent)

Figure 2.5.4-3 Material damping plot resonant column and cyclic torsion test results

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In RAI 2.5.4-2, the staff asked the applicant to justify its use of the EPRI curves and to further

explain its basis for concluding that the ESP site soils are consistent with those used to develop

the EPRI curves. In response to RAI 2.5.4-2, the applicant stated that the EPRI curves it used

represent soils in the general range of gravelly sands to low-plasticity silty or sandy clays and

that soils at the ESP site fall within this category of soils. SER Section 2.5.4.3.2 provides a

complete description of the applicant's response to RAI 2.5.4-2 and the staff's evaluation of this

response.

In RAI 2.5.4-5, the staff asked the applicant to explain the difference between soil S-wave

velocities measured directly in the field and in the laboratory using soil samples. For two of -he

soil samples, taken at depths of 208 and 242 ft. the laboratory measurement of S-wave velocity

is 68 and 76 percent, respectively, of the field-measured test results for similar depths. In

response to RAI 2.5.4-5, the applicant stated that the low values are an indication of the

accumulated disturbance that occurs to soil samples when they are removed from the ground,

transpo ted to the laboratory, and tested in equipment that may not replicate the in situ stress

state and loading conditions. SER Section 2.5.4.3.2 provides a complete description of the

applicant's response to RAI 2.5.4-2 and the staff's evaluation of this response.

2.5.4.1.3 Explorations

To characterize the ESP site, the applicant conducted a subsurface exploration program that

consisted of drilling and sampling four boreholes and conducting four cone penetrometer tests

(CPT) with pore pressure measurements. The applicant stated that the purpose of the

exploration work was to establish the location and consistency of the soil layers, to collect soil

samples for laboratory testing (see SER Section 2.5.4.1.2), and to install piezometers for

ground water monitoring. For guidance, the applicant stated that it used RG 1.132, "Site

Investigations for Foundations of Nuclear Power Plants," with the exception of the number arid

depth of explorations. The applicant stated that fewer explorations were justified because of

the similarity of soil conditions at the ESP and CPS sites. Specifically, the applicant stated in

Section .3.1.1 of SSAR Appendix A that its rationale for the reduced number of explorations vwas

as follows:

* Over 10 explorations had been previously drilled, sampled, and tested

within the general EGC ESP Site footprint area during the investigation

for the CPS Site. A careful review of this existing information determined

that the methods used for drilling and sampling, soil classification, and

laboratory testing of soils from these explorations was of sufficient quality

to allow re-use of the data for the EGC ESP Site work.

* The work being carried out for the EGC ESP was being done before the

reactor plant design had been selected. Therefore, some of the spacing

and depth requirements given in Appendix C of RG 1.132 could not be

established. Once a reactor plant design is selected, then the

requirements in Appendix C of RG 1.132 will be reviewed again during

the COL stage, along with the design requirements of the reactor plant

design, to determine whether additional drilling and sampling is needed.

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In addition, the applicant stated that if it had encountered any significant soil property variations

during its drilling and sampling program, it would have added more explorations to resolve the

observed differences.

The applicant used mud rotary drilling methods for the four explorations that it drilled at the ESP

site. Figure 2.5.4-4, reproduced from Figure 3-1 in SSAR Appendix A, shows the locations of

each of the four boreholes.

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Figure 2.5.4-4 EGC ESP geotechnical investigation locations

2-285
Two of the explorations extended to 100 ft below the ground surface, and the other two

extended 20 to 30 ft into rock at nearly 300 ft below the ground surface. The applicant used

SPT, Shelby, and Pitcher tube sampling methods to collect representative soil samples. For

each borehole, the applicant obtained SPT blowcounts and also calibrated the SPT hammer

system in one of the boreholes. At depths shallower than 100 ft, the applicant collected soil

samples at 5 ft intervals using ASTM D 1586-99, "Standard Test Method for Penetration

Resistance and Split Barrel Sampling of Soils," for guidance. At each major change in

stratigraphy, the applicant also collected undisturbed soil samples following the methods given

in ASTM D 1587-00, "Standard Practice for Thin-Walled Tube Sampling of Soils for

Geotechnical Purposes." At depths between 100 and 150 ft (at boreholes B-2 and B-3), the

applicant increased its soil sampling interval to 10 ft, and at depths greater than 150 ft. the

applicant used a sampling interval of 15 ft. For the two boreholes that extended down into rock,

the applicant collected continuous rock-core samples for classification using ASTM D 2113-99,

"Standard Practice for Rock Core Drilling and Sampling of Rock for Site Investigations."

The applicant also conducted a CPT program at the ESP site. The locations of the CPT

soundings are shown above in Figure 2.5.4-4. The applicant used the results of the CPT

soundings to evaluate the consistency of the soils in the upper 50 to 80 ft of soil in the ESP site

area. The CPT soundings included pore water pressure measurements, and during two of the

soundings, the applicant obtained S-wave velocity data. The total depths of the soundings at

CPT-1, CPT-2, CPT-3, and CPT-4 were 78.1, 55.7, 54.0, and 76.9 ft. respectively. For the

seismic tests, the applicant generated an S-wave at the ground surface by horizontally striking

a board at the surface using a sledge hammer. The applicant measured the travel time of the

resulting S-waves with a velocity-sensitive geophone located at the tip of the CPT assembly.

The applicant made measurements of S-wave travel times at 3-ft depth intervals from the

ground surface until it could no longer advance the CPT assembly into the ground.

The applicant used its four ESP boreholes and CPT soundings to augment the results of similar

programs conducted at the CPS site. The licensee conducted an extensive drilling and

sampling program during work on the CPS site, which consisted of 76 boreholes. The applicant

stated that some of these boreholes were drilled within or adjacent to the footprint of the ESP

site and a number of the boreholes extended into rock. Concerning its comparison of the

results between the ESP and CPS site boreholes, the applicant stated the following:

Results of these comparisons show that both sites consist of over 250 feet of

predominantly silts and clays overlying rock. The silts and clays are very stiff to

hard in consistency-as a result of past glaciations. Rock is slightly deeper at

the EGC ESP Site (specifically, nearly 250 ft below ground surface at the CPS

Site versus over 280 ft at the EGC ESP Site); however, rock descriptions and

quality are consistent between the sites. It was concluded from this comparison

that the engineering characteristics of the two sites are consistent; therefore, the

database from the CPS Site can be used in evaluating site response to gravity

and seismic loading at the EGC ESP Site.

2.5.4.1.4 Geophysical Surveys

The applicant conducted geophysical surveys at the ESP site in order to determine the S-wave

velocity of the soil and upper layer of rock. The applicant stated that it would use this

2-286
information to determine the response of the site to seismic ground motion propagating up from

the rock to the ground surface. In addition, the applicant stated that it may use the results of

the geophysical surveys during the COL stage of design to evaluate SSI.

The applicant used two types of geophysical seismic tests. The first test was a P- and S-wave

suspension logging test in one of the boreholes, and the second test used the CPT assembly,

which was described above in SER Section 2.5.4.1.3. The applicant conducted the P-S

suspension logging test at approximately 1 .5-ft depth intervals to within approximately 20 ft into

the top of rock. The applicant performed the test by lowering the logging probe into the open

borehole filled with drilling fluid. Each measurement recorded the average P- and S-wave

velocity of the subsurface material between the two receivers located near the top of the probe.

The applicant stated that the quality of the test results was influenced by the integrity of the

borehole sidewalls and by the consistency of the drilling mud. Therefore, in order to optimize

the quality of the measurements, the applicant performed the test on the same day as the

completion of the rock coring at borehole B-2 and mixed the bentonite drilling fluid immediately

before the start of the test; Figure 2.5.4-5, reproduced from Figure 5-19 in SSAR Appendix A,

shows the P- and S-wave velocities for each of the different soil units to a depth of about 300 ft

below the ground surface.

2-287
3h.0 (V.) l ndCoOpasslon WVltl 5o4 VlWetb (lI ___ _oll Por..... EGCC ESP S. /I..d CPS St.;'

O plh (It. IMM 1L" w M00t_.

1 bgl (t( ) Cenl. CI) LL nP. Pt Ci O efl

0oonIn 0 42 13t t6 Id 439 (4 l cbh eater T(13t) (II (25) 14 I1) tabhe tsl-l t bp

Inte.2h 42. 9 Ills 39 ° 39 (132) If?) (2) (93) (13)

iL eu-oo-TlN 59 103 la I 0

L.oWeIn 163-190 133 I3 28 t 1 ((40) (I I) (I 9) (1 ) 7

P fnohr Igo 199 269 13S 14 29 14 IS

TID (137) (14) (27) (174 (13)

ft.Afilo.d NA. 23 49 IT 29 AOrain. e 9292 (NA) (NA) (NA) (N.A) (NA)

Bd L NA. NA. NA NA N A. *9lewdlo (NA) (NA) (NA.) (NA) (vA ) ctectat 292It

Geotechnical Report for the EGC Early Site Permit

Figure 5-19

Shear and Compressional Wave

Velocities and Other Soil Properties

Legend

vat lt-2

A Vp at &2

Vs at CPT.02

- Vs at CPT0<4

Notes:

I Soil propert es sh)oof are mhe arnln ethc n"en values forall avalable 0.1 sarrple resltls tor each satrglathic, unt Top newber sthe mean ,61"d appl.able EGC ESP S3d. Irrlitga1ton data.

(Mlarc) Mean M 5ahue of aplicable dale front CPS Ste P-Series Soil Sampeles as reported on SWn 2.5 ol CPS. 2002

N A, Resu9ns not *vMilale

Figure 2.5.4-5 S- and P-wave velocities and other soil properties

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Based on its geophysical surveys, the applicant established the following minimum site

characl:eristic S-wave velocities in its plant parameter envelope (PPE) table (SSAR

Table 1.5-1):

* 820 ft/s in the upper 50 ft of soil

* 1090 ft/s to nearly 3000 ft/s at depths of 50 ft to the top of rock

* 2580 ft/s in the upper 20 ft of rock

The applicant found that its comparison of the velocities between the CPS and ESP sites

showed very similar average conditions. The applicant used a much smaller depth interval bor

its velocity measurements during the ESP site tests, and, therefore, the ESP site velocity

results provided a much better indication of the variation in velocity within each of the prominent

stratigraphic units.

2.5.4.1.5 Excavation and Backfill

SSAR Section 2.5.4.5 states that construction of the facilities at the ESP site would likely

require excavations to a depth of approximately 55 to 60 ft below the ground surface to avoid

potential settlement and liquefaction concerns. The applicant stated that during original

excavations at the CPS site, the following conditions were observed:

* The excavation work at the CPS site shows that the drilling and sampling program

provided a good description of the soil conditions in the upper 56 ft at the site,

confirming that the boreholes completed within the EGC ESP site footprint for both the

OPS and EGC ESP sites will be representative of conditions in the upper 56 ft of soil

profile.

* seepage into the construction excavation was very limited at the CPS site. This

observation indicates that dewatering requirements within the upper 56 ft at the EGC

EESP site will be minimal because of the similarity in ground water location and soil

types.

* Some localized pockets of sand were encountered at the base of the excavation at a

depth of 56 ft. These pockets were either compacted or removed and replaced with a

fyash-backfill mixture. Similar conditions could be encountered at the EGC ESP site.

The applicant found that nothing discussed within Section 2.5.4.5 of the CPS USAR indicates a

condition that would significantly affect the construction or operation of a new generating facility

at the E',P site.

2.5.4.1.6 Ground Water Conditions

The applicant installed three piezometers during its ESP site exploration to obtain more specific

information about ground water conditions at the ESP site. The applicant's ground water

measurements indicate that the static ground water table within the Illinoian till is approximately

30 ft below the ground surface, but that there are shallower perched ground water layers closer

to the surface. The applicant found similar ground water conditions at both the ESP and CPS

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sites. SSAR Section 2.5.4.6 provides a complete description of the ESP site ground water

conditions.

2.5.4.1.7 Response of Soil and Rock to Dynamic Loading

SSAR Section 2.5.4.7 defers the analyses of soil-rock-structure interaction for the ESP site to

the COL stage. Specifically, the applicant stated that these analyses will depend on the

geometry and weight of the selected power generating system, and on the method that it will

use during the COL stage to evaluate SSI. Since some of the soil and rock dynamic tests used

by the licensee for the CPS site in the mid-to-late 1970s are no longer used, the applicant

stated that before adopting any of the dynamic soil and rock properties given in the CPS USAR,

it will re-derive these dynamic properties based on the results of field and laboratory information

collected during the ESP site program (see SER Section 2.5.4.1.2) and future programs.

Section 2.5.2.3.5 of this SER presents the staff's evaluation of the applicant's free-field site

response analysis, including an evaluation of the applicant's responses to RAls 2.5.4-4 and

2.5.4-7. The applicant's decision to defer the SSI analyses to the COL stage is COL Action

Item 2.5.4-1.

2.5.4.1.8 Liquefaction Potential

To evaluate the liquefaction potential of the soils at the ESP site, the applicant used an

empirical blowcount procedure, which is described in RG 1.198, "Procedures and Criteria for

Assessing Seismic Soil Liquefaction at Nuclear Power Plants," issued November 2003. This

approach uses correlations between blowcounts recorded during SPT tests and observed

liquefaction at sites that did or did not liquefy. The empirical method calculates a factor of

safety (FOS) based on the expected soil shearing resistance and the expected maximum

seismically induced shearing stresses in a soil layer. The soil shearing resistance is quantified

by the cyclic resistance ratio (CRR), which is determined from the SPT blowcount values, with

modifications for depth and SPT driving conditions. The shearing stresses induced by seismic

loading are quantified by the cyclic stress ratio (CSR), which is proportional to the PGA for the

specified seismic loading. In addition, the method uses a magnitude scaling factor (MSF),

which is based on the specified earthquake M, that is expected to generate the specified PGA.

The FOS against liquefaction is calculated as:

CRR

FOS =-CR(MSF) CSR( )

The MSF is smaller for larger magnitude earthquakes (reducing the FOS) to account for the

longer duration of shaking and lower frequency vibrations typical of larger events. The

applicant calculated the FOS against liquefaction for soil conditions at regular depth intervals to

obtain a profile of FOS with depth.

To implement the above liquefaction procedure for the ESP site, the applicant used a PGA of

0.3g, which represents the peak acceptable value for the plant that forms the basis for the PPE.

The applicant also used a range of earthquake magnitudes (M = 5.5, 6.5, and 8.0) that are

consistent with the range of source mechanisms that have the potential to cause ground

shaking at the ESP site. To estimate the shearing resistance of the ESP site soils, the

applicant used the SPT blowcount values from its four boreholes (B-1, B-2, B-3, and B-4). The

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applicant found that the FOS is greater than 1.1 for the soil layers below a depth of 60 ft below

the ground surface. Above 60 ft, the applicant found several layers where the FOS is less than

1.1, indicating that these layers are susceptible to liquefaction. RG 1.198 states that soil

elements with an FOS less than or equal to 1.1 'Would achieve conditions wherein soil

liquefaction should be considered to have been triggered." However, the applicant stated that

these soils (susceptible to liquefaction) will "need to be excavated and replaced or improved for

settlement considerations, thereby mitigating any liquefaction potential." Therefore, the

applicant concluded that liquefaction is not a design consideration for the ESP site.

In RAI 2.5.4-6, the staff asked the applicant to provide a sample liquefaction analysis from one

of its four borehole locations and to clearly show how it determined the FOS for the different soil

layers. In addition, the staff asked the applicant to describe the methods that it might use to

mitigate the potential for liquefaction and to describe the extent of the liquefiable soils over the

ESP site area. In response to RAI 2.5.4-6, the applicant provided a sample calculation for

borehole B-1 at the 38.5-ft depth interval. In addition, the applicant described the methods

(other than removal and replacement) that it may use to mitigate the potential for liquefaction.

The applicant stated that it encountered noncohesive soils in its soil borings, but that not all of

these noncohesive soils are considered liquefiable. SER Section 2.5.4.3.8 provides a complete

description of the applicant's response to RAI 2.5.4-6 and the staff's evaluation of this

response.

For the OPS site, the licensee used a different method to assess the potential for liquefaction.

Instead of using the empirical blowcount procedure, the licensee used cyclic triaxial testing to

determine the soil shearing resistance. To determine the shearing stresses induced by seismic

loading, the licensee used the SSE ground motion. Using this method, the licensee found an

FOS greater than 2.0, and, therefore, liquefaction was not an issue for the CPS site.

2.5.4.1.9 Earthquake Design Basis

SSAR Section 2.5.4 describes the development of the SSE ground motion for which the

applicant used the performance-based approach, described in ASCE/SEI Standard 43-05.

Section 2.5.2.1.6 of this SER describes the applicant's use of the performance-based approach

to develop the SSE response spectrum for the ESP site.

2.5.4.1.10 Static Stability

The applicant did not estimate the bearing capacity, settlement, or lateral earth pressures for

the ESP site, since it has not selected a nuclear power plant design. The applicant stated that

each generating system has different footprint sizes, depths of embedment, and effective

weights, and these variables will affect the determination of bearing pressures, settlement, and

lateral earth pressures. For this reason, the applicant deferred the determination of static

stability to the COL stage.

Using the licensee's evaluation of static stability for the CPS site, the applicant stated that it

expected high allowable bearing values and low compressibility for the ESP site because of the

similarity in soil conditions between the two sites. Based on the bearing capacity values giver

in the CPS USAR, which range from 39.9 to 60.6 tsf, the applicant established the minimum

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site characteristic value for bearing pressures at the ESP site at 25 tsf. Net foundation

pressures for the Category I structures at the CPS site are less than 2.5 tsf.

In RAI 2.5.4-3, the staff asked the applicant to provide further detail regarding the criteria that it

used to establish the minimum static bearing capacity of 25 tsf for the ESP site. In response to

RAI 2.5.4-3, the applicant stated that the methods used by the licensee for the calculation of the

bearing capacities were conventional methods that assume a local shear failure condition. The

applicant stated that the combination of foundation depth below the ground surface and the

heavily overconsolidated state of the Illinoian till result in the high bearing capacities given in the

CPS USAR. Comparing the minimum bearing capacity value chosen by the applicant (25 tsf)

with the lower value in the range of bearing capacities for the CPS site (39.9) provides an FOS

greater than 1.5. SER Section 2.5.4.3.10 provides a complete description of the applicant's

response to RAI 2.5.4-3 and the staff's evaluation of this response.

2.5.4.1.11 Design Criteria

SSAR Section 2.5.4.11, "Design Criteria," states that the design criteria for the ESP site

Category I structures will be established during the COL stage when the physical characteristics

of the operating system are known. The applicant stated that it would use the CPS USAR as a

starting point for developing design criteria for the ESP site.

2.5.4.1.12 Techniques to Improve Subsurface Conditions

SSAR Section 2.5.4.12, "Techniques to Improve Subsurface Conditions," states that until the

power generating system is selected, the need for ground improvement for the ESP site is

unknown. The applicant stated that systems that are founded at depths of 55 ft or above could

require ground improvement and that decisions regarding the need for and type of ground

improvement will be made during the COL stage. For the CPS site, the licensee encountered

localized areas and pockets of loose granular material at the base of excavations for the CPS

Category I structures (about 55 ft below the ground surface) during construction at the CPS

site. These materials were either compacted or removed and replaced with a flyash-backf ill

material.

2.5.4.1.13 Subsurface Instrumentation

SSAR Section 2.5.4.13, "Subsurface Instrumentation," states that the settlement measurements

made by the licensee for the CPS plant structures will be used for future settlement predictions

at the ESP site. Because of the similar soil conditions between the two sites, and assuming the

new facilities are similar in size, load, and foundation level to those constructed at the CPS site,

the applicant stated that it will be able to use conventional settlement prediction methods and

rely on the previous settlement measurements.

2.5.4.1.14 Construction Notes

SSAR Section 2.5.4.14 states that the CPS USAR provides valuable information from the

construction of the CPS facilities and that this information will be used during the COL stage of

the project. The applicant stated the following:

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Any future excavation associated with the construction of a new generating

system will be mapped to confirm that soil types and consistency are in general

accord with the conditions identified during previous construction at the site and

that have been interpreted from the field explorations carried out at the EGC

ESP Site. This field mapping will involve inspecting excavated slopes for the

presence of previously unknown fault offsets.

The applicant also committed to (1) "notify the NRC staff immediately if previously unknown

geologic features that could represent a hazard to the plant are encountered during

excaval:ion," and (2) "notify the NRC staff when the excavations are open for examination and

evaluat on."

2.5.4.2 Regulatory Evaluation

SSAR Section 2.5.4 describes the applicant's evaluation of the stability of the subsurface

materials and foundations at the ESP site. In SSAR Section 1.5, the applicant stated that it

developed the geological, geophysical, and geotechnical information used to evaluate the

stability of the subsurface materials in accordance with the requirements of 10 CFR 100.23.

The applicant applied the guidance of RS-002, RG 1.70, DG-1 105 (which has been superseded

by RG 1.198 since the applicant submitted the SSAR), RG 1.132, and RG 1.138, "Laboratory

Investigations of Soils for Engineering Analysis and Design of Nuclear Power Plants." The staff

reviewed SSAR Section 2.5.4 for conformance with the regulatory requirements and guidance

applicable to the characterization of the stability of subsurface materials, as identified below.

In its review of SSAR Section 2.5.4, the staff considered the regulatory requirements in

10 CFR 100.23(c) and 10 CFR 100.23(d)(4). According to 10 CFR 100.23(c), applicants must

investigate the engineering characteristics of a site and its environs in sufficient scope and

detail to permit an adequate evaluation of the proposed site. Pursuant to 10 CFR 100.23(d)(4),

applicants must evaluate siting factors such as soil and rock stability, liquefaction potential, and

natural End artificial slope stability. Section 2.5.4 of RS-002 provides specific guidance

concerning the evaluation of information characterizing the stability of subsurface materials,

including the need for geotechnical field and laboratory tests as well as geophysical

investigations.

2.5.4.3 Technical Evaluation

This section provides the staff's evaluation of the geophysical and geotechnical investigations

carried out by the applicant to determine the static and dynamic engineering properties of the

materials that underlie the ESP site. The technical information presented in SSAR

Section 2.5.4 resulted from the applicant's field and laboratory investigations performed for the

ESP. The applicant intended its ESP field and laboratory field investigations to confirm the

large volume of geotechnical data developed by the licensee for the existing CPS units, located

adjacent to the ESP site. The applicant used the subsurface material properties from its field

and laboratory investigations to evaluate the response of the site to dynamic loading (SSE

ground motion), including liquefaction potential. The applicant deferred the determination of

static stability to the COL stage.

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Through its review of SSAR Section 2.5.4, the staff determined whether the applicant

adequately sampled the subsurface materials underlying the ESP site in order to characterize

the engineering properties as well as the response of -thesite1to dynamic and static loading.

The staff also reviewed the applicant's field and laboratory investigations used to determine the

geotechnical engineering properties of the soil and rock underlying the ESP site. In addition,

the staff observed some of the applicant's onsite borings and field explorations, performed

August 7-8, 2002, to determine whether the applicant followed the guidance in RG 1.132.

2.5.4.3.1 Geologic Features

SSAR Section 2.5.4.1 references SSAR Section 2.5.1 for a description of the regional and site

geology. Section 2.5.1.3 of this SER presents the staff's evaluation of the regional and site

geology.

2.5.4.3.2 Properties of Subsurface Materials

The staff focused its review of SSAR Sections 2.5.4.2 (properties of subsurface materials) and

2.5.4.3 (explorations) on the applicant's description of (1) subsurface materials, (2) field

investigations, (3) laboratory testing, and (4) static and dynamic engineering properties of the

ESP site subsurface materials.

Normally, an applicant performs a complete field investigation and sampling program to

evaluate the engineering properties and stability of the soil and rock underlying the site.

However, since the applicant relied on the licensee's previous field and laboratory investigations

for the existing CPS units, the applicant's ESP investigations were used to confirm previously

established soil and rock properties. As such, the applicant conducted a subsurface exploration

program that consisted of drilling and sampling four boreholes and conducting four CPTs. In

RAI 2.5.4-1, the staff asked the applicant to describe its criteria for assessing whether the

differences in the soil properties for the ESP and CPS sites were significant enough to warrant

additional soil exploration. In addition, the staff asked the applicant to provide tables showing a

comparison between the static and dynamic soil properties for the two sites. In response to

RAI 2.5.4.1, the applicant stated that it would have conducted additional explorations if it had

encountered significant differences in the soil properties between the two sites. The applicant

stated that the geologic information it reviewed indicated that the regional processes that

formed the site profile at the two sites were the same. In addition, the applicant stated that the

sampling program for the CPS site included a number of explorations within and beyond the

ESP site. Since the geologic formation and stratigraphy for the two sites were essentially the

same, the applicant expected to encounter only small local variations in soil properties during its

ESP site exploration. During its ESP site exploration, the applicant visually monitored the soil it

retrieved during drilling and sampling to see if the soil color and texture were consistent with the

soil profile described in the CPS site USAR. In addition, the applicant also compared the SPT

blowcount values that it obtained from the ESP boreholes to those from the CPS site boreholes.

The applicant used the combination of consistency, color, and texture to decide whether the

material was essentially the same. As an example of its evaluation process, the applicant

stated the following:

For example, if the blowcount reported in the USAR was significantly different

(e.g., an order of magnitude greater) than what was recorded during the EGC

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ESP Site exploration program and the texture of the material was fine-grained

rather than a sand, the field task leader for the EGC ESP Site explorations was

prepared to take additional soil samples to investigate this difference.

Once the applicant completed its fieldwork, it made the following comparisons during its

laboratory testing program:

* It compared visual-manual field descriptions of the soil samples collected during the

EGC ESP site investigation with each other and with CPS site data. These comparisons

were performed to evaluate whether each stratigraphic unit encountered at the CPS site

was present or absent at the EGC ESP site, and to identify similarities and/or

differences in thickness of and contact elevations between these units. Soil descriptions

compared include apparent soil gradation, plasticity, presence of inclusions and

bedding, color, consistency (soft to hard, loose to dense), and moisture condition. This

comparison differed from that done in the field from the standpoint that all the

information was available for review, rather than the individual comparisons done in the

Field as the boring was drilled and sampled. Details of these comparisons are presented

in Sections 5.2.1 and 5.2.2 of SSAR Appendix A. As described, the same stratigraphic

units were identified between each EGC ESP site investigation location and the CPS

site, with moderate variations in contact elevations and unit thicknesses.

* uIt compared data from laboratory tests performed on samples from the EGC ESP site

with each other and with CPS site test data. These comparisons were performed to

identify similarities and/or differences in engineering properties of the stratigraphic units

between the two sites, and within the EGC ESP site. Test results compared include

Atterberg Limits, in situ dry density, moisture content, undrained shear strength, and

consolidation properties. Results of these comparisons are presented in Sections 5.2.2

and 5.2.3 of SSAR Appendix A. SPT blowcounts at the two sites were also compared,

As summarized in Section 5.2.1 of SSAR Appendix A. S- and P-wave velocity data from

the seismic CPT and suspension logging tests were also compared with applicable data

from the CPS site (from downhole and uphole logging tests), as described in

section 5.2.4 of SSAR Appendix A.

After making the comparisons as described above, the applicant developed qualitative and

quantitative criteria to determine the similarity between soil stratigraphic units and the

engineering properties within each stratigraphic unit. The applicant's qualitative criteria

consisted of observing the similarities of the soil descriptions between the sites. These

descriptions included soil color, texture, and consistency in terms of denseness or hardness as

indicated by SPT blowcounts. The applicant's quantitative criteria consisted of comparing plots

and tables of the engineering property data for similarity. The applicant's comparison focused

on the typical range of properties within a stratigraphic unit recorded at the CPS site versus the

range in the same properties recorded at the ESP site. The applicant stated that it did not use

"hard numerical acceptance criteria" for this comparison of engineering properties; however, the

applicant observed that the ESP site data generally fell within the range of CPS site results for

each stratigraphic unit. In conclusion, the applicant stated that there were some variations, but

that these variations were not considered significant enough to alter the conclusion that

subsurface conditions are similar between the sites and within the ESP site.

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The staff reviewed the applicant's comparison of the soil properties between the two sites in

Section 5.2 of SSAR Appendix A. The staff's review included a comparison between SPT

blowcount values, in situ dry density, moisture content, Atterberg limits, compressibility and

strength characteristics, P- and S-wave velocities, and modulus and damping properties. In

addition, the staff also reviewed the tabulated statistical summaries of the geotechnical test

results that the applicant provided in response to RAI 2.5.4-1. Figures 5-7 through 5-18 in

SSAR Appendix A provide an excellent visual comparison of the engineering properties

between the CPS and ESP sites. While there are some outliers, for the most part the staff

concurs with the applicant's conclusion that the subsurface conditions are similar between the

two sites. As such, the staff concludes that the applicant has sufficiently sampled the ESP site

subsurface in order to establish the similarity between the CPS and ESP sites. The staff notes

that 76 locations were drilled and sampled by the licensee for the CPS site investigation and

that some of these locations (10) overlapped with the ESP site area. Regarding future

subsurface investigations for the ESP site, the applicant stated the following:

The work being carried out for the EGC ESP was being done before reactor

plant design had been selected. Therefore, some of the spacing and depth

requirements given in Appendix C of Regulatory Guide 1.132 could not be

established. Once a reactor plant design is selected, then the requirements in

Appendix C of Regulatory Guide 1.132 will be reviewed again during the COL

stage, along with the design requirements of the reactor plant design, to

determine whether additional drilling and sampling is needed.

Concerning the appropriate spacing of borings or soundings, RG 1.132 states that for favorable

uniform geologic conditions, at least one boring should be made at the location of every safetyrelated structure. Where variable conditions occur, RG 1.132 states that the spacing between

borings should be smaller. For larger, heavier structures, such as the containment and auxiliary

buildings, RG 1.132 recommends a boring spacing of at least 100 ft with a number of additional

borings along the periphery, at corners, and other selected locations. Regarding the

appropriate depth for borings, RG 1.132 states that all borings should extend at least 33 ft

below the lowest part of the foundation. With regard to these recommendations in RG 1.132,

the staff cannot accept the applicant's concluding statement to review RG 1.132 at the COL

stage to "determine whether additional drilling and sampling is needed" as sufficient. While the

staff's review of the applicant's geotechnical field and laboratory test results confirmed the

similarity between the CPS and ESP subsurface soil layers and properties, this similarity does

not eliminate the need for further soil borings during the COL stage. There are enough

variations in the soil properties within the ESP site itself to necessitate further exploration at the

COL stage. Examples include variations in SPT blowcount values, S-wave velocities, and other

static and dynamic properties, which may indicate localized areas of variable subsurface

material.

In Open Item 2.5.4-1, the staff asked the applicant to clarify its intentions with respect to the

need for additional field drilling and sampling of soil at the ESP site during the COL stage. In

response, the applicant stated that the original wording in the ESP application indicates that the

need for additional explorations will be determined during the COL stage. The applicant stated

that this wording will be revised to indicate that additional exploration work is expected

consistent with the following information:

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If this site is selected in the future for a COL application, additional explorations

Will be conducted by the COL contractor for the final design of the selected

reactor system. This additional exploration work will include a sufficient amount

of drilling and sampling to characterize soil conditions and collect soil samples

for laboratory testing necessary for the final design of the foundations for the

:structures. The numbers and locations of the additional explorations will depend

on the depth and plan view area of the foundation for the selected reactor

system, the net weight of the various components of the reactor system, and the

sensitivity of the selected system to settlement. These explorations would be

required to meet the standard of practice for foundation design of a large

structure. Additional explorations will also be required for the new intake

alignment, and could be required to assess construction methods. Examples of

exploration carried out for construction evaluations could include groundwater

pump tests for dewatering evaluations or collections of samples from selected

areas for material re-use studies.

The COL application will consider and address Regulatory Guide 1.132 when

determining the number, location, depth, and type of explorations. The specific

scope of final explorations will also consider the design requirements of the

structure and the uniformity of conditions encountered during the COL

explorations relative to previous information and relative to design requirements

such that appropriate and sufficient information is available for final design of the

selected reactor system.

Since the applicant has clarified its intentions to perform further drilling and sampling during the

COL stage and to address the guidance recommended by RG 1.132, the staff considers Open

Item 2.5.4-1 to be resolved. The applicant's commitment to address the guidance in RG 1.132

regarding drilling and sampling during the COL stage is COL Action Item 2.5.4-2.

To determine the variation in shear modulus and material damping ratio with shearing strain

amplitude, the applicant conducted cyclic testing of the ESP site soils. These dynamic

properties are necessary to construct shear modulus and damping curves in order to determine

the response of the site to the SSE ground motion. The applicant was unable to make a

comparison between its cyclic test results for the ESP and CPS sites, since significant

advances in resonant column/cyclic torsional shear tests have occurred since the licensee

conducted cyclic tests on soils from the CPS site. Since the applicant conducted only-six sets

of resonant column/cyclic torsional shear tests, the applicant decided to use the EPRI shear

modulus and damping curves (EPRI, 1993) for its site response analyses. The EPRI curves

are based on a much larger cyclic testing data set than that gathered by the applicant for the

ESP site. In RAI 2.5.4-2, the staff asked the applicant to justify its use of the EPRI curves and

to further explain its basis for concluding that the ESP site soils are consistent with those used

to develoo the EPRI curves. In addition, the staff asked the applicant to explain why the

material damping values from the ESP laboratory tests, shown in Figures 5-21 and 5-24 of

SSAR Appendix A, are higher than the EPRI damping curves. In response to RAI 2.5.4-2, the

applicant stated that the EPRI curves represent soils in the "general range of gravelly sands to

low plasticity silty and sandy clays." The EPRI curves are based on a hyperbolic model of the

nonlinear change in soil shear modulus and material damping with shearing strain. This model

was developed in the late 1960s and early 1970s through laboratory testing programs and

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developed for use in generic site response studies in eastern North America. Subsequent to

the development of the EPRI curves, the applicant stated that regression analyses of recorded

ground motions "were conducted to confirm that use of the curves in site response analyses

produces reasonable ground response predictions." The applicant stated that information in

Section 5.2 of SSAR Appendix A indicates that soils at the ESP site fall within the range of

gravelly sands to low-plasticity silty or sandy clays. In response to the staff's observation that

the ESP laboratory testing data for hysteric damping appear to be relatively high at low strain

compared to the generic data from the EPRI report, the applicant stated the following:

The information in Figure 5-21 (SSAR Appendix A) does indeed suggest that the

hysteric damping from the laboratory tests was higher than the EPRI curves.

The same conclusion can be made from the information in Figure 5-24.

However, the curves that are above the EPRI damping curves are related to the

resonant column tests. The fact that the resonant column data shown in

Figures 5-21 and 5-24 are solid, bold lines masks the response from the

torsional shear tests-suggesting that all the damping values are too high at low

shearing strain amplitudes. However, material damping values from the torsional

shear tests are consistent with the EPRI damping curves, as shown in

Figures 4.2-2 through 4.2-6 of Appendix B to the EGC ESP SSAR.

The higher damping from the resonant column tests has been recognized for a

number of years, and was noted in the EPRI (1993) set of reports. It is attributed

to rate of loading effects. Typical frequencies of loading for the resonant column

test range from 100 to 200 Hz for these soils. As the frequency increases from

the torsional shear testing (frequencies of 0.1 to 10 Hz) to resonant column

(frequencies of 100 to 200 Hz), the absolute value of damping increases by

several percent. This trend is shown in Figures B.15, C.15, D.15, E.15, and

G.1 5 of Attachment A-7 to the Appendix A report. The observed frequency

effect on damping is the reason combined resonant column/torsional shear

(RC/TS) tests are conducted. The frequency of loading for the torsional shear

tests ranges from 0.1 to 10 Hz and therefore is much more consistent with

predominant frequencies of earthquake loading.

In order to verify the applicant's classification of the ESP soils as "gravelly sands to low

plasticity silty and sandy clays," the staff reviewed Section 5.2.2 of SSAR Appendix A.

Section 5.2.2 provides a general description of each of the soil layers underlying the ESP site

and includes information on plasticity, water content, and dry density. The staff concludes from

its review that the applicant's characterization of the ESP site soils is appropriate. In addition,

the staff concludes that the applicant's use of the EPRI curves is justified since these curves

are based on a much larger database of properties from similar soils (gravelly sands) than

those obtained by the applicant for the ESP site from its four soil borings. Although the fit

between the EPRI curves and the resonant column tests on the ESP site soils is weak, the staff

notes that the torsional shear test data do fit the EPRI curves. The frequency of loading for the

torsional shear tests ranges from 0.1 to 10 Hz, which is consistent with the predominant

frequencies of earthquake ground motion. Figure 2.5.4-6, which reproduces Figure 4.2-2 from

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is

Sample Depth - 33 ft (10.1 m)

1.00

0.80

Mx

EU

12

O

0.60

0.40

0.20 _

0.00

0.00 0.00 0.01 0.10 1.00

Shearing Strain, %

10.00

6

0.0

E

0

0.00 '

0.00 0.00 0.01 0.10 1.00

Shearing Strain, %

10.00

* RC Test @ 27 psi

* TS Test O 27 psiOCycle 10

A TS Test @ 108 psi Cyde I

| Generic Orve 21-50 ft

- --- - Generic Ourve 120-250 It

A TS Test e 27 psi Cycle 1

* W Teste 108psi

a TS Test Q 108 psi rjce 10

-- o- - Generic QCrve 51-120 ft

Seismic Hazards Report for the EGC ESP Site Figure

dulus Reduction and Damping Test Results Compared to EPRI (1993) Soil 4.2-2

Property Curves for Test UTA-34-A|

Figure 2.5.4-6 Modulus reduction and damping test results compared to EPRI (1993) soil

property curves for test UTA-34-A

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SSAR Appendix B, shows the fit between the ESP site data from the resonant column and

torsional shear tests compared to the EPRI (1993) generic curves for gravelly sands to lowplasticity silty or sand clays.

Based on its review of the applicant's soil classifications and the fit between the ESP site soil

torsional shear test data and the EPRI (1993) generic curves, described above, the staff

concludes that the applicant's use of the EPRI shear modulus and damping curves is

appropriate.

In addition to its field measurements (CPT and suspension logging) of the soil S-wave

velocities, the applicant also made laboratory measurements of S-wave velocity using the six

resonant column tests on ESP site samples taken over a range of depths. For the first four

laboratory samples (from depths of 33, 41.5, 115, and 171 ft below the surface), the applicant's

S-wave velocity results closely match the field suspension logging test results. As shown in

Table 5-3 of SSAR Appendix A, the ratio of laboratory- to field-measured S-wave velocity is

between 86 to 95 percent for each of these samples. For the deepest two soil samples at

depths of 208 and 242 ft, the ratio decreased to 68 and 76 percent, respectively. Since the

difference between S-wave velocities (field and laboratory) is caused primarily by sample

disturbance associated with the laboratory testing process, the staff asked the applicant in

RAI 2.5.4-5 to justify these low ratios. In response to RAI 2.5.4-5, the applicant stated that the

low ratios are an indication of the accumulated disturbance that occurs to soil samples when

they are removed from the ground, transported to the laboratory, set up in the laboratory, and

tested in equipment that may not replicate the stress state and loading conditions in situ during

a seismic event. For the soil sample with the lowest ratio (0.68), the applicant stated that this

was an obviously disturbed sample as shown by its modulus and damping ratio curves, which

are shown in Figures 5-20 and 5-21 in SSAR Appendix A (Sample E). For the deepest sample

at 242 ft below the surface, the applicant attributed its low ratio (0.76) to the large, unavoidable

stress relief as the applicant brought the sample to the surface. Since these two deeper soil

samples showed evidence of disturbance, the applicant used only the shallower soil samples to

determine the shear modulus and damping ratio to justify its use of the EPRI (1993) generic

curves.

Since the applicant was able to use its shallower laboratory test results to show a fit to the EPRI

(1993) generic shear modulus and damping ratio curves (see RAI 2.5.4-2 above), the staff

concludes that the low laboratory- to field-measured S-wave velocity ratios are not significant.

The applicant used the EPRI (1993) generic curves to determine the site response to the SSE

ground motion.

The staff concludes, based on its review of SSAR Sections 2.5.4.2 and 2.5.4.3 and the

applicant's responses to its RAIs and open item, that the applicant adequately determined the

engineering properties of the soil and rock underlying the ESP site through its field and

laboratory investigations. In addition, the applicant used the latest field and laboratory

methods, in accordance with RGs 1.132 and 1.138, to determine these properties. The staff

concludes that the applicant performed sufficient field investigation and laboratory testing to

establish the similarity between the CPS and ESP sites and, as such, the overall subsurface

profile as well as the material properties underlying the ESP site. The staff notes that in

response to Open Item 2.5.4-1 the applicant committed to perform additional investigations (soil

borings) once it has selected the building locations, as recommended in RG 1.132 (see Open

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Item 2.5.4-1 above). The COL (or construction permit (CP)) applicant will need to describe

these additional investigations in its COL (or CP) application. See COL Action Item 2.5.4-2.

2.5.4.3.3 Relationship of Foundations and Underlying Materials

Section 2.5.4.3 of RS-002 directs the staff to compare the applicant's plot plans and the profiles

of all seismic Category I facilities with the subsurface profile and material properties. Based on

this comparison, the staff can determine if (1) the applicant performed sufficient exploration of

the subsurface and (2) the applicant's foundation design assumptions contain adequate

margins of safety. The applicant decided to provide this information as part of its COL

submittal. Submission of the applicant's plot plans and the profiles of all seismic Category I

facilities for comparison with the subsurface profile and material properties is COL Action

Item 2.5.4-3.

2.5.4.3.4 Geophysical Surveys

The staff focused its review of SSAR Section 2.5.4.3 on the adequacy of the applicant's

geophysical investigations to determine the soil and rock dynamic properties. The applicant

conducted four CPT soundings and, during two of the soundings, obtained S-wave velocity

data. To measure the S-wave velocity of the soil, the applicant generated an S-wave at the

ground surface by horizontally striking a board at the surface using a sledge hammer. The

applicant measured the travel time of the resulting S-waves with a velocity-sensitive geophone

located at the tip of the CPT assembly. In addition to the CPT soundings, the applicant also

conducted P- and S-wave suspension logging tests in one of its four soil borings. The applicant

performed the suspension logging test at approximately 1.5-ft depth intervals to within

approximately 20 ft into the top of rock. In addition to these two seismic tests, the applicant

also measured the S-wave velocity of the soil samples in the laboratory as part of its cyclic

testing.

The staff reviewed the applicant's description of the suspension logging test and the CPT. In

addition, the staff reviewed the applicant's test reports, prepared by its two contractors, in

Attachments A-4 and A-5 to SSAR Appendix A. Attachment A-4 provides the details of the

applicant's CPT soundings and includes a number of seismograms, which show the S-wave

arrivals at the tip of the CPT assembly. In addition, the staff reviewed the applicant's

computation of the S-wave velocities, which were based on S-wave travel times and the seismic

receiver (geophone) depth. Attachment A-5 provides the details of the applicant's suspension

logging tests and includes a few sample seismograms, a P- and S-wave velocity depth profile,

and the measured P- and S-wave velocity values. For the 280 ft of soil, the S-wave velocity

gradually increased from about 800 ftWs to nearly 3000 ft/s. The staff noted that there are fairly

significant oscillations in the S-wave velocity profile with depth, which the applicant captured in

its dynamic site response analyses (see Section 2.5.2.1.5 of this SER). The S-wave velocity

results from the CPT soundings, which covered the upper soil layers to a depth of about 55 and

76 ft, are consistent with those from the suspension logging tests. In addition, the older CPS

site S-wave velocity results are consistent with the ESP site results.

The staff has determined that the applicant used the latest geophysical and geotechnical

measurement methods and equipment in accordance with the recommendations of RGs 1.132

and 1.13,3 to determine the dynamic properties of the soil and rock underlying the site. Based

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on its review of SSAR Section 2.5.4.4, the staff concludes that the applicant adequately

determined the soil and rock dynamic properties through its geophysical survey of the ESP site.

2.5.4.3.5 Excavation and Backfill

In SSAR Section 2.5.4.5, the applicant stated that the construction of the facilities at the ESP

site would likely require excavations to a depth of approximately 55 to 60 ft below the ground

surface to avoid potential settlement and liquefaction concerns. The applicant also described

some of the licensee's findings during its excavations for the CPS site. The most important

finding is that the licensee encountered some localized pockets of sand at the base of the

excavation at a depth of 56 ft. The licensee either compacted these sand pockets or removed

and replaced them with a flyash-backf ill mixture.

Since the applicant has not selected a reactor design or location within the ESP site, it did not

provide detailed excavation and backfill plans or plot plans and profiles as outlined in

Section 2.5.4 of RS-002. Therefore, the staff could not adequately evaluate the applicant's

excavation and backfill plans and will await future submittal of these plans as part of the COL or

CP application. This is COL Action Item 2.5.4-4.

The applicant also included SSAR Sections 2.5.4.13 and 2.5.4.14 in its application. The ESP

review standard RS-002 covers these two subsections under Section 2.5.4.5.

SSAR Section 2.5.4.13 states that the applicant will perform settlement analyses at the COL

stage and will be able to use previous settlement measurements made by the licensee for the

CPS plant structures. The applicant's assertion is based on the assumption of similar soil

conditions between the two sites and that the new facilities will be similar in size, load, and

foundation level to those constructed at the CPS site. The need for the COL or CP applicant to

perform settlement analyses is covered below in SER Section 2.5.4.3.10.

SSAR Section 2.5.4.14 states that the applicant will map any future excavation associated with

the construction of a new nuclear power plant to confirm that the soil types and consistency are

in agreement with the conditions identified and interpreted from the ESP field explorations. The

applicant stated that this field mapping will involve inspecting excavated slopes for the presence

of previously unknown fault offsets. The applicant also committed to inform the NRC staff (1) if

it encounters previously unknown geologic features that could represent a hazard to the plant

and (2) when site excavations are open for examination and evaluation. These commitments

comprise COL Action Item 2.5.4-5.

2.5.4.3.6 Ground Water Conditions

In SSAR Section 2.5.4.6, the applicant briefly described its installation of three piezometers

during its ESP site exploration to obtain more specific information about ground water

conditions at the ESP site. The applicant found that the static ground water table is

approximately 30 ft below the ground surface and that the ground water conditions are similar

at the ESP and CPS sites.

Since the applicant has not selected a reactor design or location within the ESP site, it did not

provide an evaluation of ground water conditions as they affect foundation stability or detailed

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dewatering plans as outlined in Section 2.5.4 of RS-002. Therefore, the staff could not evaluate

the ground water conditions as they affect the loading and stability of foundation materials or

the applicant's dewatering plans during construction as well as ground water control throughout

the life of the plant. As such, the staff will await the future submittal of these evaluations and

plans a; part of the COL or CP application. The need to evaluate ground water conditions as

they affect foundation stability or detailed dewatering plans is COL Action Item 2.5.4-6.

2.5.4.3.7 Response of Soil and Rock to Dynamic Loading

In SSAR Section 2.5.4.7, the applicant stated that it deferred the analyses of the SSI for the

ESP site to the COL stage. Since the SSI analyses will depend on the geometry and weight of

the selected power generating system and the ESP applicant has not selected a reactor des.gn

or locatiDn within the ESP site, it did not perform SSI analyses. The staff concurs with the

applicant's decision to defer the SSI analyses to the COL stage; however, the staff expected to

review the applicant's determination of the free-field site amplification response in SSAR

Section 2.5.4.7. Instead of providing the ESP site free-field site amplification in SSAR

Section 2.5.4.7, the applicant provided the site amplification in SSAR Section 2.5.2.5 and a

description of the soil dynamic properties in SSAR Section 2.5.4.2. Section 2.5.2.3.5 of this

SER contains the staff's evaluation of the applicant's site response analyses, and SER

Section :2.5.4.3.2 provides the staff's evaluation of the ESP site dynamic soil properties.

2.5.4.3.8 Liquefaction Potential

In its review of SSAR Section 2.5.4.8, the staff evaluated the applicant's liquefaction analyses.

The stafl's review focused on the applicant's conclusion that, based on its liquefaction

evaluations, liquefaction is not a design consideration for the ESP site. The applicant found

that, above 60 ft below the ground surface, there are several soil layers for which the FOS

against liquefaction is less than 1.1, indicating that these layers are susceptible to liquefaction.

However, the applicant stated that "potentially liquefiable soils in the upper 60 ft at the EGC

ESP Site will likely have to be removed to meet settlement requirements." The applicant stated

that it would select fill material (heavily compacted granular fill) that is stronger than the

removed soil, which would increase the FOS against liquefaction to be greater than 1.1.

Concerning the applicant's liquefaction analyses, the staff reviewed the empirical blowcount

procedure used by the applicant, which is described in RG 1.198. The empirical method

calculates, an FOS based on the expected soil shearing resistance and the expected maximurn

seismically induced shearing stresses in a soil layer. In RAI 2.5.4-6, the staff asked the

applicant to provide a sample liquefaction analysis from one of the four borehole locations and

to clearly show how it determined the FOS for the different soil layers. In addition, the staff

asked the applicant to describe the methods that it may use to mitigate the potential for

liquefaction and to describe the extent of the liquefiable (noncohesive) soils over the ESP site

area.

In response to RAI 2.5.4-6, the applicant provided a sample calculation for borehole B-1 at the

38.5-ft depth interval. In addition, the applicant described the methods (other than removal and

replacement) that it may use to mitigate the potential for liquefaction. The four ground

improvement methods described by the applicant are (1) use of vibro-densification methods,

(2) use of stone columns, (3) use of in-place soil cement mixing, and (4) use of earthquake

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- -

drains. For each of these improvement methods, the applicant provided a brief description and

an assurance that most of these methods have been tested in severe earthquakes and have

successfullyicontrolled the-potential for-and consequences of liquefaction. With regard to the

third part of RAI 2.5.4-6, the applicant provided the following description of the extent of the

noncohesive (silts and sands) soils over the ESP site area:

The extent of the non-cohesive soils at the EGC ESP site is generally limited to

outwash intervals in the Wisconsinan till, interglacial zone, and upper 15 feet of

the Illinoian till. Interbedded silt and sand layers were encountered from 62 to

72 feet bgs [below ground surface] at Borehole B-2, sand was encountered from

43 to 60 feet bgs at Borehole B-3, and clayey sand was encountered from 49 to

59 feet bgs at Borehole B-4. Additional thinner layers of non-cohesive sands

and silts were observed in shallower intervals in B-1 and B-2.

The applicant added that not all of these noncohesive soils are considered liquefiable for the

design considerations.

The staff reviewed the sample liquefaction analysis provided by the applicant for borehole B-1

to verify that the applicant used the method recommended by RG 1.198 for determining the

FOS against liquefaction. The applicant used the Youd (2001) procedure, which evaluates soil

strength against liquefaction based on SPT blowcount values and the induced cyclic stresses

based on earthquake PGA and magnitude values. The applicant evaluated three earthquakes

with magnitudes of 5.5, 6.5, and 8.0 and a constant PGA of 0.3g for each earthquake. The

applicant selected these three earthquake magnitudes based on its deaggregation of the PSHA

results for the controlling earthquakes for the ESP site. The M 5.5 earthquake represents a

local source mechanism, the M 6.5 earthquake represents an earthquake from the Wabash

Valley source zone, and the M 8.0 earthquake represents an earthquake from the New Madrid

seismic source zone. The applicant used a constant PGA value of 0.3g since this is the PPE

value it selected for the ESP site. The peak acceleration value of 0.3g exceeds the peak

acceleration value (at 100 Hz) of the ESP site SSE, which is 0.26g. For each of the threemagnitudes, some of the soil layers had FOSs less than 1.1. The applicant also varied the

peak acceleration values to determine the sensitivity of the calculated FOS to changes in

magnitude and peak acceleration. The applicant found that a reduction in PGA from 0.35 to

0.25 increases the FOS by approximately 50 percent for each depth interval. Based on its

review of the sample liquefaction analysis, the staff concludes that the applicant used the latest

empirical method and adequately varied the significant soil and seismic input parameters in

accordance with the guidance provided in RG 1.1 98. Therefore, the applicant's liquefaction

analyses are acceptable.

In addition to the applicant's sample liquefaction analysis, the staff also reviewed the applicant's

descriptions of potential soil improvement methods and its description of the extent of the

potentially liquefiable soils over the ESP site. From the applicant's above description, the staff

concludes that noncohesive soils are fairly extensive over the area of the ESP site.

Based on its review of SSAR Section 2.5.4.8 and the applicant's response to RAI 2.5.4-6,

described above, the staff concludes that the applicant has employed an acceptable

methodology to determine the liquefaction potential of the soil underlying the ESP site.

Because portions of the upper 60 ft of soil are susceptible to liquefaction, the applicant stated

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that these soils would be either removed or replaced or improved to reduce any liquefaction

potential. This is Permit Condition 6.

2.5.4.3.9 Earthquake Design Basis

SSAR Section 2.5.4.9 describes the performance-based approach used by the applicant to

determine the SSE. This approach is also described in SSAR Section 2.5.2.6 and in more

detail in Section 4.3 of SSAR Appendix B. Section 2.5.2.3.6 of this SER provides the staff's

evaluation of the SSE, including the performance-based approach.

2.5.4.3.10 Static Stability

SSAR Section 2.5.4.10 states that the applicant deferred the determination of static stability to

the COL. stage. The applicant stated that since it has not selected a nuclear power plant

design, it did not estimate the bearing capacity, settlement, or lateral earth pressures for the

ESP site. These analyses depend on factors such as building footprint size, depth of

embedment, and effective weight. The applicant did establish an ESP site characteristic value

for minimum static stability at 25 tsf. This value is based on the licensee's evaluation of static

stability for the CPS site and the assumption that similar-sized structures will be built on the

ESP site!. Bearing capacities in the CPS USAR range from about 40 to 60 tsf.

In RAI 2.5.4-3, the staff asked the applicant to provide further detail regarding the criteria that it

used to establish the minimum static bearing capacity of 25 tsf for the ESP site. In response to

RAI 2.5.4-3, the applicant stated that the methods used by the licensee for the calculation of -the

bearing capacities were conventional methods that assume a local shear failure condition. The

range in bearing capacity values for the Category I structures at the CPS site range from 39.9

to 60.6 tsf and correspond to CPS building foundation elevations ranging from 35 to 40 ft below

the ground surface. The applicant stated that during the construction of the CPS facility, the

soil was excavated to a depth of approximately 55 ft below the ground surface to remove soils

that could be compressible. The licensee then placed approximately 20 ft of highly compacted

granular backfill between the base of the excavation and the foundation level for the CPS

facility foundations. The values given by the licensee for the bearing capacity represent,

therefore, a condition in which the foundations were placed on approximately 20 ft of highly

compacted granular fill over the highly overconsolidated Illinoian till soil unit. The applicant

stated that the combination of depth below the ground surface and the heavily overconsolidated

state of the Illinoian till results in the high bearing capacities given in the CPS USAR.

Comparing the minimum bearing capacity value chosen by the applicant (25 tsf) with the lower

value in the range of bearing capacities for the CPS site (39.9) provides an FOS greater than

1.5.

Since, as the applicant points out, the minimum bearing capacity value established by the

applicant provides an FOS greater than 1.5 compared to the minimum calculated bearing

capacity fDr the CPS Category I structures, the staff finds that this value is appropriate as a

PPE for the ESP site. This finding is based on the applicant's commitment to excavate

approximately 55 ft below the ground surface and to backfill with highly compacted granular fill.

In addition, the average undrained shear strength of the Illinoian till must be similar to that

underlying the CPS site. The applicant stated that the actual foundation depth, size, and

shape, structure locations, and settlement limits "will be considered to confirm the final ultimate

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bearing capacity at COL." The need for the COL or CP applicant to perform a complete static

stability assessment (including bearing capacities, settlement analyses, and lateral load

assessment) andlto ensure that the-bearing capacities meet the minimum value of 25 tsf

comprises COL Action Item 2.5.4-7.

2.5.4.3.11 Design Criteria

SSAR Section 2.5.4.11 states that the design criteria for the ESP site Category I structures will

be established during the COL stage. Since the applicant has not selected a reactor design or

location within the ESP site, its deferral of a description of the design criteria to the COL stage

is acceptable to the staff. The need for the COL or CP applicant to describe the design criteria

and methods, including the FOSs from the design analyses, is COL Action Item 2.5.4-8.

2.5.4.3.12 Techniques to Improve Subsurface Conditions

SSAR Section 2.5.4.12 states that until the power generating system is selected, the need for

ground improvement for the ESP site is unknown. The applicant stated that structures that are

founded at depths of 55 ft or above could require ground improvement, and that "decisions

regarding the need for and type of ground improvement will be made during the COL stage."

Based on the applicant's liquefaction analyses, which showed that portions of the upper 60 ft of

soil are susceptible to liquefaction (FOS • 1.1), the staff considers the improvement (i.e.,

removal and replacement or compaction) of the upper 55 ft of soil beneath the ESP site to be

necessary. The improvement of the upper soil layers beneath the site will also be necessary to

ensure that the minimum bearing capacity value of 25 tsf is met. In addition, the licensee

encountered localized pockets of loose granular material at the base of the excavations for the

CPS Category I structures during construction at the CPS site. The licensee either compacted

these loose granular pockets of soil or removed and replaced them with backfill material. The

need to employ ground improvement for the ESP site is also discussed above in conjunction

with Permit Condition 6.

2.5.4.4 Conclusions

Based on its review of SSAR Section 2.5.4 and the applicant's responses to the associated

RAls and open item, the staff concludes that the applicant has adequately determined the

engineering properties of the soil and rock underlying the ESP site through its field and

laboratory investigations. In addition, the applicant used the latest field and laboratory

methods, in accordance with RGs 1.132, 1.138, and 1.198, to determine these properties.

Accordingly, the staff concludes that the applicant performed sufficient field investigations and

laboratory testing to determine the overall subsurface profile, the properties of the soil and rock

underlying the site, and the similarity between the CPS and ESP subsurface profiles and

properties. Specifically, the staff concludes that the applicant adequately determined (1) the

soil and rock dynamic properties through its field investigations and laboratory tests and (2) the

liquefaction potential of the soils. The applicant covered the response of the soil and rock to

dynamic loading in SSAR Section 2.5.2.

In SSAR Sections 2.5.4.5, 2.5.4.6, 2.5.4.10, 2.5.4.11, and 2.5.4.12, the applicant did not

provide sufficient information for the staff to perform a complete evaluation. In addition, the

applicant did not provide any information on the relationship of the foundation and underlying

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materials (Section 2.5.4.3 in RS-002). The staff reviewed SSAR Sections 2.5.4.13 and 2.5.4.14

as part of its review of SSAR Section 2.5.4.5. Each of these topics depends on specific

information related to building location and design and will be needed as part of any COL or CP

application.

In SSAIR Table 1.4-1, the applicant identified three subsurface material properties as ESP site

characteristic values. The first site characteristic specifies that there is no liquefaction below

60 ft below the ground surface. The applicant demonstrated, in SSAR Section 2.5.4.8, that any

liquefaction at the ESP site would be limited to the upper 60 ft of soil. SSAR Table 1.4-1 states

that "soils above 60 ft bgs to be replaced or improved"; however, in SSAR Section 2.5.4.12 the

applicant stated, "decisions regarding the need for and type of ground improvement will be

made during the COL stage." An unequivocal commitment by the applicant to improve or

replace and remove the soils above 60 ft below the ground surface is Permit Condition 6. The

second site characteristic value specifies a minimum bearing capacity of 25 tsf. This value i,

based cn the CPS site soil properties and not the ESP site properties, since the applicant

deferred the determination of bearing capacity values to the COL stage. Finally, the third

design parameter specifies minimum S-wave velocities for the three depth intervals 0-50 ft,

50-285 ft, and 285-310 ft as 820 ftls, 1090 ft/s, and 2580 ft/s, respectively. These S-wave

velocity values are based on the applicant's field geophysical surveys. The staff has reviewed

the applicant's suggested site characteristics related to SSAR Section 2.5.4 for inclusion in an

ESP, should the NRC issue one to the applicant. For the reasons set forth above, the staff

agrees with the applicant's site characteristics and the values for those characteristics.

2.5.5 Stability of Slopes

SSAR Section 2.5.5 describes the applicant's plans for future slope stability analyses. The

applicant did not carry out slope stability analyses for the ESP application.

2.5.5.1 Technical Information in the Application

The applicant stated that it did not perform a slope stability analysis for the ESP site application.

If a new intake structure into Clinton Lake is required for a future design, the applicant stated

that it would perform an additional assessment of the slope stability at the point of entry into the

lake. The applicant further stated that the slopes for the existing CPS Unit 2 facility are

approximately 30 ft deep and are located over 500 ft from the ESP site, and therefore do not

pose a hazard. In addition to slopes associated with the potential future intake structure, the

applicant stated that it will analyze the slopes associated with the construction of the power

block or the outfall at the COL stage. Currently, the foundation depth of the new generating

system is unknown, and the applicant stated that these depths are necessary to assess the

potential height of slopes required for construction.

The applicant stated that the starting point for future slope stability analyses will be the

information in the CPS USAR. The applicant stated that the licensee performed an extensive

evaluation of slope stability during design work for the CPS site. The licensee evaluated the

stability of the slopes associated with the Clinton Lake main dam and the CPS UHS under both

static and dynamic loading conditions. However, since the Clinton Lake dam is not considered

a Categoiy I structure, the licensee only evaluated the CPS UHS for the SSE ground motion.

The applicant concluded from its review of the CPS USAR that potential future issues

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associated with slope stability will not result in any unusual construction requirements or

constraints.

2.5.5.2 Regulatory Evaluation

SSAR Section 2.5.5 states that the applicant did not perform a slope stability analysis for the

ESP site application. As such, the applicant did not list any regulatory guidance or cite any

regulations as applicable to SSAR Section 2.5.5.

2.5.5.3 Technical Evaluation

In SSAR Section 2.5.5, the applicant provided a general description of its plan for future slope

stability analyses at the COL stage. Although the general description was useful to the staff in

performing a complete review, the COL or CP applicant will need to provide detailed slope

stability analyses. This is COL Action Item 2.5.5-1.

2.5.5.4 Conclusions

SSAR Section 2.5.5 states that the applicant will provide slope stability analyses at the COL

stage. As such, at this time the staff is unable to reach any conclusions regarding the stability

of slopes that have not been designed or constructed.

2.5.6 Embankments and Dams

SSAR Section 2.5.6 describes the applicant's assessment of (1) the Clinton Lake main dam

and the CPS UHS as they relate to a potential future nuclear facility on the ESP site and (2) the

potential for seismically induced floods and water waves.

2.5.6.1 Technical Information in the Application

2.5.6.1.1 Design of Main Dam and CPS Ultimate Heat Sink

SSAR Section 2.5.6.1, aDesign of Main Dam and CPS UHS," states that there are no plans to

modify or rely on the Clinton Lake main dam for emergency cooling water for potential future

nuclear facilities on the ESP site. The applicant stated that the ESP facility will use cooling

towers for cooling, with Clinton Lake being used to provide makeup water to the cooling towers.

Since the ESP facility will use the CPS UHS to supply makeup water to the cooling towers, the

applicant stated that it would perform evaluations (if appropriate) at the COL stage to assess

the performance of the submerged dam forming the UHS under the ESP SSE ground motion.

The applicant stated that the starting point for its COL assessment of the CPS UHS will be the

CPS USAR. SSAR Section 2.4.8, "Cooling Water Canals and Reservoirs," provides the main

description of the applicant's plans to use the CPS UHS to supply shutdown cooling water for

the existing CPS facility as well as makeup water to the ESP facility cooling towers.

2.5.6.1.2 Seismically Induced Floods and Water Waves

SSAR Section 2.5.6.2, "Seismically Induced Floods and Water Waves," describes the potential

for seismically induced floods and water waves. Since there are no dams located upstream of

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the ESP site and no large water-retaining structures in proximity to the existing facilities, the

applicant stated that the potential for seismically induced floods and water waves at the ESP

site is negligible. In addition, the applicant stated that the potential for flooding from a seiche is

also negligible because of the configuration of Clinton Lake and the relative elevation difference

between the lake and the plant site grade. The ground surface at the ESP site is at an

approximate elevation of 730 ft msI. In contrast, Clinton Lake is at an elevation of

approximately 690 ft. In addition, the ESP site is also about 800 ft from the shoreline of Clinton

Lake. The applicant stated that any seiche caused by an SSE would be too small to reach the

ESP site because of the distance (800 ft) and the height difference (40 ft). SSAR Section 2.4.5,

"Probable Maximum Surge and Seiche Flooding," provides additional discussion of the

maximum surge and seiche flooding.

2.5.6.2 Regulatory Evaluation

The applicant did not state which regulations SSAR Section 2.5.6 addressed; however, in

response to RAI 1.5-1, the applicant stated that it complied with all of the regulations listed in

RS-002. RS-002 does not contain a specific section on embankments and dams; however,

these topics are covered in RS-002 Sections 2.4.4 and 2.5.5. In SSAR Table 1.5-1, the

applicant stated that it used RG 1.70 for general guidance on format and content. Section 2.5.6

of RG 1.70 describes the necessary information and analysis related to the investigation,

engineering design, proposed construction, and performance of all embankments used for plant

flood protection or for impounding cooling water.

Since the applicant decided to defer the analyses of dam failure and slope stability until the

COL stage, the staff did not evaluate the regulatory compliance of SER Section 2.5.6. SER

Section :2.4.5 presents the staff's regulatory evaluation concerning the potential for seiche

flooding.

2.5.6.3 Technical Evaluation

SSAR Section 2.5.6 states that the ESP facility will use cooling towers for cooling, with Clinton

Lake being used to provide makeup water to the cooling towers. Since the ESP facility will use

the CPS UHS to supply makeup water to the cooling towers, the applicant stated that it would

perform evaluations (if appropriate) at the COL stage to assess the performance of the

submerged dam forming the UHS under the ESP SSE ground motion. The applicant's decision

to delay this evaluation until the COL stage is acceptable to the staff. This is COL Action

Item 2.5.6-1.

Concerning seismically induced floods and water waves, SSAR Section 2.5.6 states that since

there are no dams located upstream of the ESP site and no large water-retaining structures in

proximity to the existing facilities, the potential for seismically induced floods and water waves

at the ESP site is negligible. In addition, the applicant stated that the potential for flooding from

a seiche is also negligible because of the configuration of Clinton Lake and the relative

elevation difference between the lake and the plant site grade. Since the ground surface at the

ESP site is approximately 40 ft higher than Clinton Lake and about 800 ft from the shoreline of

Clinton Lake, the staff concurs with the applicant's conclusion that any seiche caused by an

SSE would be too small to reach the ESP site. SER Section 2.4.5 provides additional

evaluation of the potential for seiche flooding.

2-309
2.5.6.4 Conclusions

Sections 2.4.4, 2.4.5, and 2.5.5 of this SER present the staff's conclusions regarding dam

failures, seiche flooding, and slope stability, respectively.

2-310
3. SITE SAFETY ASSESSMENT

3.5.1.6 Aircraft Hazards

For an early site permit (ESP) application, the U. S. Nuclear Regulatory Commission (NRC)

staff reviews the applicant's assessment of aircraft hazards to verify that the risks due to such

hazards are sufficiently low for a new nuclear power plant that might be constructed on the

proposed site.

3.5.1.6.1 Technical Information in the Application

In Section 2.2.2.5 of the Site Safety Analysis Report (SSAR), Exelon Generation Company,

LLC (EG(C or the applicant) presents information on airports and airways that could affect the

design of systems, structures, and components important to the safety of a nuclear power plant

or plant; within the applicant's plant parameter envelope (PPE) that might be constructed on

the proposed ESP site. This information is evaluated in SSAR Section 2.2.2.5.3.

Four private airports and airstrips are located within 10 kilometers (6 miles) of the proposed

ESP site. The Spencer airport, owned by AmerGen and located 2 miles west-southwest of tVe

site, is riot operational. The remaining three airports or airstrips (Martin RLA Airport, Thorp

Airport, and Bakers Strip) can only accommodate small single- or twin-engine aircraft. The

Martin ALA Airport is about 4 miles south of the ESP site; the Thorp Airport is about 5 miles

northwest of the site; and Bakers Strip is about 5.5 miles southeast of the site. These airports

do not have commercial operations and are only available for public use in emergencies.

The closest public airports are the Central Illinois Regional Airport in Bloomington, about

23 miles north of the site; the Decatur Airport, about 23 miles south of the site; and the Rantoul

National Aviation Center Airport (Frank Elliott Field), about 37 miles east of the site. The SSAR

indicates that the Central Illinois Regional Airport and the Decatur Airport have scheduled

commercial flights and have more than 50,000 operations per year. The Rantoul Airport, which

does not have regularly scheduled commercial flights, has about 16,000 operations per year.

A detailed evaluation of potential hazards of airport flight operations was not necessary

because the number of flights per year associated with the above airports does not exceed the

threshold specified in Section 3.5.1.6 of NRC Review Standard (RS)-002, "Processing

Applications for Early Site Permits." Therefore, the applicant did not include a detailed

evaluation of the potential hazards of airport flight operations in the SSAR. However, the

Clinton Power Station (CPS) Update Safety Analysis Report (USAR) contains an evaluation cf

the hazards of operations at the Martin RLA and Thorp Airports.

The SSAR states that a heliport is located at CPS for use by company helicopters.

Four low-altitude airways pass near the site. These airways, which are used by aircraft flying

below 18,000 feet, are 8 nautical miles in width. The closest airway is V313, with a centerline

passing less than 2 miles east of the site. The centerline of V233 passes less than 3 miles

northwest of the site. The centerlines of V72 and V434 pass approximately 5 miles northeast of

the site and 6 miles north-northeast of the site, respectively.

3-1
The applicant did not provide traffic data for these airways. However, the CPS USAR contains

traffic estimates that were updated in November 2002 and have been extrapolated for a 40-year

period on the basis of Federal Aviation Administration (FAA) estimates of the increase in air

carrier operations between 1980 and 1992.

The airways are sufficiently close to the proposed site to require detailed evaluations of the

potential hazards. In response to the staff's Request for Additional Information (RAI) 2.2.2-2,

the applicant committed to revise SSAR Section 2.2.2.5.3 to provide detailed estimates of the

probability of aircraft impacts from these Federal airways. The SSAR states that these airways

are addressed in the CPS USAR and that the probability of an aircraft crash from these airways

is within the guidelines of Section 3.5.1.6 of NUREG-0800, "Standard Review Plan for the

Review of Safety Analysis Reports for Nuclear Power Plants" (also referred to as the SRP).

AmerGen updated the USAR evaluation in November 2002. The USAR analysis concludes that

the probability of an aircraft crash on the CPS site from flights along the four airways is

5.42x108 per year. In the SSAR, the applicant estimates that the allowable footprint for the

ESP safety-related facilities could be as large as 386,000 ft2 (about 0.014 mi2) without

exceeding the impact probability criterion of 1.Oxl 0-7' per year in RS-002. The applicant further

notes that the effective impact area computed for CPS is about 200,000 ft2 (about 0.01 mi2).

The SSAR does not discuss hazards associated with military training routes. The aviation

charts in SSAR Figure 2.2-3 do not show any military training routes near the proposed site.

3.5.1.6.2 Regulatory Evaluation

In RAI 1.5-1, the staff asked the applicant to provide a comprehensive list of NRC regulations

applicable to its ESP SSAR. In its response to RAI 1.5-1, the applicant stated that RS-002

identifies the NRC regulations applicable to its ESP SSAR. The staff considered the regulatory

requirements in Title 10 of the Code of Federal Regulations (10 CFR), Part 100, "Reactor Site

Criteria," Subpart B, [in particular, the requirements of 10 CFR 100.20(b) and 10 CFR

100.21 (e)], as identified in RS-002, Attachment 2, Section 3.5.1.6, in reviewing information

regarding aircraft hazards that could affect the safe design and siting of a nuclear power

plant(s) falling within the applicant's PPE that might be constructed at the proposed site. The

staff reviewed this portion of the application for conformance with the applicable regulations and

considered the corresponding regulatory guidance.

According to Section 3.5.1.6 of RS-002, the 10 CFR 100.20 requirement that individual and

societal risks of potential plant accidents be low is met if the probability of aircraft accidents

having the potential for radiological consequences greater than the exposure criteria in 10 CFR

50.34(a)(1) is less than about 1 x1i ' per year.

The probability is considered to be less than about 1x10` per year if the distances from the site

meet these three criteria:

(1) The site-to-airport distance, D, is between 5 and 10 statute miles and the projected

annual number of operations is less than 500 D2, or D is greater than 10 statute miles

and the projected annual number of operations is less than 1000 D2.

3-2
(2) The site is at least 5 statute miles from the edge of military training routes, including lowlevel training routes, except for routes used by more than 1000 flights per year or where

activities (such as practice bombing) may create an unusual stress situation.

(3) The site is at least 2 statute miles beyond the nearest edge of a Federal airway, holding

pattern, or approach pattern.

If these three proximity criteria are not met, or if sufficiently hazardous military activities are

identified, a detailed review of aircraft hazards should be performed. Section 3.5.1.6 of RS-002

provide;3 guidance on performing such reviews.

In SSAR Table 1.5-1, the applicant identifies the applicable NRC guidance on identifying and

evaluating aircraft hazards:

* RG 1.70, Revision 3, "Standard Format and Content of Safety Analysis Reports for

Nuclear Power Pants-LWR Edition"

* ASRP Section 3.5.1.6

* RS-002 Section 3.5.1.6

3.5.1.6.3 Technical Evaluation

The applicant identified three private airfields near the proposed ESP site. The SSAR

concludes that none of the fields has enough flight operations to require a detailed analysis of

the risk to a plant at the proposed ESP site based on a criterion in RG 1.70 similar to the first

criterion in the list above. This criterion only applies to the Thorp Airport and Bakers Strip. The

criterion does not apply to the Martin RLA Airport because the distance from that airport to the

ESP site is less than 5 miles.

The staff concurs with the applicant's conclusion that the hazards associated with Thorp Airport

and Bakers Strip do not require a detailed analysis because their distance from the site and the

number of annual operations at each airfield satisfy the first criterion.

The staff did an independent evaluation of the hazards associated with the Martin RLA Airpon:

because it is within 5 miles of the ESP site. Since Martin RLA Airport is a private airfield, the

staff finds it conservative to assume 500 general aviation operations per year from the facility.

The staff conservatively assumed an effective area of 0.02 mi2 for safety-related structures in

the ESP site powerblock footprint on the basis of Figure 2.1-4 of the environmental report

submittec with the ESP application and that 50 percent of the operations result in flights near

the proposed ESP site. Using the procedure set forth in Section 111.3(a) of Section 3.5.1.6 in

Attachment 2 to RS-002, the staff estimates that an aircraft from the Martin RLA Airport has a

probability of about 6x1 0-8 per year of impacting the ESP facility. This probability is lower than

the 10-7 threshold in the acceptance criteria in SRP Section 3.5.1.6. Thus, the staff concludes

that aircraft hazards associated with the Martin RLA Airport do not pose a significant risk to

facilities at the proposed ESP site. The staff has not identified any additional private airfields

within 16 kilometers (10 miles) of the site.

3-3
The applicant identified three public airports near the proposed ESP site and determined that

the number of operations at each airport was lower than in criterion 1 above. The staff did an

independent review of public airports in the vicinity of the proposed ESP site and identified

10 airports within 50 miles of the site. Table 3.5.1.6-1 below lists these airports, including the

three identified by the applicant. The table provides the distance from each airport to the

proposed ESP site, the number of operations per year, and a description of the distribution of

operations by aircraft type (the information on airport location and operations was obtained from

AirNav.com on November 16, 2004 at http://www.airnav.com/airports/us/IL). FAA information

regarding the site was updated on September 30, 2004. On the basis of the airport distances

from the airports to the site and the annual number of operations, these airports satisfy

criterion 1. Hence, hazards of operations at these airports near the proposed ESP site do not

pose a significant risk to safety-related structures that might be built at the site.

The applicant identifies four airways that pass near or over the proposed ESP site. The SSAR

does not present an analysis of the risks associated with the airways. Rather, it relies on the

CPS USAR analysis of the risk. AmerGen updated this analysis in November 2002. The USAR

analysis follows the guidance in SRP Section 3.5.1.6, which is similar to the guidance for the

review of ESP applications in RS-002. Using the results of the USAR analysis, the applicant

estimates that a safety-related structure of an ESP facility could have an effective footprint of

about 386,000 ft2 (about 0.014 mi2) and still meet the SRP criterion of about 10i7 per year.

The staff performed an independent assessment of the risks associated with the airways.

The staff assumed a powerblock footprint of 0.02 mi2 (on the basis of Figure 2.1-4 of the

environmental report submitted with the ESP application). The staff based its estimate of the

traffic along each airway in 2065 on the traffic estimates in the USAR and an annual growth

rate of 1.5 percent. This growth rate is slightly larger than the rate assumed in the USAR.

Table 3.5.1.6-2 lists the resulting risk estimates by airway, using the in-flight crash rate of

4x1 Q.'O per mile from RS-002. The total risk is estimated to be about 5.0x1 0.8 per year. This

estimate is about the same as the USAR risk estimate for a crash into the current CPS unit.

Because many aircraft using the low-altitude airways are small and the assumptions used in the

probability estimates are conservative, the staff concludes that the probability of an aircraft

crash on the ESP site having radiological consequences greater than the 10 CFR 50.34(a)(1)

criteria is less than 5.0x108.

3.5.1.6.4 Conclusions

The staff reviewed the applicant's aircraft hazard analysis using the procedures set forth in

RS-002, Section 3.5.1.6. As discussed above, the staff reviewed the applicant's assessment of

aircraft hazards at the site with a probability of less than about 1 07 per year for an accident

having the potential for radiological consequences greater than the exposure criteria in 10 CFR

50.34(a)(1). The staff also did independent analyses. Based on these analyses, the staff

concludes that aircraft hazards at the proposed ESP site pose no undue risk to the health and

safety of the public. Therefore, the staff concludes that, from the perspective of aircraft

hazards, the proposed site is acceptable for siting a plant or plants of the types specified by the

applicant. In addition, the site meets the relevant requirements of 10 CFR Part 52, "Early Site

Permits; Standard Design Certifications; and Combined Licenses for Nuclear Power Plants,"

and 10 CFR Part 100.

3-4
Table 3.5.1.6-1 Public Airports Near the Proposed ESP Site

Distance Reported

from ESP Operations

Airport Site (mi) Per Year Operations by Aircraft Type

Central Ilinois Regional 20 57,305 71 % general, 23% air taxi, 5% commercial

University of Illinois 31 129,575 91% general, 9% air taxi

Decatur 23 55,480 69% general, 15% air taxi, 12% military, 5% commuter

Piatt County 19 5,996 100% general

Abraham Lincoln Capital 50 66,795 70% general, 20% air taxi, 9% military

Rantoul 37 20,075 100% general

Frasca Field 34 14,965 90% general, 10% air taxi

Logan County 26 6,987 80% general, 19% air taxi, 1% military

Pekin 49 9,125 77% general, 22% air taxi

Paxton 42 4,015 95% general, 5% air taxi

Table 3.5.1.6-2 Probability of Aircraft Impacts from Federal Airways

Present Projected Width of

Distance to (2002) Traffic for Airway Plus

Airway Traffic 2065 Effective 2x Distance Probability

Centerline (Flights per (Flights per Footprint to Edge of of Impact

Airway (mi) Year) Year) Area (mi2) Airway (mi) (yr )(a)

V313 1.5 7,300 18,650

V233 2.0

6.0

7,300 18,650

0.02

0.02

0.02

0.02

V434 5,475 13,988

9,325

9.21 1.62x10-8

9.21 1.62x1 Q8

12.0 9.3x10-9

9.5 7.9x1 0-9

4.96x1 0-8

V72 4.75 3,650

Total

(a) Assuming an inf light crash probability of 4x1 0-'° per mile.

3-5
. . . .i ,

; . , -1

--

- iE i
11. RADIOLOGICAL EFFLUENT RELEASE DOSE CONSEQUENCES

FROM NORMAL OPERATIONS

11.1 Source Terms

The U.". Nuclear Regulatory Commission (NRC) staff reviewed the information on radiological

effluents and solid radioactive waste provided in Site Safety Analysis Report (SSAR)

Section 3.1 of the Exelon Generation Company, LLC (EGC or the applicant) early site permit

(ESP) application to determine whether site characteristics are such that the radiation dose to

members of the public would be within regulatory requirements.

11.1.1 Technical Information in the Application

The applicant provided information on the radioactive gaseous and liquid effluents and solid

radioactive waste material that would be generated as a normal byproduct of nuclear power

operations. These radioactive materials would be collected, processed, stored, and discharged

in a controlled manner to the local environment or transported offsite for long-term storage or

disposal. The facility to be built on the ESP site would have the ability to handle these

radiological effluents and solid waste material in a manner that minimized radioactive releases

to the environment and maintained exposure to the public and plant personnel during normal

plant operation and maintenance at levels that were as low as is reasonably achievable

(ALARA).

11.1.2 Regulatory Evaluation

NRC regulations require that applicants for an ESP address characteristics of the proposed site

that could affect the radiation dose to a member of the public from radiological effluents. In

Request for Additional Information (RAI) 1.5-1, the staff asked the applicant to provide a

comprehensive list of NRC regulations applicable to its ESP SSAR. In its response to

RAI 1.5-1, the applicant stated that SSAR Section 3.1 addresses radiological effluents in

accordance with Title 10 of the Code of Federal Regulations (10 CFR), Section 52.1 7(a)(1 )(ih).

Specifically, 10 CFR 52.17(a)(1)(iv) states that an ESP application should describe the

anticipated maximum levels of radiological effluents that each facility will produce. The staff

reviewed this portion of the application for conformance with the applicable regulations.

11.1.3 lechnical Evaluation

11.1.3.1 Gaseous Effluents

The gaseous waste management system would control, collect, process, store, and dispose of

radioactive gases during plant operation, including startup, normal operation, shutdown,

refueling, and anticipated operational occurrences. Routine radioactive gaseous effluents

would be released to the environment through the waste gas processing systems, which

minimize the releases to the environment. Radioactive gases that might be present in the plant

buildings as a result of leakage from systems would also be monitored and released through

the building ventilation systems. The release of radioactive gaseous effluents from the facility

would be controlled and monitored to be within the regulatory limits in 10 CFR Part 20,

"Standards for Protection Against Radiation," and maintained ALARA in accordance with

11-1
10 CFR Part 50, Appendix I, "Numerical Guides for Design Objectives and Limiting Conditions

for Operation to Meet the Criterion 'As Low as Is Reasonably Achievable' for Radioactive

Material 'in Light-Water-Cooled Nuclear Power Reactor Effluents."

The applicant estimated the bounding quantity of radioactive gaseous effluents that might be

released from the gaseous waste management and building ventilation systems. The applicant

determined the gaseous radioactive effluent concentrations based on a composite of the

highest activity content of the individual isotopes it anticipated would be released from the

alternative reactors designs under consideration.

The applicant also provided bounding gaseous effluent release data to support compliance with

the gaseous effluent release concentration limits in Table 2 of 10 CFR Part 20, Appendix B,

"Annual Limits on Intakes (ALls) and Derived Air Concentrations (DACs) of Radionuclides for

Occupational Exposure; Effluent Concentrations; Concentrations for Release to Sewerage."

The applicant calculated the estimated dose to a hypothetical maximally exposed member of

the public from the gaseous effluents, using radiological exposure models based on Regulatory

Guide (RG) 1.1 11, "Methods for Estimating Atmospheric Transport and Dispersion of Gaseous

Effluents in Routine Releases from Light-Water-Cooled Reactors," and the GASPAR II program

(NUREG/CR-4653, "GASPAR Il-Technical Reference and User Guide," March 1987). The

applicant evaluated several exposure pathways, including direct radiation from immersion in the

gaseous effluent cloud and from particulates deposited on the ground, inhalation of gases and

particulates, ingestion of milk contaminated through the grass-cow-milk pathway, and ingestion

of foods contaminated by gases and particulates.

11.1.3.2 Liquid Effluents

The liquid waste management system would control, collect, process, store, and dispose of

potentially radioactive liquids during plant operation, including startup, normal operation,

shutdown, refueling, and anticipated operational occurrences. The system would typically-be

operated in a manner that minimized the release of radioactivity into the environment. Normal

liquid effluents would discharge through the existing discharge of the Clinton Power Station

(CPS).

Currently, the CPS facility does not routinely discharge radioactive liquid wastes into Clinton

Lake. EGC stated that it would likely continue this practice with its ESP facility. However, to

provide operating flexibility, the applicant gave a bounding estimate to demonstrate its capability

to comply with the regulatory requirements in 10 CFR Part 20 and Appendix I to 10 CFR

Part 50.

The applicant provided the estimated bounding annual average quantity of radioactivity

projected to be released in Table 1.4-4 of the SSAR. This quantity represents the highest

activity content of the individual isotopes from the alternative reactor designs presented in

SSAR Section 1.4, "Plant Parameters Envelope," and would bound the activity of the isotopes

for any selected reactor design. SSAR Table 3.1-5 compares the projected liquid effluent

release concentrations to the 10 CFR Part 20 liquid effluent concentration limits. The data

shows that the bounding liquid effluent release concentrations are within the 10 CFR Part 20

effluent concentration limits.

11-2
The applicant estimated the dose to a hypothetical maximally exposed member of the public:

from the liquid effluents, using radiological exposure models based on RG 1.109, "Calculation

of Annual Doses to Man From Routine Releases of Reactor Effluents for the Purpose of

Evaluating Compliance with 10 CFR Part 50, Appendix I," and the LADTAP II program

(NUREG/CR-4013, "LADTAP Il-Technical Reference and User Guide," April 1986).

The appDlicant evaluated several exposure pathways, including eating fish or invertebrates

caught near the point of discharge, using the shoreline for activities (e.g., sunbathing or

fishing), and swimming and boating on the lake near the point of discharge.

11.1.3.3 Solid Waste

The solid waste management system of the EGC ESP facility would control, collect, handle,

process, package, and temporarily store the wet and dry solid radioactive waste materials

generated during normal plant operations before they are shipped offsite. The solid waste

materials might consist of wet waste sludge, dewatered resins, and contaminated solids suc,!

as cartridge filters, rags, paper, clothing, tools, and equipment. The applicant would

periodically ship solid radioactive waste material between the EGC ESP site and the permanent

waste dsposal facility.

The applicant estimated that it would ship an average of 15,087 ft3 of radioactive waste offsite

each year. The applicant estimated the maximum curie content of the shipped waste at

5100 curies. The waste would be packaged and shipped in accordance with the applicable

regulations in 10 CFR Part 71, 'Packaging and Transportation of Radioactive Material," and

49 CFR Part 173, "Shippers-General Requirements for Shipments and Packagings."

11.1.4 Conclusion

The applicant has provided adequate information to provide reasonable assurance that it would

control, monitor, and maintain radioactive gaseous and liquid effluents and solid waste from the

EGC ESP facility within the regulatory limits in 10 CFR Part 20, 10 CFR Part 71, and 49 CFR

Part 173 and maintain them at ALARA levels in accordance with the effluent design objectives

set forth in Appendix I to 10 CFR Part 50. A COL applicant that references an ESP for the EGC

ESP site should verify that the calculated radiological doses to members of the public from

radioactive gaseous and liquids effluents for any facility to be built on the EGC ESP site are

bounded by the radiological doses in the SSAR for the ESP application and reviewed by the

NRC staff as described above. This is COL Action Item 11.1-1.

11-3

13. CONDUCT OF OPERATIONS

13.3 Emergency Planning

The U.S. Nuclear Regulatory Commission (NRC) evaluates emergency plans for nuclear power

reactors to determine whether there is reasonable assurance that adequate protective

measures can and will be taken in the event of a radiological emergency. An early site permit

(ESP) application, pursuant to Title 10 of the Code of Federal Regulations (10 CFR),

Section 52.17(b), must identify any physical characteristics unique to the proposed site that

could pose a significant impediment to the development of emergency plans. The application

must also describe contacts and arrangements the applicant has made with Federal, State, and

local governmental agencies with emergency response planning responsibilities. In addition,

the application may propose major features of emergency plans, as described in Supplement 2

to Revision 1 of NUREG-0654/FEMA-REP-1, "Criteria for Preparation and Evaluation of

Radiological Emergency Response Plans and Preparedness in Support of Nuclear Power

Plants--Criteria for Emergency Planning in an Early Site Permit Application-Draft Report for

Comment" (hereafter referred to as Supplement 2), issued April 1996, or may propose

complete and integrated emergency plans.

The Exelon Generation Company, LLC (EGC or the applicant), ESP application includes the

"Emergency Plan for the Exelon Generation Company, LLC Early Site Permit" (hereafter

referred to as the EGC ESP Emergency Plan), that addresses the major features option

allowed for ESP applications under 10 CFR 52.17(b)(2)(i). Because the proposed ESP site

footprint consists of a portion of the existing Clinton Power Station (CPS) facility, and is located

immediately adjacent to CPS, very little distinction exists between the CPS site and the ESP

site for purposes of emergency response planning.

The staff, in consultation with the Federal Emergency Management Agency (FEMA), has

reviewed the applicant's proposed EGC ESP Emergency Plan, Volume I of the Illinois Plan for

Radiological Accidents (IPRA) dated May 2001, Volume VilI of the IPRA dated July 2003, and

responses to requests for additional information (RAls), in accordance with NRC Review

Standard (RS)-002, "Processing Applications for Early Site Permits," issued in May 2004.

In RAI 1:3.3-2, the staff requested copies of the versions of the State and local emergency plans

that EGC refers to in the application. On December 15, 2004, the applicant provided copies of

the State and local plans in response to RAI 13.3-2. However, EGC provided a more recent

version of IPRA Volume Vil than referenced in its application. The applicant also provided a

summary of the changes to IPRA Volume Vil in the more recent version. The staff was unable

to complete its review of this information before preparation of the draft safety evaluation report

(DSER). Therefore, the staff characterized its review and acceptance of the information the

applicant provided on December 15, 2004, in response to RAI 13.3-2, as Confirmatory

Item 13.3-1. The staff reviewed the summary of the changes to IPRA Volume Vill in the

applicant's letter dated December 15, 2004, and determined that it did not affect this SER. The

staff also determined that the application was updated to reference the current version of IPRA

Volume \'lIl (2003). Therefore, the staff considers Confirmatory Item 13.3-1 to be resolved.

Because the applicant elected to present and seek NRC acceptance of the major features of

emergency plans, the staff's evaluation addresses, in order, the three aspects of such a

13-1
submission. The following identifies each aspect and the section of this safety evaluation report

(SER) that is discussed:

(1) identification of physical characteristics that could pose a significant impediment to the

development of emergency plans (SER Section 13.3.1)

(2) description of contacts and arrangements made with Federal, State, and local

governmental agencies with emergency planning responsibilities (SER Section 13.3.2)

(3) proposed major features of the emergency plans (SER Section 13.3.3)

The applicant identified 10 CFR Part 50, "Domestic Licensing of Production and Utilization

Facilities," as applicable to the major features it proposed. Appendix E, "Emergency Planning

and Preparedness for Production and Utilization Facilities," to 10 CFR Part 50, however, applies

to the "major features" option of 10 CFR 52.17(b)(2) only to the extent that it requires a

description of the "essential elements of advance planning that have been considered" (see

Section IlIl of Appendix E to 10 CFR Part 50). The staff approved the applicant's identification

of 10 CFR Part 50 as one of the regulatory requirements applicable to the staff's review of the

major features proposed by the applicant. The staff's findings are set forth throughout

Section 13.3.3 of this SER and are limited to those particular portions of Appendix E to 10 CFR

Part 50 that the staff considered during the course of its review of a particular major feature.

More importantly, any staff finding that a proposed major feature complies with a particular

requirement of Appendix E to 10 CFR Part 50 is limited to the description of the major feature

approved by the staff in this SER.

Notwithstanding any staff approval of a proposed major feature in this SER, all features of the

emergency plan requiring a description pursuant to Appendix E to 10 CFR Part 50, but that are

not described in the ESP application, will be reviewed in the context of a combined license

(COL) or operating license (OL) application. The staff will review complete and integrated

emergency plans submitted in a COL or OL application to determine whether they comply with

such requirements, as well as the requirements of 10 CFR 50.47, "Emergency Plans."

The staff's evaluation of the proposed major features of the applicant's emergency plans

parallels the major features and planning standards in Supplement 2.

13.3.1 Significant Impediments to the Development of Emergency Plans

13.3.1.1 Technical Information in the Application

In Section 2.3, "Evacuation Time Estimate Analysis," of the EGC ESP Emergency Plan, the

applicant stated that the evacuation time estimate' (ETE) performed in 1993 for the CPS plume

exposure pathway served as the basis for the ETE analysis supporting its ESP application. The

applicant further stated that the 1993 ETE assesses the relative feasibility of an evacuation for

the 10-mile (mi) emergency planning zone (EPZ) plume exposure pathway. The applicant

evaluated the assumptions that served as the basis for the 1993 ETE; Section 2.3.1,

'"Evaluation Time Estimates for the Clinton Power Station," July 1993.

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"Assurmptions," of the EGC ESP Emergency Plan lists these assumptions. The applicant

found that these assumptions remain valid for the area surrounding the ESP site.

Sections 2.2, "Summary of Methodology," and 5.5, "Evacuation Simulation," of the 1993 ETE

describe the methodology used, including the NETVAC computer simulation model. This model

has many features that enable a reasonably sophisticated modeling of the road network, the!

use of evacuation preparation and departure time distributions, and the use of population and

vehicle demand distribution data to simulate a variety of evacuation scenarios.

The 1993 ETE identifies the worst-case ETE for the entire EPZ as a summer weekday, with an

ETE of .200 minutes for fair weather and 255 minutes for adverse weather. The Apple and Pork

Festival on summer weekends results in an ETE of 380 minutes for fair weather and

530 minutes for adverse weather.

Volumes I and Vill of the IPRA reference the 1993 ETE in the "Planning Standards and

Evaluation Criteria Correlation Document" for each volume. The 1993 ETE uses 1990

population data. An assessment of changes in population, using the 2000 census data, was

conducted in 2003 in the "Phase One Report-Assessment of Changes within the Emergency

Planning Zone for Clinton Nuclear Generating Station," issued in December 2003 (hereafter

referred to as the Phase One Report). In RAI 13.3-15, the staff asked whether the information

contained in the Phase One Report documenting the assessment of population changes in the

plume exposure pathway EPZ should be considered as an update to the 1993 ETE. In

response to RAI 13.3-15, the applicant stated that it did not use the Phase One Report in the

preparation of the EGC ESP Emergency Plan and that it need not be referenced or considered

because Section 2.3.3, "Analysis-Comparison of Infrastructure and Population," of the EGC

ESP Emergency Plan independently develops and describes the report's conclusions.

Section :2.2.1, "Plume Exposure Pathway Emergency Planning Zone," of the EGC ESP

Emergency Plan states that the EGC ESP site EPZ boundary is identical to the CPS EPZ, that

is within approximately a 10-mile radius of the ESP site. Figure 2.1 -1, "ESP EPZ with Radial

Grid," of the EGC ESP Emergency Plan illustrates the radial boundary of the ESP site plume

exposure pathway EPZ. The figure also shows transportation networks, topographical

features, and political boundaries. Figure 2.2-1, "ESP EPZ Subareas, Evacuation Routes,

and Relocation Centers," of the EGC ESP Emergency Plan delineates the actual EPZ,

superimposed on the 10-mile radial grid, along with evacuation routes, subareas, and relocation

centers.

In RAI 1 v .3-17, even though some extrapolated population data have been provided for the

addition of two reactors at the Clinton site and refueling outages, the staff asked the applicant

to provide additional extrapolated population data for the next 20 years (i.e., the life of the ES?

application) and discuss their impact on ETEs. In response to RAI 13.3-17, the applicant stated

that Section 2.1, "Geography and Demography," of the EGC ESP Site Safety Analysis Report

discusses the population data extrapolated for 60 years (i.e., the life of the ESP plus the life of

the operating license). The applicant further stated that the extrapolated population results do

not represent a significant change from those considered in the 1993 ETE; therefore, the

applicant expects minimal impact.

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Section 2.3.2, "Population Data," of the EGC ESP Emergency Plan estimates the number of

people within the 10-mile EPZ who would require evacuation. The applicant developed

population estimates for the number of permanent residents within the 10-mile EPZ from 2000

U.S. Census Bureau data; Table 2.1-1, "Census 2000 Demographics within 10 Miles of the

Clinton Power Station in 1-mi Bands by Radial Grid Sector," and Figure 2.3-2, "ESP EPZ

Permanent Population by Radial Grid Sector," in the EGC ESP Emergency Plan provide these

data. The applicant derived the seasonal resident population from the 2000 U.S. Census

Bureau data category, "Vacant Housing for Seasonal, Recreational or Occasional Use." In

Section 2.3.2.2, "Seasonal Population," of the EGC ESP Emergency Plan, the applicant stated

that it multiplied the value in Table 2.3-1, "Census 2000 Demographics Data within 10 miles of

the Clinton Power Station by Radial Grid Sector," by the previously accepted household

occupancy rate of 3, resulting in a total seasonal population of the 10-mile EPZ of 105.

Section 2.3.2.3, "Transient Population," of the EGC ESP Emergency Plan addresses the

population estimates for transient facilities (e.g., hotels/motels, major employers, visitors to

recreational areas). Tables 2.3-2, "2002 Transient Population," and 2.3-3, "Estimated EPZ Size

Transient Population," referenced in Section 2.3.2.3 of the EGC ESP Emergency Plan, also

provide transient population data. Table 3.11, "Clinton EPZ Population by Subareas: All

Conditions," in the 1993 ETE provides similar tabulations of data based on the 1990 census.

The 1993 ETE and the ESP application consider the Apple and Pork Festival, that is a special

event when the total summer weekend transient population increases to 65,676 persons. The

auto occupancy factor for transients depends on whether they are at campsites or are

employees. Section 2.1, "Sources of Data and General Assumptions," of the 1993 ETE

provides these data.

The applicant stated in Section 2.3.2.3 of the EGC ESP Emergency Plan that it developed the

estimates from 2002 survey data and that the DeWitt County Emergency Services and Disaster

Agency (ESDA) coordinator verified them. Section 2.3.2.3 also states that the transient

population statistics include migrant farm workers because of the nature of the farming in the

region. This section of the EGC ESP Emergency Plan also discusses the CPS site population.

To evaluate the significant impediments to the development of an emergency plan, the

applicant used the sequence of constructing and operating dual AP1000 units on the site.

Section 2.3.2.3.1, "Special Population," of the EGC ESP Emergency Plan addresses special

populations. Table 2.3-4, "2002 Special Population in 10-mile EPZ," in Section 2.3.2.3.1 of the

EGC ESP Emergency Plan presents the special population estimates for the four seasons and

the weekday or weekend scenarios. The applicant developed the population estimates for

special facilities (schools, hospitals, nursing homes, and correction facilities) from 2002 survey

data, and the DeWitt County ESDA coordinator verified them. The 1993 ETE provides similar

data tabulations in Table 3.11.

Section 2.3.3 of the EGC ESP Emergency Plan describes the analysis to test the current

validity of the 1993 ETE conclusions. The applicant drew the following conclusions from its

analysis:

The infrastructure baseline used in the 1993 ETE has not changed and, therefore, does

not impact the conclusions of estimated evacuation time.

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* The permanent and seasonal population increase is considered negligible and has no

negative impact on the 1993 ETE.

* *The resulting special population increase of 26 individuals has no negative impact on

the estimate for evacuation time.

* The total population estimate for the limiting summer weekday case has not changed

significantly and, therefore, has no negative impact on the ETE.

* The population and its distribution have not changed significantly; therefore, the

modeling of vehicle entry into the roadway network has not changed. With no changes

to the roadway network and no significant changes to the total population, there is no

impact on the 1993 ETE and the conclusions of that analysis remain valid.

Section 2.3.4, "Analysis-Special Event," of the EGC ESP Emergency Plan describes the

analysis of the ETE for the annual Apple and Pork Festival. The applicant concluded that the

evacuation times for fair and adverse weather contained in the 1993 ETE remain valid.

The ETE analysis in Section 2.3 of the EGC ESP Emergency Plan assesses the relative

feasibility of an evacuation for the 10-mile plume exposure pathway EPZ. The applicant based

the evacuation times on a detailed consideration of the plume exposure pathway EPZ roadway

network and population distribution. The information in Table 2.3-5, "Evacuation Time

Estimates," of the EGC ESP Emergency Plan details representative evacuation times for

daytime and nighttime scenarios under fair and adverse weather conditions for the evacuation

of various areas within the EPZ (once a decision has been made to evacuate). In Section 2.3.1

of the EGiC ESP Emergency Plan, the applicant described adverse weather as sudden

rainstorms that would reduce effective roadway capacity by 20 percent for summer conditions

and snowstorms that would reduce roadway capacity by 30 percent for winter conditions. The

evacuation times noted include notification, mobilization, and travel time for the general

population, including the permanent population and special facilities (e.g., schools, nursing

homes, hospitals, and recreational areas).

The 1993; ETE for the CPS plume exposure pathway EPZ served as the basis for the ETE

analysis supporting the application. The applicant evaluated the assumptions listed in

Section 2.3.1 of the EGC ESP Emergency Plan and found that they remain valid for the area

surrounding the ESP site. The applicant further stated in Section 2.3.1 that the preparation and

mobilization times developed for each population component (i.e., permanent residents,

seasonal residents, transient, and special facilities) in the 1993 ETE analysis are reasonable.

Section 2.3.3 of the EGC ESP Emergency Plan compares the road and highway infrastructure

that was the basis of the links and nodes input to the NETVAC program employed in the 199.;

ETE to the current infrastructure. This analysis also compares a geographic information

system (GIS) plot of roads and highways, based on data obtained from the 2000 census

TIGER/Line Files, to the plume exposure pathway EPZ blue-line drawing and the written

description of the 1993 ETE. The applicant took three approaches in this infrastructure

comparison. In the first approach, the applicant evaluated EPZ zones defined by 22.5-degree

sectors arid 1-mile incremental radii overlaying the current GIS plot by comparing them to the

similar zones on the blue-line drawing. This comparison revealed no differences in the

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infrastructure, although there were slight differences in the overlay locations resulting from

differences in the accuracy of the GIS data versus the 1993 drawing. In the second approach,

that occurred in May.2002, the applicant drove the principal roadways described in the 1993

ETE. The verification of roadways included the links and nodes shown in Figure 2.1-1 of the

EGC ESP Emergency Plan. In the third approach, the applicant directly compared the link

evacuation routes, 901-905 and 801-815, to nodes 1-75 indicated on the drawing and the GIS

plot. The applicant noted no differences. Regarding the second approach (i.e., the May 2002

drive of the principal roadways), the staff requested, in RAI 13.3-20(f), that the applicant

discuss any road changes identified, including new or changed access points, roadway

conditions, and roadway constrictions that could reduce the capacity of sections of the route. In

response to RAI 13.3-20(f), the applicant stated that a verification of roadways was indeed

performed in May of 2002 as part of a validity test of the 1993 ETE conclusions and that it

noted no differences.

In RAI 13.3-20(a), the staff asked the applicant to discuss its rationale for excluding shadow or

voluntary evacuation in the 1993 ETE. In response to RAI 13.3-20(a), the applicant stated that

the 1993 ETE study for CPS did not address shadow or voluntary evacuation because the

population density in the area within 1 to 2 miles outside of the EPZ boundaries is very sparse.

The largest communities located along primary evacuation routes and within a few miles

outside of the EPZ are Maroa, located along State Route 51 south of the EPZ, and Heyworth,

located along State Route 51 north of the EPZ. The 2000 census stated the population of

Maroa City as only 1654 (651 households), and the population of Heyworth Village as only 2431

(897 households). The ETE simulations indicate that Route 51 has the capacity to accept

-traffic from these communities, in addition to the traffic evacuating from the EPZ. Voluntary

evacuation of the entire resident population from Maroa City would contribute only about

325 vehicles per hour, while voluntary evacuation of the entire resident population from

Heyworth would contribute about 450 vehicles per hour. Route 51 and the other roadways

serving these communities could accommodate these traffic volumes, without interfering with

traffic evacuating from the EPZ. The evacuation simulations do not indicate any expected

congestion on Route 51, proceeding north or south from Clinton, for any of the evacuation

scenarios. The conditions that control the predicted evacuation times reflect local congestion

on roadways within the city of Clinton. The applicant's responses to RAI 13.3-20(u) and (v)

provide more details concerning predicted traffic flow.

The 1993 ETE states that the road network was obtained by a field survey in 1984 and verified

through discussions with the Illinois Power Company, as discussed in Section 2.1 of the 1993

ETE. Section 2.3, "Conditions Modeled," of the 1993 ETE states that the county agency

officials agreed that no significant changes to the EPZ roadway network had occurred since

1984. This section also states that the roadways are unchanged and that no major construction

projects are planned.

Section 2.1 of the 1993 ETE provides the assumptions used for vehicle occupancy rates.

Permanent resident rates in the 1993 ETE are based on the 1990 census average household

occupancy rates. Seasonal resident rates are based on the average seasonal resident

household size as reported in the 1990 census data. Transient population rates in the 1993

ETE are based on the peak occupancy of recreational and hotel/motel facilities within the EPZ

(as determined by a telephone survey). The vehicle occupancy rates are (1) major places for

employment-i vehicle per employee, except the rate for CPS, that is 1.5 people per vehicle,

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(2) recreation areas-1 vehicle per campsite and 3 people per vehicle for all other areas,

(3) students-60 persons per bus, and (4) hospitals/nursing homes/correctional

facilities-40 people per bus.

Section 2.1 of the 1993 ETE also contains the assumptions for adverse weather conditions.

The applicant analyzed sudden rainstorms that would reduce roadway capacity by 20 percent

for sumner conditions and snowstorms that would reduce capacity by 30 percent for winter

conditions. The reductions in capacity and speed in Section 2.3 of the ETE analysis are

consistent with the Highway Capacity Manual; however, the difference in the ETE for the winter

weeknight adverse and the normal conditions (Table 6.2, "Evacuation Time Estimate Summary,

Winter Weeknight") is almost negligible, with no difference in many instances and a 5-minute

difference for evacuation of the entire EPZ. In RAI 13.3.20(h), the staff asked the applicant t:o

discuss the reason for the almost negligible difference in the ETE for the evacuation of the

entire plume exposure pathway EPZ for the winter weeknight adverse conditions and the

normal conditions described in the 1993 ETE analysis. In response to RAI 13.3-20(h), the

applicant stated that winter weeknight scenarios have the lowest vehicle demand and the

shortest ETEs. The relatively short evacuation times for the winter weeknight scenarios

(180 minutes for normal weather, 185 minutes for adverse weather) indicate that NETVAC

predicts few delays from traffic congestion. Based on a review of the simulation results, the

primary controlling factor that determines the ETEs for these two cases is intersection capacity

at a few locations in the city of Clinton. The primary effect of adverse weather on NETVAC

simulations is to reduce roadway capacity and travel speeds; intersection capacity is largely

unaffected. Since the number of vehicles is identical for "normal" and "adverse" weather

conditions, the time for traffic to clear the critical intersections is the same for both cases. The

small difference in ETEs reflects the travel time from Clinton to the EPZ boundaries. The travel

distance is roughly 4 miles; at 30 miles per hour (mph), this requires 8 minutes, while at

21 mph, it takes about 12 minutes.

The 199:3 ETE provides the time distributions for the evacuation components for the transient

and special populations. For school children, the 1993 ETE assumes that it could take up to

1 hour to assemble buses. School buses are loaded into the evacuation network within

30-90 minutes following the decision to evacuate. Some buses are assumed to be located at

the school.

For hospitals, nursing homes, and correctional facilities, the 1993 ETE uses data from other,

nonsite-specific studies to arrive at the assumption that these facilities would commenceevacuation between 1 to 2 hours after the 15-minute notification. In RAI 13.3-20(b), the staff

asked the applicant to provide site-specific data for those hospitals, nursing homes, and I

correctional facilities addressed in the 1993 ETE or to describe the other studies that it used to

arrive at ihis assumption. In response to RAI 13.3-20(b), dated January 24, 2005, the applicant

stated that the departure time distribution used in the 1993 ETE study for the special facilities

(including hospitals, nursing homes, and correctional facilities) was formulated with departures

following the decision to evacuate as indicated in the revisions to Attachment A, "Analysis of

Special Facility Evacuation Times," and Table 1, "Evacuation Time Estimates for Special

Facilities in EPZ for Clinton Station." The 1993 ETE study was based on information obtained

from individual facilities and from county emergency management officials responsible for

coordinating transportation resources for transport-dependent residents and special facilities.

The applicant reviewed these assumptions with the Illinois Emergency Management Agency

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(IEMA) and the responsible county agencies before performing the ETE analysis. For the

evacuation simulations, the goal is to estimate evacuation times for the entire evacuating

population, including special facilities. -The evacuation model, NETVAC, does not distinguish

among vehicles originating from different nodes or facilities, and the evacuation model design

does not allow a different departure time distribution to be specified for each facility. Analysis

for individual facilities is generally a manual effort, utilizing the evacuation model results to

estimate travel times along specific routes. The applicant's response to RAI 13.3-20(c)

described below provides additional information.

The 1993 ETE analysis for the total population, provided in Tables 6.1 through 6.4, "Evacuation

Time Estimate Summary: Winter Weekday, Winter Weeknight, Summer Weekday, and

Summer Weekend," for the season of year and weather scenarios, includes the ETE for special

facilities/population. In RAI 13.3-20(c), the staff asked the applicant to provide a separate

analysis of the ETE for special populations for normal and adverse conditions. In response to

RAI 13.3-20(c), the applicant provided an analysis of ETEs for individual special facilities in

Attachment A, "Analysis of Special Facility Evacuation Times," to its letter to the NRC dated

January 24, 2005.

Sections 3.1.2, 'Transport-Dependent Permanent Population" and 5.3, "Transportation

Dependent Population," of the 1993 ETE analysis characterize the nonauto-owning population

as contributing one vehicle per household, that neighbors or State/local authorities would

provide. In RAI 13.3-20(d), the staff asked the applicant to provide the following information:

* the basis for the assumption that neighbors and State/local authorities would contribute

one vehicle per household for the transport-dependent (nonauto-owning) population, as

described in the 1993 ETE study

* site-specific data regarding the number of nonauto-owning households within the plume

exposure pathway EPZ

* the methodology for determining the transport-dependent population

* an estimate of the number of auto-owning residents versus transport-dependent

residents

* the initiation/mobilization time distribution for the transport-dependent population

* a separate estimate of the time required to evacuate the transport-dependent population

In response to RAI 13.3-20(d), the applicant stated in its letter to the NRC dated January 24,

2005, that Table B-1, "Estimates of Transport-Dependent Population in Clinton Station EPZ,"

and Attachment B, "Transport-Dependent Population," to the letter provide estimates of the

number of transport-dependent households by subarea for the EPZ. These data indicate that

the large majority of transport-dependent households (259 out of 302) are located in the city of

Clinton (subarea 7). However, a footnote was added to revised Table B-1 in the letter dated

October 27, 2005, that states that the total of subareas 1-8 is only 301 due to round-off of the

subarea values to whole numbers. The 2000 census (SF-3) tabulates the number of vehicles

per household; transport-dependent households were estimated on the reported number of

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occupied households with no vehicles. The DeWitt County ESDA indicates that the transportdependent residential population within the city of Clinton will evacuate via buses provided by

the city, in addition to assistance from auto-owning residents (generally neighbors or relatives).

The buses will evacuate residents from a designated set of pickup locations in the city. The

buses will evacuate residents from Clinton to the reception center in Decatur, Illinois. According

to ESDA, the number of buses available should be able to evacuate transport-dependent

residents in a single pass. If residents arrive at pickup points after the buses have departed,

one or more buses will return to Clinton to evacuate any remaining residents. It is assumed

that the small number of transport-dependent residents in other subareas will evacuate with

assistance from neighbors or relatives. For the 1993 ETE study, one vehicle per household

was assigned for the entire residential population, including transport-dependent households.

The analysis in the 1993 study assumed the distribution of mobilization times for the transportdependent population to be the same as for the general residential population. The ETEs for

the general population in Clinton are, therefore, considered representative (or conservative) for

transport-dependent residents.

Section 2.3 of the 1993 ETE provides the methodology for determining the number of vehicles

and the auto occupancy rates for the different population groups based primarily on studies

done elsewhere.

Section 4.0, "The Evacuation Roadway Network,' and Appendix 3, "Roadway Network Listings

and Capacities from NETVAC," to the 1993 ETE provide a description of the road network, a

printout of the network characteristics, and the roadway network listing and capacities. In

RAI 13.3-20(e), the staff asked the applicant to clarify whether the 1993 ETE analyzed the

characteristics of each segment for the narrowest section or bottleneck of nonuniform

roadways. In response to RAI 13.3-20(e), the applicant stated that when roadway conditions

are not uniform over the length of a link, roadway dimensions (e.g., lane width, side width)

represent the most restrictive conditions over the link. In general, multiple links are used when

a significant change in roadway conditions is encountered (e.g., change in lane width, addition

or deletion of lane, change in speed limit).

Section 5.4, "Evacuation Preparation Times and Departure Distributions," of the 1993 ETE

analysis discusses the time distributions used for the different population types. The time

distribution for the permanent resident population did not use site-specific data. Instead, the

applicant used data from other studies to arrive at the notification and preparation time

distribution. Figure 5.1, "Notification/Preparation/Mobilization Time Distributions," provides th s

distribution, that assumes that no one begins evacuation for the first 30 minutes (i.e., during tie

notification period). The permanent resident population time distribution for mobilization and

preparation for evacuation spans a period of 2 hours.

Section 6.1, "Evacuation Time Estimate Summary," of the 1993 ETE analysis describes the

locations where queuing is likely to occur under the various scenarios. Sections 7.2,

"Evacuation Traffic and Access Control Locations," and 7.3, "Evacuation Traffic Management

Locations and Other Potential Mitigating Measures," of the 1993 ETE analysis describe the

locations identified in the NETVAC simulation that may require traffic management personnel

during the evacuation. Section 7.2 includes traffic management at locations warranted by

vehicle queuing and delays. The applicant used the NETVAC model results to identify these

locations. In RAI 13.3-20(g), the staff asked the applicant to discuss how the NETVAC model

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accounts for traffic control or whether the ETE would be reduced if these traffic control

measures were implemented. The staff also asked the applicant to clarify whether existing

traffic control devices would prevail during an evacuation or if emergency personnel would staff

traffic control points. In response to RAI 13.3-20(g), the applicant stated that the NETVAC

evacuation model has two operating modes. The first of these modes assumes traffic flow at

intersections consistent with existing traffic controls (signals operating on normal cycles, stop

signs observed), while the second mode assumes that those controls would be overridden by

emergency personnel, who would then direct traffic at designated control points to optimize the

flow of evacuating vehicles. The decision on what mode to use for a given ETE study is based

on discussions with emergency response agencies responsible for managing the evacuation. If

the agencies indicate that plans call for emergency personnel to override existing traffic

controls, then NETVAC is run in the 'override" mode. If plans call for emergency personnel to

manage traffic flow, while existing controls remain in operation, then NETVAC is run in "normal"

mode. For the 1993 study, the NETVAC model was run assuming existing traffic controls would

remain in place.

Table 4.1, "Primary Evacuation Routes by Township/Incorporated Area," of the 1993 ETE

analysis provides a map of the roadwork in the EPZ. Section 6.1 of the 1993 ETE identifies and

discusses road intersections with the potential for delays (queuing) during evacuation. The

main access road from CPS to Route 54 is one of the roadways that could experience queuing

under both fair and adverse weather conditions for all cases. This delay affects the ETEs for all

evacuation scenarios because it originates within the 0-2-mile ring included in all evacuation

scenarios.

The 1993 ETE considers a variety of factors necessary for ETEs. For example, Section 6.2,

"Apple and Pork Festival," addresses the Apple and Pork Festival, that brings nearly

50,000 transients to the township of Clinton. In RAI 13.3-20(i), the staff asked the applicant for

the following information:

* the basis for the assumption that 50,000 people, in 16,500 additional vehicles, will enter

the evacuation route during the Apple and Pork Festival

* the dependency of the people attending the festival on public transportation to get to

their vehicles (if park-and-ride shuttles are used during the event)

* whether any of these vehicles would return home to pack or pick up relatives before

evacuating the plume exposure pathway EPZ

* the estimated time to mobilize from the festival to start of the evacuation

* trip generation times for this event

In response to RAI 13.3-20(i), the applicant stated that the correct numbers for the 1993 ETE

study are 50,000 people in 16,667 vehicles (3 persons per vehicle). For the Apple and Pork

Festival scenario, this population is separate from (in addition to) the residential population.

Consequently, the applicant assumed that these vehicles would depart directly from the Apple

and Pork Festival and exit the EPZ. (This obviously represents a substantial amount of double13-10
counting.) Vehicles departing from the festival were assigned to eight departure nodes in the

city of Clinton.

The assigned distribution of departure times for vehicles from the Apple and Pork Festival

was 30 to 60 minutes, the standard time distribution used for recreation activities. As a

practical matter, however, the NETVAC simulations indicate that it would take more than

3 hours for the local roadway network to absorb this many vehicles, regardless of the assigned

distribution of departure times. (At the assigned entry nodes, "spillback" conditions persist for

more than 3 hours.) According to local officials, the park-and-ride shuttles can move up to

20,000 people per hour to remote parking areas, or 50,000 people in 2.5 hours. Local officials

were unable to provide a breakdown of festival attendance based on location of residence.

Since the population residing inside the EPZ is only 13,268, the large majority of the 50,000

attending the festival must reside outside of the EPZ. If the scenario were revised to account

for residents returning home from the festival, before evacuating the EPZ, this would lengthen

the departure times for the residential population, but it would also reduce the number of

vehicles evacuating directly from Clinton, thereby reducing the total number of evacuating

vehicles. In RAI 13.3-200), the staff asked the applicant to discuss the basis for the population

estimatEl of 22,000 people per day for the festival used in Section 2.3.4 of the EGC ESP

Emergency Plan, since the 1993 ETE study adds 50,000 people to the transient population for

the Apple and Pork Festival. In response to RAI 13.3-200), the applicant stated that the value

of 22,000 people per day for the festival in Section 2.3.4 of the EGC ESP Emergency Plan is

incorrea:. According to the DeWitt County ESDA, evacuation planning is based on an

estimated maximum attendance of 50,000 people. The applicant stated that Section 2.3.4 of

the EGC ESP Emergency Plan will be revised to state, 'The current estimate of peak population

for the festival remains the same as in 1993: about 50,000 people. Therefore, the evacuation

times of 380 minutes for fair weather and 530 minutes for adverse weather during the Apple

and Pori: Festival remain valid (see Table 2.3.5)."

Section 2.1, "Site Description," of the EGC ESP Emergency Plan states that the Weldon

Springs State Recreation Area has camping, fishing, and picnicking facilities. Section 2.1 also

states that Lake Clinton State Recreation Area has facilities to accommodate boating, camping,

fishing, picnicking, and hiking. In RAI 13.3-3, the staff asked the applicant to provide additioral

information concerning the availability of adequate shelter facilities for the public in the Weldcon

Springs state Recreation Area and Lake Clinton State Recreation Area. In response to

RAI 13.3-3, the applicant stated that the Weldon Springs State Recreation Area and the Lake

Clinton State Recreation Area do not include any identified shelter facilities. In the case of an

emergency, the applicant assumed that the public in these locations would leave the recreation

area and proceed either to their own homes (if applicable) or to the designated shelter facilities,

as identified in Section 10.1, "Notification of On-site Personnel," of the EGC ESP Emergency

Plan. In addition, the applicant stated that the ETE analysis discussed in Section 2.3 of the

EGC ESP Emergency Plan considers this relocation.

In Section 2.4, "Results-Significant Impediments to the Development of an Emergency Plan,"

of the EGC ESP Emergency Plan, the applicant stated that there are no geographic or political

impediments to the development of an emergency plan. The applicant also stated that

Table 2.3-5, "Evacuation Time Estimates," contains those ETEs from the 1993 ETE analysis

that rema n valid for the current ESP application.

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13.3.1.2 Regulatory Evaluation

In Section 1.1, ."Overview,"-of-the EGCGESP Emergency Plan, the applicant stated that it

developed the EGC ESP Emergency Plan to comply with the requirements of 10 CFR 52.17,

"Contents of Application," using the guidance in Supplement 2. In Section 1.2, "Planning

Standards and Evaluation Criteria," of the EGC ESP Emergency Plan, the applicant stated that

the EGC ESP Emergency Plan, in conjunction with future implementing and administrative

procedures, documents the methods by which the applicant's emergency preparedness

program meets the planning standards in 10 CFR 50.47(b) and the requirements in Appendix E

to 10 CFR Part 50. Therefore, the staff finds that the applicant identified the regulatory

requirements and guidance applicable to the proposed major features of emergency plans for

an ESP application.

In its review of the application, the staff considered the regulatory requirements in 10 CFR

52.17(b)(1), that mandate that the applicant for an ESP identify physical characteristics unique

to the proposed site, such as egress limitations from the area surrounding the site, that could

pose a significant impediment to the development of emergency plans. The staff further

considered 10 CFR 52.18, "Standards for Review of Applications," that requires consultation

with FEMA to determine whether the information required of the applicant by 10 CFR

52.17(b)(1) demonstrates that no significant impediment to the development of emergency

plans exists. Supplement 2 and RS-002 provide guidance concerning the review and

evaluation of emergency response planning information given in an ESP application.

Supplement 2 defines a significant impediment as a physical characteristic or combination of

physical characteristics that would pose major difficulties for an evacuation or the taking of

other protective actions. Such unique physical characteristics may be identified by performing a

preliminary analysis of the time needed to evacuate various sectors and distances within the

10-mile EPZ for transient and permanent populations, noting major difficulties for an evacuation

(e.g., significant traffic-related delays) or the taking of other protective actions.

According to RS-002, the applicant should address factors, such as the availability of adequate

shelter facilities, local building practices, and land use (e.g., outdoor recreation facilities,

including camps, beaches, hunting or fishing areas), and the presence of large institutional or

other special needs populations (e.g., schools, hospitals, nursing homes, prisons), when

identifying significant impediments to the development of emergency plans. Any ETE or other

identification of physical impediments should include the latest population census numbers and

the most recent local conditions. In addition, the applicant should describe the proposed means

for resolving any impediments identified.

13.3.1.3 Technical Evaluation

The staff finds the applicant's clarification regarding the use of the information in the Phase

One Report in the response to RAI 13.3-15 to be acceptable. The staff finds that the

applicant's response to RAI 13.3-17 regarding extrapolated population data is consistent with

the guidance in Supplement 2 and is, therefore, acceptable. The staff finds the applicant's

clarification regarding the availability of adequate shelter facilities for the public in the Weldon

Springs and Lake Clinton State Recreation Areas in response to RAI 13.3-3 to be acceptable.

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In RAls 13.3-20(a) through (1), the staff requested information regarding the ETE for CPS as

part of its review of physical characteristics unique to the site that could pose significant

impediments to the development of emergency plans. The staff identified the need for this

information as Open Item 13.3-1. In its submission to the NRC dated January 24, 2005, the

applicant responded to RAls 13.3-20(a) through (). The information related to the 1993 ETE

for Clinlon provided by the applicant in response to RAls 13.3-20(a) through 0) is consistent

with the guidance in Supplement 2 and is, therefore, acceptable. The staff considers

Open It-am 13.3-1 to be resolved.

The staff notes that the ESP application site is adjacent to CPS. Integrated onsite and offsite

radiological emergency plans currently exist for CPS, that is an operating nuclear power plant.

Because CPS is an operating nuclear power plant, with integrated onsite and offsite emergency

plans, no significant impediments exist to the development of an emergency plan for the site.

In addition, the applicant adequately identified physical characteristics unique to the proposed

site by performing a preliminary analysis of the time required to evacuate various sectors and

distances within the plume exposure pathway EPZ for transient and permanent populations and

did not note any major impediments for an evacuation or other protective actions.

The ETEE analysis includes a map showing the proposed site and plume exposure pathway

EPZ, as well as transportation networks, topographical features, and political boundaries. The

boundaries of the EPZ, in addition to the evacuation subareas within the EPZ, are based on

factors such as current and projected demography, topography, land characteristics, access

routes, and jurisdictional boundaries. The applicant's 1993 ETE does not require updating,

since the guidance in NUREG/CR-4831, "State of the Art in Evacuation Time Estimate Studies

for Nuclear Power Plants," states that, as a general rule, a 10-percent increase in the

population indicates a need to check evacuation times.

The ETE analysis in the application includes an estimate of the number of people to be

evacuated, using the latest population census numbers and the most recent local conditions.

The population estimate also considers permanent residents, transients, and persons in special

facilities, including those confined to institutions such as hospitals, nursing homes, and prisons.

The applicant also evaluated the school population in the special facility segment of the

analysis.

The ETE analysis in the application included a complete review and description of the road

network in the proposed site area. The applicant included the assumptions for determining the

number of vehicles that should be provided, as well as the methodology for determining the

transport-dependent population. The applicant also analyzed travel times and potential

locations for serious congestion along the evacuation routes. The ETE analysis considered

normal and adverse weather conditions, such as flooding, snow, ice, fog, or rain, as well.

The ETE analysis focused on site factors that are considered to be impediments to emergency

planning and preparedness. The analysis did not identify any of the ETEs as being unduly

high. In addition, the analysis did not identify any major difficulties for an evacuation or the

taking of other protective actions, such as sheltering in the plume EPZ.

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The staff finds that the applicant adequately addressed other factors, such as the availability of

sufficient shelter facilities, taking into consideration local building practices and land use (e.g.,

outdoor recreation facilities, including camps, beaches,-and hunting or fishing areas).

The applicant did not identify any other physical characteristics that could pose a significant

impediment to the development of an emergency plan, such as new home or shopping center

construction, an industrial park, a major increase in the number of new employers, or new roads

or highways.

13.3.1.4 Conclusions

As discussed above, the applicant has demonstrated through the use of the 1993 ETE that no

physical characteristic unique to the proposed ESP site could pose a significant impediment to

the development of emergency plans. Based on its review, as set forth above, the staff

concludes that the information the applicant provided is consistent with the guidance in RS-002

and Supplement 2. Therefore, the information is acceptable and meets the requirements of

10 CFR 52.17(b)(1) and 10 CFR 52.18.

13.3.2 Contacts and Arrangements with Federal, State, and Local Agencies

13.3.2.1 Technical Information in the Application

Section 3.1.1.2, "State Agencies," of the EGC ESP Emergency Plan states that the Director of

IEMA has acknowledged support of the EGC ESP Emergency Plan. A letter dated

December 9, 2002, from Mr. Jeffrey A. Benjamin, Vice President, Licensing & Regulatory

Affairs (EGC), to Mr. Michael Chamness, Director, IEMA, requests IEMA support of the EGC

ESP application. The letter states that Mr. Chamness's signature attests to his awareness of

the intent of EGC to take credit for the existing IPRA Volumes I and Vill in the ESP application

and that no significant impediments exist to implementing the emergency plan for the ESP

plant.

Appendix A, 'Contacts and Arrangements" to the EGC ESP Emergency Plan contains a letter

dated December 9, 2002, from Mr. Jeffrey A. Benjamin, Vice President, Licensing & Regulatory

Affairs (EGC), to Mr. Thomas W. Ortciger, Director, Illinois Department of Nuclear Safety

(IDNS), requesting IDNS support of the EGC ESP application. The letter states that

Mr. Ortciger's signature attests to his awareness of the intent of EGC to take credit for the

existing IPRA Volumes I and Vill in the ESP application and that no significant impediments

exist to implementing the emergency plan for the ESP plant.

Section 3.2.5, "Agreements in Planning Effort," of the EGC ESP Emergency Plan states that

IDNS and IEMA are aware of and have concurred with the applicant's intent to take credit for

IPRA Volumes I and Vil in the ESP application.

In RAI 13.3-4, the staff requested documentation of the applicant's contacts and arrangements

with local governmental agencies having emergency planning responsibilities within the plume

exposure EPZ. This documentation should specifically address the expanded responsibilities

associated with an additional reactor (or reactors) at the Clinton site. In its response to

RAI 13.3-4, the applicant stated that the IEMA agreement letter, which was included in

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Appendix A to the EGC ESP Emergency Plan, provides documentation of the necessary

contacts and arrangements with local governmental agencies having emergency planning

responsibilities within the plume exposure EPZ. The applicant also stated that the State of

Illinois established IEMA to coordinate and assist the counties and municipalities in the event of

radiological accidents. The applicant referenced and provided the staff with a copy of the State

of Illinos Statute 20 ILCS 3305/2, "Illinois Emergency Management Act."

Section 3.2.5 of the EGC ESP Emergency Plan also states that agreement letters with those

Federal agencies that are legally required to respond are not necessary.

13.3.2.12 Regulatory Evaluation

In Section 1.1 of the EGC ESP Emergency Plan, the applicant stated that it developed the plan

to comply with the requirements of 10 CFR 52.17 using the guidance in Supplement 2. In

Section 1.2 of the EGC ESP Emergency Plan, the applicant stated that the EGC ESP

Emergency Plan, in conjunction with future implementing and administrative procedures,

documents the methods by which the applicant's emergency preparedness program meets the

planning standards in 10 CFR 50.47(b) and the requirements in Appendix E to 10 CFR Part ;0.

The staff finds that the applicant identified the regulatory requirements and guidance applicable

to the proposed major features of emergency plans for an ESP application.

In its review of the application, the staff considered the regulatory requirements in 10 CFR

52.17(b)(3), which mandate, in part, that an ESP application describe the contacts and

arrangements made with Federal, State, and local governmental agencies with emergency

planning responsibilities. Supplement 2 and RS-002 provide guidance concerning the review

and evaluation of emergency planning information given in an ESP application.

Supplement 2 states that the description of contacts and arrangements should include the

name and location of the organization contacted, the title and/or position of the person(s)

contacted, and the role of the organization in emergency planning. The evaluation criteria in

Supplement 2, Section V, provide additional guidance, that applies to the submission of

emergency plans under the major features option of 10 CFR 52.17(b)(2)(i).

According to RS-002, for an operating reactor site, the ESP application should clearly indicate

the impact of applying an existing emergency preparedness program element to the expanded

use of the site, including any necessary changes to the program in support of a new reactor(s).

For example, letters of agreement, reflecting contacts and arrangements made with local and

State governmental agencies with emergency planning responsibilities might need revision to

reflect the anticipated presence of an additional reactor(s) at the site. Such revised letters of

agreement should reflect any impact an additional reactor(s) would have on the agencies'

emergency response planning responsibilities and should include acknowledgment by the

agencies of the proposed expanded responsibilities. The use of separate correspondence

would alsD be acceptable. If the applicant cannot make arrangements with Federal, State, and

local governmental agencies with emergency response planning responsibilities, for whatever

reason, the applicant should discuss its efforts to make such arrangements, along with a

description of any compensatory measures it has taken or plans to take because of the lack of

such arrangements.

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13.3.2.3 Technical Evaluation

The applicant's -initial description of'contacts and arrangements made with Federal, State, and

local governmental agencies did not clearly address the presence of an additional reactor(s) at

the site and any resulting impact on the agencies' emergency planning responsibilities,

including the agencies' acknowledgment of the proposed expanded responsibilities. Further,

the additional information provided by the applicant in its response to RAI 13.3-4 did not

adequately address the request. Therefore, the staff identified in Open Item 13.3-2 that the

applicant's documentation of contacts and arrangements with local governmental agencies

having emergency planning responsibilities within the plume exposure EPZ (potentially DeWitt,

Macon, McLean, and Piatt Counties; the municipalities of Clinton, Wapella, and Weldon; and

the Village of DeWitt) did not address the expanded responsibilities associated with an

additional reactor(s) at the Clinton site. In its submission to the NRC dated April 4, 2005, the

applicant responded to Open Item 13.3-2. The applicant stated that, as indicated in the original

response to RAI 13.3-4 (submitted October 5, 2004), documentation of contacts and

arrangements with local governmental agencies with emergency planning responsibilities within

the plume exposure EPZ is provided through IEMA and the State of Illinois Statute 20 ILCS

3305. Specifically, Section 3305/2 of the statute establishes the IEMA and authorizes

"emergency management programs with the political subdivision of the State." Section 3305/4

of the statute defines political subdivisions as "any county, city, village, or incorporated town or

township...." Section 3305/5(f) indicates that the IEMA shall (among other things) take the

following actions:

(1) Coordinate the overall emergency management program of the State.

(4) Promulgate rules and requirements for political subdivision emergency

operations plans that are not inconsistent with and are at least as stringent as

applicable federal laws and regulations.

(5) Review and approve, in accordance with Illinois Emergency Management

Agency rules, emergency operations plans for those political subdivisions

required to have an emergency services and disaster agency pursuant to this

Act.

(5.5) Promulgate rules and requirements for the political subdivision emergency

management exercises, including, but not limited to, exercises of the emergency

operations plans.

(5.10) Review, evaluate, and approve, in accordance with Illinois Emergency

Management Agency rules, political subdivision emergency management

exercises for those political subdivisions required to have an emergency services

and disaster agency pursuant to this Act.

(6) Determine requirements of the State and its political subdivisions for food,

clothing, and other necessities in event of a disaster.

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These sections show that IEMA coordinates and provides all necessary contacts and

arrangements with the political subdivisions of the State, including the local governmental

agencies with emergency planning responsibilities within the plume exposure EPZ.

Based on the applicant's above description of contacts and arrangements with Federal, State,

and local governmental agencies with emergency planning responsibilities, that included the

name and location of the organization contacted, the title of the persons contacted, and the role

of the organization in emergency planning, the staff considers Open Item 13.3-2 to be resolved.

13.3.2.4 Conclusions

As discussed above, the applicant provided an acceptable description of contacts and

arrangements made with Federal, State, and local governmental agencies with emergency

planning responsibilities. Based on its review as set forth above, the staff concludes that

the information the applicant provided is consistent with the guidance of RS-002 and

Supplement 2. Therefore, the information is acceptable and meets the requirements of 10 C:FR

52.1 7(b)(3).

13.3.3 Major Features of the Emergency Plans

13.3.3.1 Emergency Planning Zones

13.3.3.1.1 Technical Information in the Application

Section :2.2.1 of the EGC ESP Emergency Plan states that the EPZ boundary of the EGC ESP

site is identical to the CPS EPZ boundary, that was defined in 1985 following a detailed review

of the demography, topography, characteristics of the land, access routes, and jurisdictional

boundaries in the area surrounding the power facility. The review determined that the primary

basis for the EPZ boundary definition should be political jurisdictions, strong topographical

features (e.g., rivers and mountains), or manmade features (e.g., highways and railroads). The

area of the plume exposure EPZ is about 10 miles in radius. Figure 2.2-1 of the EGC ESP

Emergency Plan shows the radial boundary of the EGC ESP site plume exposure pathway

EPZ.

Section 2'.2.2, "Ingestion Pathway Emergency Planning Zone," of the EGC ESP Emergency

Plan states that Map E, "Dairies and Food Processing Plants, Water Basins and Public Water

Supply Intakes, and Illinois Department of Public Health Medical Facility Map," of IPRA

Volume VIII identifies major roads, population centers, and public drinking water system intakes

from surface water sources within Illinois that are located within a 50-mile radius of the EGC

ESP site. The map also identifies the county boundaries.

13.3.3.1.2 Regulatory Evaluation

In Section 1.1 of the EGC ESP Emergency Plan, the applicant stated that it developed the plan

to comply with the requirements of 10 CFR 52.17, using the guidance in Supplement 2. In

Section 1.2 of the EGC ESP Emergency Plan, the applicant stated that the EGC ESP

Emergency Plan, in conjunction with future implementing and administrative procedures,

documents the methods by which the applicant's emergency preparedness program meets the

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planning standards in 10 CFR 50.47(b) and the requirements in Appendix E to 10 CFR Part 50.

The staff finds that the applicant identified the regulatory requirements and guidance applicable

to the proposed major features of emergency plans for an ESP application.

In its review of the application, the staff considered the regulatory requirements in 10 CFR

52.17(b)(2)(i) and 10 CFR 52.18. In addition, the staff considered the regulatory requirements

in 10 CFR 50.33(g), 10 CFR 50.47(c)(2), and Sections I, IlIl, and IV of Appendix E to 10 CFR

Part 50 in its review of the size and configuration of the EPZs. Under 10 CFR 52.17(b)(2)(i), an

applicant for an ESP may propose major features of emergency plans for NRC review and

approval, in consultation with FEMA, in the absence of a complete and integrated emergency

plan. Under 10 CFR 52.18, after consultation with FEMA, the NRC will determine whether the

major features of the emergency plans submitted under 10 CFR 52.17(b)(2)(i) are acceptable.

RS-002 and Supplement 2 provide guidance concerning the review and evaluation of

emergency planning information given in an ESP application. Supplement 2 also provides

specific evaluation criteria for the major features of emergency plans, including those that apply

to determining the size and configuration of the EPZs.

Section III.A of Supplement 2 states that an ESP applicant choosing the option of proposing the

major features of an emergency plan should give special emphasis to the exact size of the

EPZs. Generally, the 10-mile and 50-mile EPZs consist of an area about 10 miles and 50 miles

in radius, respectively. Applicants should determine the exact size and configuration of the

EPZs with respect to local emergency response needs and capabilities, since the EPZs can be

affected by conditions, such as demography, topography, land characteristics, access routes,

and jurisdictional boundaries.

13.3.3.1.3 Technical Evaluation

The applicant described the exact sizes of the EPZs. The applicant also described the exact

size and configuration of the EPZs in relation to local emergency response needs and

capabilities, as they are affected by such conditions as demography, topography, land

characteristics, access routes, and jurisdictional boundaries.

13.3.3.1.4 Conclusions

As discussed above, the applicant proposed a plume exposure pathway EPZ of approximately

a 10-mile radius and an ingestion pathway EPZ of approximately a 50-mile radius, both that

reflect local emergency response needs and capabilities. Based on its review, the staff

concludes that the proposed major feature, that addresses the size and configuration of the

EPZs, is consistent with the guidance in RS-002 and Supplement 2. Therefore, this feature is

acceptable and meets the requirements of 10 CFR 50.33(g), 10 CFR 50.47(c)(2), 10 CFR

52.17(b)(2)(i), 10 CFR 52.18, and Sections I, III, and IV of Appendix E to 10 CFR Part 50,

insofar as it describes the essential elements of advanced planning the applicant considered for

the EPZs, as set forth above. EGC provided other information in the application that is outside

the scope of the staff's review of this feature and is not discussed in this SER. Therefore, the

staff did not make findings regarding its acceptability.

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13.3.3.2 Assignment of Responsibility (Organization Control) (Major Feature A)

13.3.3.2.1 Technical Information in the Application

Section 3.1, "Concept of Operation,' of the EGC ESP Emergency Plan identifies the Federal,

State, local, and private sector organizations that are intended to be part of the overall response

organization for EPZs as the NRC, the U.S. Department of Energy (DOE), the Federal Bureau

of Investigation (FBI), the U.S. National Weather Service (NWS), the EGC ESP facility

organization, the corporate organization, and the public information organization. Section 3.4,

"Emergency Response Support and Resources," of the EGC ESP Emergency Plan identifies

the support services organizations to the EGC ESP facility as the Institute of Nuclear Power

Operations; American Nuclear Insurers; Environmental, Inc.; Teledyne Brown Engineering;

DOE Radiation Emergency Assistance Center/Training Site (REAC/TS); Murray and Trettel,

Inc.; ICN Worldwide Dosimetry Service; Framatome Technologies, the future nuclear steam

supply system vendor; John Warner Hospital and Ambulance Service; Decatur Memorial

Hospital; DeWitt County Sheriff's Department; Clinton Fire Department; IDNS; and IEMA.

Volume I of the IPRA lists the State and local governmental agencies with responsibility for

emergency response in Sections F, "Overview, Operational Centers;" 11, "Overview, Utility

Emergency Plans;" 1J, "Overview, Contiguous States;" 2A, "Direction and Control, Office of the

Governor;" 2B, "Direction and Control, Chain of Command;" 3A, "Agency Responsibilities, State

Agencies;" 3B, "Agency Responsibilities, Federal Agencies;" and 3C, "Agency Responsibilities,

Private Organizations."

Volume VIII of the IPRA lists the State and local governmental agencies with responsibility for

emergency response in Sections 1 C, "General Information, Concept of Operations;" 1 D,

"General Information, Participating State Agencies;" 2A, "DeWitt County, Functional SummarY

Descriptions;" 2B, "DeWitt County, Initial Contact and Operational Response Levels;" 2E,

"DeWitt county, Emergency Facilities;" and 2F, "DeWitt County, Concept of Operations;" as

well as Annexes 2A, "DeWitt County Checklist Procedures;" 2B, "Clinton Checklist Procedures;"

2C, 'Weldon Checklist Procedures;" 2D, "Wapella Checklist Procedures;" 2E, "DeWitt Village

Checklisi Procedures;" and 2F, "Support County Checklist Procedures."

Volume I of the IPRA describes State and local functions and responsibilities for major

elements of emergency response in Sections 1 E, "Overview, Basic Functions," 2A, 2B, 3A, 313,

and 3C. Section 2A describes the responsibilities for the Office of the Governor, and

Section 3A describes the responsibilities of the 11 State agencies in the event of a radiological

emergency at CPS. The State of Illinois has overall command responsibility for radiological and

nonradiological aspects of a nuclear incident. Section 1 E describes the basic emergency

response functions and Section 3A provides the specific duties of each State agency for

implemerting these basic responsibilities. Section 2B describes the Illinois chain of command.

Section 3B notes the responsibilities of Federal agencies, while Section 3C details the

American Red Cross responsibilities.

In IPRA Volume Vil, Sections 2A and 2F and Annex 2A identify the major functions to be

performed by DeWitt County. In the area of protective actions, DeWitt County would undertake

traffic anc access control; evacuation support; food, water, and milk control; exposure control;

law enforcement; emergency medical services; fire and rescue; and social services. Annex 21-

13-19
provides the support county functions and responsibilities, and Annexes 2B, 2C, 2D, and 2E

provide the functions and responsibilities for the three municipalities and one village in DeWitt

County: Tables F.2.'c.1 through-F.2.c:5'of IPRA Volume VIII relating to DeWitt County, the

municipalities of Clinton, Weldon, Wapella, and DeWitt Village, respectively, display agency

responsibilities by organization in matrix format.

Section 1A, "Purpose and Authorization," of IPRA Volume I, provides the following legal

citations to support the activities of IDNS and IEMA in developing and maintaining the IPRA:

* Illinois Emergency Management Agency Act (20 ILCS 3305)

* Directive from Governor James R. Thompson, dated May 17, 1979

* Illinois Nuclear Safety Preparedness Act (420 ILCS 5)

* Department of Nuclear Safety-Powers Enabling Statute (20 ILCS 2005/2005-1)

* Radiation Protection Act of 1990 (420 ILCS 40)

* Illinois Nuclear Facility Safety Act (420 ILCS 10)

IDNS and IEMA are the primary State agencies with responsibilities for responding to a

radiological emergency. The IPRA protects the citizens of Illinois in the event of a radiological

accident. Other State agencies also have major responsibilities in an emergency, as described

in Section 3A of IPRA Volume I.

Section 2F of IPRA Volume VIII states that the principal executive officers of DeWitt County and

the risk municipalities are authorized to initiate actions and command emergency personnel in

any effort to protect the residents of their jurisdictions by their respective bylaws and charters

and by the Illinois Emergency Management Agency Act. In RAI 13.3-13(a), the staff asked the

applicant to describe the legal basis (i.e., reference specific acts, codes, or statutes) for county

or municipal authorities to comprise part of the overall response organization for the EPZs. In

response to RAI 13.3-13(a), the applicant stated that Section 1A of IPRA Volume I describes

this legal basis. This authorization document includes the political subdivisions of the State

(e.g., the county and municipal authorities). Specifically, one purpose of 20 ILCS 3305/2 is to

"confer upon the Governor and upon the principal executive officer of the political subdivisions

of the State the powers provided herein."

Section 3.1.1.1.1, "United States Nuclear Regulatory Commission," of the EGC ESP

Emergency Plan describes the role of the NRC in the event of an incident. Section 3.1.1.1.4,

"United States Department of Energy," of the EGC ESP Emergency Plan describes the role of

DOE in the event of an incident. Section 3.1.1.1.6, "Federal Bureau of Investigation," of the

EGC ESP Emergency Plan describes the role of the FBI in the event of an incident.

Section 3.1.1.1.7, "United States National Weather Service," describes the role of the NWS in

the event of an incident. Section 3.1.2, "Applicant Response Organization," describes the

applicant's emergency response organization (ERO) that would replace the normal plant

organization during an emergency. The ERO will consist of the EGC ESP facility, corporate,

and public information response suborganizations. Section 3.4 of the EGC ESP Emergency

Plan describes the contractors that will be retained to provide supporting services to the EGC

ESP facility. The applicant will use a contract/purchase order with a private contractor in lieu of

an agreement letter for the specified duration of the contract. Appendix A to the EGC ESP

Emergency Plan describes support services under agreements or contracts. For the support

services listed in Section 3.4 of the EGC ESP Emergency Plan, the specific contractors may

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change but the functions will be maintained. The applicant will only ensure that the agreements

and contacts with the necessary third parties will be in place when the attributes of this plan

need to be in effect.

Section 3.1.1.3, "County Government Agencies," of the EGC ESP Emergency Plan states that

the surrounding communities that comprise the plume exposure pathway EPZ have developed

integrated emergency response programs that call upon the resources of the community.

Section 3.1.1.3 also states that the community organizations will implement and coordinate the

community response to an emergency. In addition, Section 3.1.1.3 identifies the surrounding

communities as DeWitt, Macon, McLean, and Piatt Counties; the municipalities of Clinton,

Wapella, and Weldon; and the Village of DeWitt. In RAI 13.3-18, the staff requested a copy of

a letter of agreement with the DeWitt County Sheriff's Department that is dated 2003 or later.

The applicant provided a copy of such a letter in its response to RAI 13.3-18.

Section 3.2.5 of the EGC ESP Emergency Plan states that written agreements establishing

the concept of operations developed between the applicant and its support organizations

having an emergency response role within the CPS EPZ have been developed. These

arrangements identify the emergency measures to be. provided, the mutually accepted criteria

for implementation, and the agreements for the exchange of information. Appendix A to the

EGC ESP Emergency Plan provides letters of agreement, contracts, and purchase orders

between the applicant and the various support organizations having a response role.

Chapter 2, 'DeWitt County," in IPRA Volume VIII contains letters signed by the county board

chairme.- of DeWitt, Macon, McLean, and Piatt Counties, as well as the mayors of Clinton,

Weldon, Wapella, and DeWitt, acknowledging these duties, responsibilities, and relationship;.

13.3.3.2.2 Regulatory Evaluation

In Section 1.1 of the EGC ESP Emergency Plan, the applicant stated that it developed the plan

to comply with the requirements of 10 CFR 52.17, using the guidance in Supplement 2. In

Section 1.2 of the EGC ESP Emergency Plan, the applicant stated that the EGC ESP

Emergency Plan, in conjunction with future implementing and administrative procedures,

documents the methods by which the applicant's emergency preparedness program meets the

planning standards in 10 CFR 50.47(b) and the requirements in Appendix E to 10 CFR Part 50.

The staff finds that the applicant identified the regulatory requirements and guidance applicable

to the proposed major features of emergency plans for an ESP application.

In its review of the application, the staff considered the regulatory requirements in 10 CFR

52.17(b)i:2)(i), 10 CFR 52.18, and Sections lIl and IV.A of Appendix E to 10 CFR Part 50.

Under 10 CFR 52.17(b)(2)(i), an applicant for an ESP can propose major features of

emergency plans for NRC review and approval, in consultation with FEMA, in the absence of

complete and integrated emergency plans. Under 10 CFR 52.18, after consultation with

FEMA, the NRC will determine whether the major features of emergency plans submitted

under 10 CFR 52.17(b)(2)(i) are acceptable. RS-002 and Supplement 2 provide guidance

concerning the review and evaluation of emergency planning information given in an ESP

application. Supplement 2 also provides specific evaluation criteria for the major features

of emergency plans, including those that apply to major feature A, "Assignment of

Respons bility-Organization Control."

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Major feature A calls for the applicant to identify EROs, including functions and responsibilities

for major elements of response, and the legal bases for State and local authorities. The ESP

application should also describe contacts and arrangements between agencies and other

support organizations having a response role within the EPZs, and it should include any written

letters of agreement.

13.3.3.2.3 Technical Evaluation

As described above, the EGC ESP Emergency Plan, IPRA Volumes I and Vil, and the

applicant's response to RAI 13.3-13(a) identify the Federal, State, local, and private sector

organizations (including utilities) that are intended to be part of the overall response

organization for the EPZs.

Volumes I and Vill of the IPRA identify the functions and responsibilities for major elements of

emergency response, such as command and control, alerting and notification, communications,

public information, accident assessment, public health and sanitation, social services, fire and

rescue, traffic control, emergency medical services, law enforcement, transportation, protective

response, and radiological exposure control. In addition, IPRA Volumes I and Vil (by reference

to specific acts, codes, or statutes) identify the legal basis for the State, local, and private sector

organizations that are part of the overall response organization for the EPZs to carry out their

identified functions and responsibilities.

The EGC ESP Emergency Plan, IPRA Volumes I and Vil, and the EGC response to

RAI 13.3-18 adequately describe contacts and arrangements pertaining to the concept of

operations developed among Federal, State, and local agencies and other support

organizations having an emergency response role within the EPZs. The plan includes letters of

agreement. Sections 13.3.2," Contacts and Arrangements with Federal, State, and Local

Agencies;" 13.3.3.4, "Emergency Response Support and Resources;" 13.3.3.7, "Emergency

Communications;" 13.3.3.10, "Accident Assessment;" and 13.3.3.13, "Medical and Public

Health Support;" of this SER also describe these contacts and arrangements.

13.3.3.2.4 Conclusions

As discussed above, the applicant identified the EROs, including the functions and

responsibilities for major elements of response, and the legal bases for State and local

authorities. In addition, the applicant described contacts and arrangements among the

agencies and other support organizations having a response role within the EPZ. Based on its

review, the staff concludes that the proposed major feature A is consistent with the guidance in

RS-002 and Supplement 2. Therefore, this feature is acceptable and meets the requirements

of 10 CFR 52.17(b)(2)(i), 10 CFR 52.18, and Sections III and IV.A of Appendix E to 10 CFR

Part 50, insofar as it describes the essential elements of advanced planning that the applicant

considered for organization control, as set forth above. EGC provided other information in the

application that is outside the scope of the staff's review of this feature and is not discussed in

this SER. Therefore, the staff did not make findings regarding its acceptability.

13-22
13.3.3. 3 Onsite Emergency Organizations (Major Feature B)

13.3.3.3.1 Technical Information in the Application

In Section 3.1.2.4, "Interrelationships," of the EGC ESP Emergency Plan, the applicant stated

that Figures 3.1-1, "Applicant Emergency Response Organization Interrelationships,' and 3.1-2,

"Agency Response Organization Interrelationships," illustrate the major applicant organizations

and suborganizations, as well as government interrelationships, in the total response effort. In

RAI 13.3-5, the staff asked the applicant to provide additional information related to ERO

interfaces between and among the on-shift emergency response functional areas, local support

services, and State and local governmental response organizations. In its response to

RAI 13.3-5, the applicant noted that Figure 3.1-2 in the EGC ESP Emergency Plan provides the

interfaces between and among the on-shift emergency response functional areas and local

support services. However, Figures 3.1-1 and 3.1-2 do not show specific details for all of the

possible interrelationships because they vary with time (e.g., before and after activation of the

emergency operations facility (EOF) and the various State and local emergency operations

centers (EOCs)) and with the declared level of event (e.g., an unusual event versus a general

emergency). For example, for the declaration of an unusual event, the interrelationship occurs

directly between the control room and the required State or local service. However, in the latter

stages of a general emergency, interrelationships would occur through the established

communications paths and generally include the emergency director in the EOF placing a

specific request through the State EOC (SEOC).

In general, for significant events, the emergency response functional areas (see "Applicant" in

Figure 3.1-2 in the EGC ESP Emergency Plan) interface with the local support services through

the EOF and the State and local governmental response agencies (within their respective

EOCs), as shown on Figure 3.1-2 and as discussed in Sections 3.1.2.2, "Corporate

Organization," and 3.1.2.5, "Corporate Emergency Director," of the EGC ESP Emergency Plan.

Section 3.3.5, "Emergency.Response Organization Positional Responsibilities," identifies

specific exceptions to this general diagram under the responsibilities for the individual ERO

positions. For example, Sections 3.3.5.1.1, "Shift Manager (Shift Emergency Director), Control

Room;" '3.3.5.1.2, "Station Emergency Director, Technical Support Center;" and 3.3.5.2.2,

"Corporate Emergency Director, Emergency Operations Director;" indicate the command and

control functions, that direct these interfaces to cycle through the shift emergency director (in

the control room), the station emergency director (in the technical support center (TSC)), and

the corporate emergency director (in the EOF) as the activation of the organization progresses.

The current Figure 3.1-2 best reflects the majority of these permutations by showing the onshift emergency organization generally as "Applicant" and the State and local agencies and

services as "State Agencies" and "County Agencies." Volume VIII of IPRA also addresses this

interface. For example, the figure titled, "DeWitt County Initial Notification," in Chapter 2 of

IPRA Volume VIII shows the DeWitt County interfaces.

Section 3.2.3, "Non-applicant Nuclear Support Services," and Appendix A to the EGC ESP

Emergency Plan, that includes a signature page documenting the annual review of the

agreement between CPS and the DeWitt County Sheriff's Department, address an agreement

to provide traffic control and law enforcement services.

13-23
Sections 3.2.3 and 12.4, "Medical Transportation," as well as Appendix A to the EGC ESP

Emergency Plan, describe arrangements that will be made, as necessary, with Clinton

Ambulance.(John Warner Hospital) for prompt ambulance transport of persons with injuries

involving radioactivity to designated hospitals.

Sections 3.2.3 and 12.1, "Off-site Hospital and Medical Services," of the EGC ESP Emergency

Plan address arrangements, confirmed by letter of agreement or contract every 2 years, that

will be maintained with a qualified hospital located in the vicinity of the EGC ESP facility for

receiving and treating contaminated or exposed persons with injuries requiring immediate

hospital care. The applicant identified John Warner Hospital in Clinton, Illinois, as the primary

supporting medical facility for injured persons who are contaminated with radioactivity.

Appendix A to the EGC ESP Emergency Plan includes a letter of agreement with the hospital.

Section 3.2.3 and Appendix A to the EGC ESP Emergency Plan identify arrangements with

Decatur Memorial Hospital to act as a supporting medical facility and provide medical services.

Appendix A to the ESP application includes a letter of agreement with the hospital.

Section 3.2.3 and Appendix A to the EGC ESP Emergency Plan identify arrangements with

the Clinton Fire Department to provide fire protection services and confined space rescue

operations. Appendix A includes a copy of a letter of agreement with the Clinton Fire

Department to provide fire response support.

13.3.3.3.2 Regulatory Evaluation

In Section 1.1 of the EGC ESP Emergency Plan, the applicant stated that it developed the plan

to comply with the requirements of 10 CFR 52.17, using the guidance in Supplement 2. In

Section 1.2 of the EGC ESP Emergency Plan, the applicant stated that the EGC ESP

Emergency Plan, in conjunction with future implementing and administrative procedures,

documents the methods by which the applicant's emergency preparedness program meets the

planning standards in 10 CFR 50.47(b) and the requirements in Appendix E to 10 CFR Part 50.

The staff finds that the applicant identified the regulatory requirements and guidance applicable

to the proposed major features of emergency plans for an ESP application.

In its review of the application, the staff considered the regulatory requirements in 10 CFR

52.17(b)(2)(i), 10 CFR 52.18, and Sections III and IV.A of Appendix E to 10 CFR Part 50.

Under 10 CFR 52.17(b)(2)(i), an applicant for an ESP can propose major features of

emergency plans for NRC review and approval, in consultation with FEMA, in the absence of

complete and integrated emergency plans. Under 10 CFR 52.18, after consultation with FEMA,

the NRC will determine whether the major features of emergency plans submitted under

10 CFR 52.17(b)(2)(i) are acceptable. RS-002 and Supplement 2 provide guidance concerning

the review and evaluation of emergency planning information given in an ESP application.

Supplement 2 also provides specific evaluation criteria for major features of emergency plans,

including those that apply to major feature B, "Onsite Emergency Organizations."

Major feature B calls for the applicant to identify interfaces between and among the onsite

functional areas of emergency activity, local services support, and State and local government

response organizations, including the services to be provided by local agencies.

13-24
13.3.3.3.3 Technical Evaluation

As discussed above, the applicant identified, in the EGC ESP Emergency Plan and in its

respon~se to RAI 13.3-5, the interfaces between and among the onsite functional areas of

emergency activity, local services support, and State and local government response

organizations.

The applicant also identified in the EGC ESP Emergency Plan the services to be provided by

local agencies for handling emergencies (e.g., police, ambulance, medical, hospital, and

firefighting organizations). The EGC ESP Emergency Plan adequately describes the

arrangements involving these services. The applicant also included written letters of

agreement.

13.3.3.3.4 Conclusions

As discussed above, the applicant identified the interfaces between and among the onsite

functional areas of emergency activity, local services support, and State and local government

response organizations for the ESP site. In addition, the applicant identified the services and

described the arrangements to be provided by various local agencies, and it submitted

adequate letters of agreement. Based on its review, the staff concludes that the proposed

major feature B is consistent with the guidance in RS-002 and Supplement 2. Therefore, this

feature is acceptable and meets the requirements of 10 CFR 52.17(b)(2)(i), 10 CFR 52.18, and

Sections III and IV.A of Appendix E to 10 CFR Part 50, insofar as it describes the essential

elements of advanced planning that the applicant considered for the onsite ERO, as set forth

above. The applicant provided other information in the application that is outside the scope of

the staff's review of this feature and is not discussed in this SER. Therefore, the staff did noi:

make findings regarding its acceptability.

13.3.3.4 Emergency Response Support and Resources (Major Feature C)

13.3.3.4.1 Technical Information in the Application

Section 3.4.5, "United States Department of Energy Radiation Emergency Assistance

Center/Training Site," of the EGC ESP Emergency Plan states that the DOE REAC/TS will

provide services of medical and health physics support. The applicant has made provisions for

requestirg assistance from the DOE REAC/TS through a letter of agreement, as noted in

Appendix A to the EGC ESP Emergency Plan.

Section 3.1.1.1.7, "United States National Weather Service," of the EGC ESP Emergency Plan

states that the NWS provides meteorological information during emergency situations.

Therefore, no special provisions for requesting assistance are needed.

Section 3.1.1.1.4, "United States Department of Energy," describes the applicant's procedure

for seeking assistance from DOE, as outlined in the Federal Radiological Monitoring and

Assessment Plan.

Sections :3A(8), "Illinois Department of Nuclear Safety," and 3B in IPRA Volume I provide the

State's procedures for requesting Federal assistance. The IDNS is authorized to request

13-25
Federal assistance depending on the severity of a radiological incident, as outlined in the

Federal Radiological Emergency Response Plan (FRERP) and in the Radiological Assistance

Program. - -

Section 3.4.3, "Environmental, Inc.," of the EGC ESP Emergency Plan states that the applicant

will rely on Environmental, Inc., to provide radiological environmental monitoring services in an

emergency situation. In addition, Section 3.4.5, "United States Department of Energy Radiation

Emergency Assistance Center/Training Site," of the EGC ESP Emergency Plan states that the

DOE REAC/TS will provide medical and health physics support services. The REAC/TS will

also provide advice on the health physics aspects of situations requiring medical assistance.

Section 3.4.7, "ICN Worldwide Dosimetry Service," of the EGC ESP Emergency Plan states

that ICN Worldwide Dosimetry Service will provide extremity dosimetry services. In an

emergency, ICN Worldwide Dosimetry Service will also provide additional dosimetry to the

affected nuclear facility and EOF. Section 3.4.8, "Framatome Technologies (Post-accident

Sample Analysis Program)," of the EGC ESP Emergency Plan states that Framatome

Technologies (Post-accident Sample Analysis Program) will maintain its hot-cell in a state of

readiness so that a sample analysis can be completed within 24 hours of sample receipt.

Section 3A(8) in IPRA Volume I provides the State's procedures for requesting Federal

assistance. IDNS is authorized to request Federal assistance depending on the severity of a

radiological incident, as outlined in the FRERP and in the Radiological Assistance Program. In

RAI 13.3-13(b), the staff requested a description of the general capabilities of radiological

laboratories (besides the two IDNS mobile laboratories) to provide radiological monitoring and

analyses services. In response to RAI 13.3-13(b), the applicant stated that Section El in IPRA

Volume 1 describes the general capabilities of radiological laboratories (besides the two IDNS

mobile laboratories). These labs include the IDNS laboratory in Springfield and the laboratories

to be provided by the Federal government under the FRERP.

Section 3.4 of the EGC ESP Emergency Plan states that the applicant will retain contractors to

provide supporting services to the EGC ESP facility. Section 3.4 also describes the support

services available under the agreements or contracts listed in Appendix A to the EGC ESP

Emergency Plan. The applicant further stated that, for the support services listed in

Section 3.4, the specific contractors may change but the functions will be maintained.

Section 2F of IPRA Volume Vil provides matrices of the DeWitt County and participating

municipal emergency response agencies and all of the State, local, and private agency

organizations that are expected to play an active role in an emergency. Section 2J, "DeWitt

County, Evacuation Plan," of IPRA Volume Vil briefly summarizes the evacuation plan and the

agencies responsible for different aspects of the evacuation. Section 3D, "Sheltering Guide,

Registration Centers and Congregate Care Shelter Spaces," of IPRA Volume Vil lists the

registration centers and congregate care shelters. Appendix D, "Registration Centers and

Congregate Care Shelters," to IPRA Volume Vil is a list of the registration centers and

congregate care centers, while Appendix E, 'Shelter Profiles," to IPRA Volume Vil is a

compilation of the sheltering profiles (i.e., the location, contact number, and amenities of the

congregate care centers). Map C in IPRA Volume Vil displays the location of the registration

centers and congregate care shelters in relation to the EPZ.

13-26
13.3.3.4.2 Regulatory Evaluation

In Section 1.1 of the EGC ESP Emergency Plan, the applicant stated that it developed the plan

to comply with the requirements of 10 CFR 52.17, using the guidance in Supplement 2. In

Section 1.2 of the EGC ESP Emergency Plan, the applicant stated that the EGC ESP

Emergency Plan, in conjunction with future implementing and administrative procedures,

documents the methods by which the applicant's emergency preparedness program meets the

planning standards in 10 CFR 50.47(b) and the requirements in Appendix E to 10 CFR Part 50.

The staff finds that the applicant identified the regulatory requirements and guidance applicable

to the proposed major features of emergency plans for an ESP application.

In its review of the application, the staff considered the regulatory requirements in 10 CFR

52.17(b1(2)(i), 10 CFR 52.18, and Sections 1I1, IV.A, IV.B, IV.C, IV.D, and IV.E of Appendix E to

10 CFR Part 50. Under 10 CFR 52.1 7(b)(2)(i), an applicant for an ESP may propose major

features of emergency plans for NRC review and approval, in consultation with FEMA, in the

absence of complete and integrated emergency plans. Under 10 CFR 52.18, after consultation

with FEIAA, the NRC will determine whether the major features of emergency plans submitted

under 10 CFR 52.17(b)(2)(i) are acceptable. RS-002 and Supplement 2 provide guidance

concerning the review and evaluation of emergency planning information given in an ESP

application. Supplement 2 also provides specific evaluation criteria for the major features of

emergency plans, including those that apply to major feature C, "Emergency Response Support

and Resources."

Major feature C calls for the applicant to describe contacts and arrangements for requesting

Federal assistance, as well as assistance from radiological laboratories and nuclear or other

facilities and organizations. The application should also identify the general capabilities and

expected availability of radiological monitoring and analyses services.

13.3.3.4.3 Technical Evaluation

The Federal government maintains an in-depth capability to assist licensees, State, and local

governments through the FRERP. The ESP application adequately addresses provisions for

requesting Federal assistance through the EGC ESP Emergency Plan and IPRA Volume I.

The EGC ESP Emergency Plan, IPRA Volumes I and VIII, and the applicant's response to

RAI 13.3-13(b) identified radiological laboratories, their general capabilities, and their expected

availability to provide radiological monitoring and analytical services during an emergency. The

EGC ESF' Emergency Plan and IPRA Volumes I and VIII also identify nuclear and other

facilities and organizations that can provide assistance in an emergency. In addition, the EGG

ESP Emergency Plan describes the contacts and arrangements the applicant has made with

the response organizations identified in Section 13.3.3.2.1 of this SER.

13.3.3.4.4 Conclusions

As discussed above, the applicant described provisions for requesting Federal assistance, and

identified nuclear and other facilities and organizations that can be relied on to provide

assistance in an emergency, including the general capabilities and availability of radiological

laboratories. In addition, the applicant described the contacts and arrangements made with the

13-27
response organizations. Based on its review, the staff concludes that the proposed major

feature C is consistent with the guidance in RS-002 and Supplement 2. Therefore, this feature

is acceptable and meets the requirements of 10 CFR 52.17(b)(2)(i), 10 CFR 52.18, and

Sections III, IV.A, IV.B, IV.C, IV.D, and IV.E of Appendix E to 10 CFR Part 50, insofar as it

describes the essential elements of advanced planning that the applicant considered for

emergency response support and resources, as set forth above. EGC provided other

information in the application that is outside the scope of the staff's review of this feature and is

not discussed in this SER. Therefore, the staff did not make findings regarding its acceptability.

13.3.3.5 Emergency Classification System (Major Feature D)

13.3.3.5.1 Technical Information in the Application

Sections 4.1, "Unusual Event," 4.2, "Alert," 4.3, "Site Area Emergency," and 4.4, "General

Emergency," of the EGC ESP Emergency Plan identify four emergency classes-unusual

event, alert, site area emergency, and general emergency, respectively.

Section 1 C, "Overview, Accident Classification," of IPRA Volume I states that the emergency

classification scheme to be used in the event of an emergency would include unusual event,

alert, site area emergency, and general emergency. The applicant's four classifications, as

defined in the EGC ESP Emergency Plan, are consistent with these.

Section 1C of IPRA Volume Vil also provides a listing of the four emergency classification

levels-unusual event, alert, site area emergency, and general emergency. The applicant's

scheme is consistent with this listing as well.

13.3.3.5.2 Regulatory. Evaluation

In Section 1.1 of the EGC ESP Emergency Plan, the applicant stated that it developed the plan

to comply with the requirements of 10 CFR 52.17, using the guidance in Supplement 2. In

Section 1.2 of the EGC ESP Emergency Plan, the applicant stated that the EGC ESP

Emergency Plan, in conjunction with future implementing and administrative procedures,

documents the methods by which the applicant's emergency preparedness program meets the

planning standards in 10 CFR 50.47(b) and the requirements in Appendix E to 10 CFR Part 50.

The staff finds that the applicant identified the regulatory requirements and guidance applicable

to the proposed major features of emergency plans for an ESP application.

In its review of the application, the staff considered the regulatory requirements of 10 CFR

52.17(b)(2)(i), 10 CFR 52.18, and Sections III and IV.C of Appendix E to 10 CFR Part 50.

Under 10 CFR 52.17(b)(2)(i), an applicant for an ESP may propose major features of

emergency plans for NRC review and approval, in consultation with FEMA, in the absence of

complete and integrated emergency plans. Under 10 CFR 52.18, after consultation with FEMA,

the NRC will determine whether the major features of emergency plans submitted under

10 CFR 52.17(b)(2)(i) are acceptable. RS-002 and Supplement 2 provide guidance concerning

the review and evaluation of emergency planning information given in an ESP application.

Supplement 2 also provides specific evaluation criteria for the major features of emergency

plans, including those that apply to major feature D, "Emergency Classification System."

13-28
Major feature D calls for the applicant to establish a standard emergency classification scheme

that is consistent with Appendix 1 to Revision 1 to NUREG-0654/FEMA-REP-1. Major

feature D also calls for the State and local organizations to establish an emergency

classification scheme that is consistent with that proposed by the applicant.

13.3.3.5.3 Technical Evaluation

The applicant established an emergency classification scheme comprising four

categories-unusual event, alert, site area emergency, and general emergency. These four

categories meet the guidance in Appendix 1 to Revision 1 of NUREG-0654/FEMA-REP-1. The

applicant's scheme also includes a fifth emergency class, "recovery," as stated in Section 4.5,

"Recovery," of the EGC ESP Emergency Plan. The staff did not regard this fifth emergency

class as essential to its review and, therefore, did not consider it. The applicant's emergency

classification scheme is consistent with that established in Volumes I and Vill of IPRA.

13.3.3.5.4 Conclusions

As discussed above, the applicant specified a standard emergency classification scheme, that

is consistent with that set forth in Appendix 1 to NUREG-0654/FEMA-REP-1 and with those

established by the State and local EROs. Based on its review, the staff concludes that the

proposEd major feature D is consistent with the guidance in RS-002 and Supplement 2.

Therefore, this feature is acceptable and meets the requirements of 10 CFR 52.17(b)(2)(i),

10 CFR 52.18, and Sections III and IV.C of Appendix E to 10 CFR Part 50, insofar as it

describes the essential elements of advanced planning that the applicant considered for the

emergency classification system, as set forth above. EGC provided other information in the

application that is outside the scope of the staff's review of this feature and is not discussed in

this SER. Therefore, the staff did not make findings regarding its acceptability.

13.3.3.6 Notification Methods and Procedures (Major Features E)

13.3.3.6.1 Technical Information in the Application

In Section 5.1, "Bases for Emergency Response Organization Notification," of the EGC ESP

Emergency Plan, the applicant stated that, in cooperation with the State of Illinois and county

authorities, it has established mutually agreeable methods and procedures for notifying offsit9

response organizations consistent with the action level scheme discussed in the previous

section. These methods and procedures apply to CPS and other EGC facilities within the State

of Illinois.

Sections 1 D, "Overview, Operational Response Levels," 3A, and 4A,"Communications, Nuclear

Accident Reporting System," in IPRA Volume I list procedures for the notification of State

agencies and local communities based on emergency classification levels.

Sections 1C, 1D, and 2B, as well as Annexes 2A, 2B, 2C, 2D, 2E, and 2F of IPRA Volume Vil,

describe detailed notification procedures, based on the CPS and State emergency classification

levels, for the counties and risk municipalities.

13-29
Sections 5.2.1, "On-site," 5.2.2, "Off-site," and 5.2.3, "Support Organizations," of the EGC ESP

Emergency Plan describe the methods for alerting, notifying, and mobilizing onsite, offsite, and

support organization emergency response.

Sections 3A, 4B, "Communications, Nuclear Accident Reporting System," 4C,

"Communications, IDNS Radio Network," and 4D, "Communications, State Agency

Communications Networks," in IPRA Volume I provide the procedures that Illinois State

agencies use to mobilize and activate emergency response personnel. Sections 3A(3),

"Agency Responsibilities, State Agencies, Illinois Emergency Management Agency," and 3A(8)

in IPRA Volume I state that the IEMA and the IDNS, respectively, receive notification of an

unusual event concurrently from CPS through the nuclear accident reporting system (NARS).

As described in Section 3A of IPRA Volume I, each agency has procedures to mobilize staff by

commercial telephone, pager, or radio commensurate with his or her responsibilities in an

emergency. The IEMA notifies the county and municipal governments as appropriate via

NARS.

Sections 1 C, 1 D, 2B, 2C, 'DeWitt County, Call List," and 2D, "DeWitt County, Flow Diagram

Notes for DeWitt County Initial Notification," as well as Annexes 2A, 2B, 2C, 2D, 2E, and 2F of

IPRA Volume VIII, provide specific mobilization and activation procedures for the counties and

municipalities within the plume exposure pathway EPZ.

Section 5.5, "State and County Information Dissemination," of the EGC ESP Emergency Plan

explains that the State of Illinois and county emergency response plans include procedures for

how State and county officials should make a public notification decision promptly (within about

15 minutes) once the plant has informed them of an emergency. Currently, the applicant's

system for disseminating information to the public includes notification by prescripted messages

through appropriate broadcast media, such as the emergency alert system (EAS).

Subsections 5.5.1, "Notification of the Public," and 5.5.2, "Messages to the Public," of the EGC

ESP Emergency Plan describe dissemination systems that are already in service and will be

used for a future EGC ESP facility.

Section 1G, "Overview, Notification of the Public," of IPRA Volume I discusses activation of the

alert notification sirens, deployment of emergency service vehicles, and operation of the EAS.

The electronic and mechanical sirens emit a blast and have voice capabilities. The siren

system, supplemented by mobile public address (PA) systems, provides coverage to essentially

100 percent of the plume exposure EPZ. After the sounding of the sirens or notification by

mobile units, radio broadcast informs members of the public within the plume exposure pathway

EPZ of what actions to take.

Section 2A, "DeWitt County, Functional Summary Descriptions," in IPRA Volume VIII specifies

that DeWitt County activates the alert notification sirens upon instruction from IEMA. The

county prepares messages, provided in the annexes, to be sent out over the EAS, once

approved by IEMA.

13.3.3.6.2 Regulatory Evaluation

In Section 1.1 of the EGC ESP Emergency Plan, the applicant stated that it developed the EGC

ESP Emergency Plan to comply with the requirements of 10 CFR 52.17, using the guidance in

13-30
Supplement 2. In Section 1.2, "Planning Standards and Evaluation Criteria," of the EGC E'iP

Emergency Plan, the applicant stated that the EGC ESP Emergency Plan, in conjunction with

future implementing and administrative procedures, documents the methods by which the

applicant's emergency preparedness program meets the planning standards in 10 CFR

50.47(b) and the requirements in Appendix E to 10 CFR Part 50. The staff finds that the

applicant identified the regulatory requirements and guidance applicable to the proposed major

features of emergency plans for an ESP application.

In its review of the application, the staff considered the regulatory requirements in 10 CFR

52.17(b)(2)(i), 10 CFR 52.18, and Sections III and IV.D of Appendix E to 10 CFR Part 50.

Under 10 CFR 52.17(b)(2)(i), an applicant for an ESP may propose major features of

emergency plans for NRC review and approval, in consultation with FEMA, in the absence cf

complete and integrated emergency plans. Under 10 CFR 52.18, after consultation with FEMA,

the NRC will determine whether the major features of emergency plans submitted under

10 CFR 52.17(b)(2)(i) are acceptable. RS-002 and Supplement 2 provide guidance concerning

the review and evaluation of emergency planning information given in ESP applications.

Supplement 2 also provides specific evaluation criteria for major features of emergency plans,

including those that apply to major feature E, "Notification Methods and Procedures."

Major feature E calls for the applicant to describe the mutually agreeable bases for notifying

response organizations, consistent with the emergency classification scheme in Appendix 1 to

NUREG-0654/FEMA-REP-1, including the method for alerting, notifying, and mobilizing

personnel. The application should also describe the administrative and physical means for

notifying and promptly instructing the public within the 10-mile EPZ.

13.3.3.6.3 Technical Evaluation

The EGO ESP Emergency Plan and IPRA Volumes I and Vill describe a mutually agreeable

basis for the notification of response organizations that is consistent with the emergency

classification scheme set forth in Appendix 1 to Revision 1 of NUREG-0654/FEMA-REP-1.

These documents also describe a method for alerting, notifying, and mobilizing emergency

response personnel. In addition, the EGC ESP Emergency Plan and IPRA Volumes I and Vill

describe the administrative and physical means for notifying and promptly instructing the public

within the plume exposure pathway EPZ.

13.3.3.6.4 Conclusions

As discussed above, the applicant described the mutually agreeable bases for notifying

response organizations, that is consistent with Appendix 1 to NUREG-0654/FEMA-REP-1, arid

includes the method for alerting, notifying, and mobilizing personnel. In addition, the applicant

described the administrative and physical means for notifying and promptly instructing the

public within the 10-mile EPZ. Based on its review, the staff concludes that the proposed major

feature E is consistent with the guidance in RS-002 and Supplement 2. Therefore, this feature

is acceptable and meets the requirements of 10 CFR 52.17(b)(2)(i), 10 CFR 52.18, and

Sections III and IV.D of Appendix E to 10 CFR Part 50, insofar as it describes the essential

elements of advanced planning that the applicant considered for notification methods and

procedures, as set forth above. EGC provided other information in the application that is

13-31
outside the scope of the staff's review of this feature and is not discussed in this SER.

Therefore, the staff did not make findings regarding its acceptability.

13.3.3.7 Emergency Communications (Major Feature F)

13.3.3.7.1 Technical Information in the Application

Section 6.1, "Communications/Notifications," of the EGC ESP Emergency Plan states that, for

the EGC ESP facility, the applicant will-maintain the capability to make initial notifications to the

designated offsite agencies on a 24-hour-per-day basis. The offsite notification system,

referred to as the NARS, is a dedicated communications system that links the facility control

room, EOF, TSC, and State and local authorities. Facsimile and commercial telephone lines

will back up the NARS. State and county warning points will be continuously staffed. In

addition, the applicant has established several dedicated communication systems that will

ensure reliable and timely exchange of information necessary to the effective command and

control of any emergency response. This includes information (1) between EGC and State and

local agencies within the EPZs, (2) between EGC and the Federal EROs, (3) between the plant,

the EOF, and the State and county EOCs, and (4) between the emergency response facilities

(ERFs) and field monitoring teams. In addition, facility communication links will exist to ensure

appropriate information transfer capabilities during an emergency. The facility may also use PA

systems, facility radios, and pagers to augment its communication capabilities.

Sections 3A(3), 3A(8), and 4A of IPRA Volume I identify NARS as the primary source of

communications among the ESP site, State agencies, and local governments. Commercial

telephones will be used for confirmation. No State, other than Illinois, is located within the EPZ

of the EGC ESP site.

Section 2G," DeWitt County, Communications," in IPRA Volume VIII specifies the

communications systems utilized by DeWitt County (NARS and telephone). Annexes 2A, 2B,

2C, 2D, 2E, and 2F of IPRA Volume VIII specify the communications systems used by DeWitt

County, the risk municipalities, and the support counties.

Section 6.3, "USNRC Communications (Emergency Notification System and Health Physics

Network)," in the EGC ESP Emergency Plan states that the applicant will install dedicated

telephone equipment between the EGC ESP facility's control room and the NRC, with an

extension of that line into the TSC. The EOF will have available a separate line capable of

being patched into the facility through the NRC. The NRC will use this line for event

notifications and status updates.

A separate dedicated telephone, the health physics network, will also be available to convey

health physics information to the NRC from the TSC and EOF, as requested. This telephone

can also be used as an open line. The NRC will direct the installation and the use of its own

telephones as indicated in Figure 6.1-3, "USNRC Communications for Nuclear Response."

Section 6.1.8, "Emergency Response Data System," of the EGC ESP Emergency Plan states

that the Emergency Response Data System (ERDS) will supply the NRC with selected plant

data points on a near-real time basis. The ERO will activate the ERDS as soon as possible, but

no later than 1 hour after declaration of an alert, a site area emergency, or a general

13-32
emergency. The selected data points will be transmitted via modem to the NRC at

approximately 1-minute intervals.

Section 2B of IPRA Volume I lists some of the Federal agencies that may be needed in the

event of an incident at a nuclear plant. Section 3A(8) of IPRA Volume I describes the duties of

IDNS ir, an emergency, including the responsibility for contacting the appropriate Federal

agenciEs whenever an accident more severe than an alert is reported. Section 3A(8) also

references the FRERP and Radiological Assistance Program. In RAI 13.3-13(c), the staff

requested a description of the provisions for prompt communications between the Federal and

State EROs. In response to RAI 13.3-13(c), the applicant stated that Section Fl (1), "Overview,

Operations Centers, State Emergency Operations Center," and Section 2B of IPRA Volume 1

describe the provisions for communications between the Federal and State EROs. Section DA,

"Preparedness Functions, Exercises and Drills," of IPRA Volume I and Section I C of IPRA

Volume VilI also discuss these communications provisions. Section 3A(8) of IPRA Volume I

indicates that the Radiation Emergency Assistance Center (REAC) will contact the Federal

agencies, and Section 3B of IPRA Volume I states that the Governor or his designee is

authorized to request Federal assistance.

The applicant stated that the shift manager will be responsible for initiating a call-out to activate

the ERC. The applicant will use an automated notification system to rapidly notify members of

the ERC. The system, in use at the CPS and planned for use at the EGC ESP facility, consists

of a computer with modem equipment capable of initiating and receiving telephone calls. When

contact is made, the system will automatically request security identification and then respond.

The system will call the paging system vendor. The pager vendor's system will accept group

and individual numbers from the ERO notification system, activating several radio transmitters

that in turn will activate personal pagers belonging to members of the ERO. The system will

incorporate redundant power, phone, and computer components with geographic separation.

Implementing procedures will specify the course of action to be taken, should the ERO

notification system fail. In case of system failure, facility personnel will manually activate the

ERO group page feature and/or directly call-out key emergency response personnel.

Section '3A of IPRA Volume I contains a list of State agencies and gives details of the

notification process for their staffs.

Sections 1 C and 1D of IPRA Volume Vill state that DeWitt County receives initial notification

from IEMA via NARS and notifies the risk municipalities and support counties. Annexes 2A, 2B,

2C, 2D, 2.E, and 2F of IPRA Volume VilI detail the emergency personnel notification procedures

of DeWitt County, local municipalities, and support counties.

Section 6.4, "Medical Communications," of the EGC ESP Emergency Plan states that

communications will be established with the primary and backup medical hospitals described in

Section 1:2.1, "Off-site Hospital and Medical Services," of the plan. Facility personnel will

establish Communications with medical transportation services via commercial telephone lines.

Section 3A(9), "Agency Responsibilities, State Agencies, Public Health," of IPRA Volume I

describes the Illinois Department of Public Health (IDPH) communications as relying on an

emergency management system using radio, telephone, or telemetry. The system links the

IDPH to hospitals, ambulances, and other emergency vehicles.

13-33
Section 2G and Annexes 2A, 2B, 2C, 2D, 2E, and 2F of IPRA Volume Vil state that the John

Warner Hospital representative at the DeWitt County EOC is responsible for communicating

with the hospital.and arranging for ambulance support (Annex 2B), although the means of

communication are not specified. The DeWitt County EOC will coordinate medical support for

risk counties and municipalities.

13.3.3.7.2 Regulatory Evaluation

In Section 1.1 of the EGC ESP Emergency Plan, the applicant stated that it developed the plan

to comply with the requirements of 10 CFR 52.17, using the guidance in Supplement 2. In

Section 1.2 of the EGC ESP Emergency Plan, the applicant stated that the EGC ESP

Emergency Plan, in conjunction with future implementing and administrative procedures,

documents the methods by which the applicant's emergency preparedness program meets the

planning standards in 10 CFR 50.47(b) and the requirements in Appendix E to 10 CFR Part 50.

The staff finds that the applicant identified the regulatory requirements and guidance applicable

to the proposed major features of emergency plans for an ESP application.

In its review of the application, the staff considered the regulatory requirements in 10 CFR

52.17(b)(2)(i), 10 CFR 52.18, and Sections III, IV.A, and IV.E of Appendix E to 10 CFR Part 50.

Under 10 CFR 52.17(b)(2)(i), an applicant may propose major features of emergency plans for

NRC review and approval, in consultation with FEMA, in the absence of a complete and

integrated emergency plan. Under 10 CFR 52.18, after consultation with FEMA, the NRC will

determine whether the major features of emergency plans submitted under 10 CFR

52.17(b)(2)(i) are acceptable. RS-002 and Supplement 2 provide guidance concerning the

review and evaluation of emergency planning information given in an ESP application.

Supplement 2 also provides specific evaluation criteria for major features of emergency plans,

including those that apply to major feature F, "Emergency Communications."

Major feature F calls for the applicant to identify communication provisions with State and local

governments within the EPZs, with Federal EROs, and with fixed and mobile medical support

facilities. The application should also describe provisions for alerting and activating emergency

personnel.

13.3.3.7.3 Technical Evaluation

The staff reviewed the applicant's response to RAI 13.3-13(c) and found it to be acceptable

based on the evaluation below.

The communication plans for emergencies described in the EGC ESP Emergency Plan and

IPRA Volumes I and Vill have provisions for communications among contiguous State/local

governments within the EPZ, and, as needed, with Federal EROs. In addition, these

communication plans for emergencies have provisions for alerting and activating emergency

personnel in each response organization. Finally, the plans describe the communication

arrangement for fixed and mobile medical support facilities.

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13.3.3.7.4 Conclusions

As discussed above, the applicant identified communication provisions with State and local

governments within the EPZs, with Federal EROs, and with fixed and mobile medical suppoit

facilities. In addition, the applicant described provisions for alerting and activating emergency

personnel. Based on its review, the staff concludes that the proposed major feature F is

consistent with the guidance in RS-002 and Supplement 2. Therefore, this feature is

acceptable and meets the requirements of 10 CFR 52.17(b)(2)(i), 10 CFR 52.18, and

Sections Ill, IV.D, and IV.E of Appendix E to 10 CFR Part 50, insofar as it describes the

essential elements of advanced planning that the applicant considered for emergency

communications, as set forth above. EGC provided other information in the application that is

outside the scope of the staff's review of this feature and is not discussed in this SER.

Therefore, the staff did not make findings regarding its acceptability.

13.3.3.6 Public Education and Information (Major Feature G)

13.3.3.8.1 Technical Information in the Application

Section 7.1, 'Public Information Publication," of the EGC ESP Emergency Plan explains that the

State has an overall responsibility to maintain a continuing disaster preparedness public

education program. Section 7.1 also states that the emergency public information publication

for the applicant's generating facilities is and will be updated annually, in coordination with State

and county agencies, to address how the general public is notified and what their actions

should be in an emergency. The applicant also stated that it will distribute the EGC ESP sitespecific publication on an annual basis by mail to residents.within the 10-mile plume exposure

pathway EPZ, as well as to appropriate locations where the transient population may obtain a

copy.

Section 7.2, "Public Education Materials," of the EGC ESP Emergency Plan states that public:

information publications will instruct members of the public to go indoors and turn on their

radios when they hear the alert notification sirens operating. These publications will also

identify the local radio stations that the public should listen to for emergency-related

information.

Sections 7.1 and 7.2 of the EGC ESP Emergency Plan state that the public information

publication will include educational information on radiation, a description of the events that

require public notification and what to do if a "take shelter" or "evacuate" recommendation is

given, a rnap of major evacuation routes, a list of communities likely to serve as host shelter

areas, and instructions on how to obtain additional information, especially for the disabled or

their caretakers and those without transportation. In addition, the publication will include an

address, telephone number, and email address to contact for further information. In

RAI 13.3-7, the staff requested that the applicant provide the respiratory protection information

included in its emergency information program. In its response to RAI 13.3-7, the applicant

stated that the public information publications for CPS currently provide respiratory protection

information. These publications address respiratory protection information by providing general

radiation information, actions to be taken for a "shelter-in-place" recommendation, and contacts

for additional information. The current "shelter-in-place" actions include the following

13-35
statements regarding respiratory protection (i.e., protective measures) consistent with

Section 5.5.2 of the EGC ESP Emergency Plan:

Go indoors and stay there. Close all doors and windows and shut off any

systems that draw in outside air, such as furnaces, fireplaces and air

conditioners.

As indicated in Section 16.4, "Emergency Plan and Agreement Revisions," of the EGC ESP

Emergency Plan, when an application for a COL references the EGC ESP Emergency Plan

pursuant to Subpart C, "Combined License," of 10 CFR Part 52, "Early Site Permits; Standard

Design Certifications; and Combined Licenses for Nuclear Power Plants," it is anticipated that

the application will incorporate the EGC ESP Emergency Plan into the EGC nuclear

standardized radiological emergency plan in effect at that time, including, in an appropriate

annex, the addition of plant-specific information associated with the EGC ESP facility. Along

with the adoption of the EGC nuclear standard radiological emergency plan, the COL facility will

adopt consistent public information publications and distribution practices.

Section 5C, "Public Information," of IPRA Volume I describes a program whereby the State of

Illinois, the operating utilities, and the affected county governments distribute information

booklets on an annual basis. The State coordinates this activity with the utility as described in

Section 7.1 of the EGC ESP Emergency Plan. The public information booklets entitled,

"Emergency Information," are distributed by mail to the public residing within the 10 -mile EPZ.

Utility billing records or zip codes are used to compile distribution lists and are updated

annually. In addition to direct mailing, booklets are available to transients and EPZ visitors at

area motels, health care facilities, recreational areas, and other public areas.

Section 2K, "DeWitt County, Public Information Considerations," in IPRA Volume ViII indicates

that the emergency information booklet includes instructions on how to obtain additional

information, instructions to follow if shelter-in-place or evacuation is recommended, educational

information concerning radiation, a map of major evacuation routes, and a list of communities

that are likely to serve as host communities for evacuees. The booklet also contains

information that is used to identify persons within the EPZ who have special concerns related to

their ability to follow protective actions. These special concerns include hearing and walking

difficulties, transportation issues, and special medical needs.

Section 7.5, "Media Orientation," of the EGC ESP Emergency Plan states that the applicant's

Midwest Regional Operating Group (MWROG) Emergency Preparedness Department, in

conjunction with the Communications and Public Affairs Department, will annually provide the

applicable news media with information concerning the emergency plan, radiation, and points of

contact for release of public information in an emergency.

Section 5D, "Public Information, Media Education," in IPRA Volume I and Section 2K in IPRA

Volume VIII describe the program for acquainting the media with the emergency plans,

information concerning radiation, and points of contact for release of public information in an

emergency. To acquaint the news media with the IPRA, information is provided annually to the

media in the vicinity of each nuclear power station. Information is provided by a briefing

session, participation in an IPRA exercise, or a mailing of informational material. Any one of

these three methods provides information on the IPRA concept of operations, accident

13-36
classification scheme, communications, protective actions, parallel actions, public informatic'n,

and the! EPZ.

In RAI 13.3-13(d), the staff requested a description of the State and local programs for

acquainting news media with emergency plans, information concerning radiation, and points of

contact for the release of public information in an emergency. In response to RAI 13.3-13(d),

the applicant stated that Section 5D in IPRA Volume 1 provides a description of the State arid

local programs for acquainting news media with emergency plans, information concerning

radiation, and points of contact for the release of public information in an emergency.

13.3.3.8.2 Regulatory Evaluation

In Section 1.1 of the EGC ESP Emergency Plan, the applicant stated that it developed the plan

to comply with the requirements of 10 CFR 52.17, using the guidance in Supplement 2. In

Section 1.2 of the EGC ESP Emergency Plan, the applicant stated that the EGC ESP

Emergency Plan, in conjunction with future implementing and administrative procedures,

documents the methods by which the applicant's emergency preparedness program meets the

planning standards in 10 CFR 50.47(b) and the requirements in Appendix E to 10 CFR Part 50.

The staif finds that the applicant identified the regulatory requirements and guidance applicable

to the proposed major features of emergency plans for an ESP application.

In its review of the application, the staff considered the regulatory requirements in 10 CFR

52.17(b)(2)(i), 10 CFR 52.18, and Sections 1II, IV.B, IV.D, IV.E, and IV.F of Appendix E to

10 CFR Part 50. Under 10 CFR 52.17(b)(2)(i), an applicant for an.ESP may propose major

features of emergency plans for NRC review and approval, in consultation with FEMA, in the

absence of complete and integrated emergency plans. Under 10 CFR 52.18, after consultation

with FEMA, NRC will determine whether the major features of emergency plans submitted

under 10 CFR 52.17(b)(2)(i) are acceptable. RS-002 and Supplement 2 provide guidance

concerning the review and evaluation of emergency planning information given in an ESP

application. Supplement 2 also provides specific evaluation criteria for major features of

emergency plans, including those that apply to major feature G, "Public Education and

Information."

Major feature G calls for the applicant to describe a program to provide information to the public

and news media on a periodic basis. The program should address how the applicant would

notify the public, including what actions they would take in an emergency, and the applicant's

means fcr acquainting the news media with emergency information.

13.3.3.8.:3 Technical Evaluation

The staff reviewed the applicant's responses to RAls 13.3-7 and 13.3-13(d) and found them to

be acceptable based on the evaluation below.

The EGC ESP Emergency Plan and IPRA Volumes I and Vil describe programs to provide a

coordinated dissemination of information to members of the public on a periodic basis (at least

annually) regarding how they will be notified and what their actions should be in an emergency.

The programs described in State and local emergency plans include information on the

following:

13-37
* educational information on radiation

* contact for additional information

* protective measures (e.g.,-evacuation routes, relocation centers, and sheltering)

* special needs of the handicapped, transient population, and special facilities

The EGC ESP Emergency Plan and IPRA Volumes I and VIII adequately describe a program

for acquainting the news media on a periodic basis (at least annually) with emergency plans,

information concerning radiation, and points of contact for release of public information in an

emergency.

13.3.3.8.4 Conclusions

As discussed above, the applicant described a program to provide information to the public and

news media on a periodic basis, that addresses public notification and emergency actions.

Based on its review, the staff concludes that the proposed major feature G is consistent with

the guidance in RS-002 and Supplement 2. Therefore, this feature is acceptable and meets the

requirements of 10 CFR 52.17(b)(2)(i), 10 CFR 52.18, and Sections III, IV.B, IV.D, IV.E, and

IV.F of Appendix E to 10 CFR Part 50, insofar as it describes the essential elements of

advanced planning that the applicant considered for public education and information, as set

forth above. The applicant provided other information in the application that is outside the

scope of the staff's review of this feature and is not discussed in this SER. Therefore, the staff

did not make findings regarding its acceptability.

13.3.3.9 Emergency Facilities and Equipment (Major Feature H)

13.3.3.9.1 Technical Information in the Application

Section 8.1.2, 'Technical Support Center," of the EGC ESP Emergency Plan states that a TSC

will be established for use during emergency situations by facility management, technical, and

engineering support personnel. The TSC will be activated for emergencies classified as an

alert or higher. Activation for other events will be optional. When activated, the TSC functions

will include the following:

* supporting the control room's emergency response

* performing the nondelegable functions when in command and control

* continually evaluating event classification

* assessing the plant status and potential offsite impact

* coordinating emergency response actions

* notifying appropriate corporate and station management

* providing notification and update information to the NRC via the emergency notification

system (ENS), including activation of ERDS

The TSC will be the onsite location used to support the control room for assessment of plant

status and potential offsite impact, as well as for the implementation of emergency actions. The

TSC will provide technical data and information to the EOF.

The TSC will provide reliable voice communications to the control room, operations support

center (OSC), EOF, the NRC, and State and local EOCs. In addition, the TSC will provide

13-38
facsimi'e transmissions capability, as described in Chapter 6, "Emergency Communications," in

the EGO ESP Emergency Plan.

The TSC will be sized for a minimum of 25 spaces and supporting equipment. Of the

25 spaces, 5 will be reserved for the NRC, and adequate space will be available for the

appropriate State representative(s). Under accident conditions, personnel in the TSC will be

protected from radiological hazards, including direct radiation and airborne contaminants, with

similar radiological habitability as the control room personnel. To ensure adequate radiological

protection, permanent radiation monitoring systems will be installed in the TSC and/or periodic

radiation surveys will be conducted. These systems will be used to indicate radiation dose

rates and airborne radioactivity inside the TSC. In addition, protective breathing apparatus

(full-face air purifying respirators) and potassium iodide (KI) will be available for use as

required. The TSC will have access to a complete set of as-built drawings and other records,

including general arrangement diagrams, piping and instrumentation drawings, and the

electrical schematics. The TSC will have the capability to record and display vital plant data: in

real time, to be used by knowledgeable individuals responsible for engineering and

management support of reactor operations and for implementation of emergency procedures.

Section 8.1.3, "Operations Support Center," in the EGC ESP Emergency Plan states that facility

support personnel will report to the OSC, an onsite location used during an emergency.

Assignments or duties will be dispatched in support of emergency operations. The OSC will be

activated whenever the TSC is activated, but the OSC need not remain activated at the alert

level, if the station emergency director judges it to be unnecessary. At the site area and

general emergency levels, the OSC or an alternate OSC will be activated at all times.

Activation for other events will be optional. Station disciplines reporting to the OSC will include,

but not be limited to, the following:

* operating personnel not assigned to the control room

* radiation protection personnel

* chemistry personnel

* maintenance personnel (mechanical, electrical, and instrumentation and control)

The OSCO will be equipped with communication links to the control room, TSC, and EOF, as

described in Chapter 6 of the EGC ESP Emergency Plan. A limited inventory of supplies will be

kept in the OSC. This inventory will include respirators, protective clothing, flashlights, and

portable survey instruments.

Sections 8.1.2 and 8.1.3 of the EGC ESP Emergency Plan provide brief, general statements

and do not give facility-specific or equipment-specific information. In RAI 13.3-12, the staff

requested that the applicant discuss the extent that it intended the application for an ESP to

address evaluation criteria V.H.1 and V.H.2 of Supplement 2 for the TSC, OSC, and EOF for an

ESP, including whether it intended the application to address NUREG-0696, "Functional Criteria

for Emergency Response Facilities-Final Report," dated February 1981. In addition, the staff

asked the applicant to state whether EGC intends to utilize the existing TSC, OSC, and EOF,

which support CPS, for the ESP site. In response to RAI 13.3-12, the applicant stated that the

EGC ESFP Emergency Plan addresses evaluation criterion V.H.1 of Supplement 2 in

Section 8.1, which provides the full ESP discussion of the major features of the TSC and OSC,

including the NUREG-0696 criteria applicable for a major features discussion. Because the

13-39
COL application is expected to reference a certified design that has already addressed the

details of the design of these facilities, EGC did not include them in the ESP application. The

specific designs vary; thus, providing these details in the ESP application could result in

discrepancies with the to-be-selected certified design. The COL application will address any

details not included in the combined to-be-referenced ESP and design certification document.

The EGC ESP facility does not intend to use the TSC or OSC that support the existing Clinton

unit and, thus, there will be no impact from the new facility on the existing CPS TSC and OSC.

Section 8.2, "Emergency Operations Facility," of the EGC ESP Emergency Plan addresses

evaluation criterion V.H.2 of Supplement 2. Section 8.2 provides a full discussion of the major

features of the EOF, including the NUREG-0696 criteria applicable for a major features

discussion. The applicant also stated that, as indicated in Section 8.2, the EGC ESP facility

intends to use the existing common EOF currently located in the EGC Cantera facility in

Warrenville, Illinois. This facility supports the existing Clinton unit, as well as other existing

units in Illinois, and has been previously evaluated against the NUREG-0696 criteria. Since the

EOF is already established to support numerous nuclear facilities, the only impact is

incorporating the appropriate documents and any necessary communication inputs. Thus,

including the EGC ESP facility in the existing EOF is expected to have minimal impact.

Completion of the activities will occur at the COL stage and these and other NUREG-0696

criteria can be readily confirmed by inspection at that time (consistent with the process utilized

for the previously licensed facilities).

Section 8.2 of the EGC ESP Emergency Plan states that the EOF will be the location where the

corporate emergency director will direct a staff to evaluate and coordinate the overall company

activities involved with an emergency. Activation of the EOF is mandatory upon declaration of

an alert or higher classification. The EOF will provide for the management of overall

emergency response, the coordination of radiological and environmental assessments, the

determination of recommended public protective actions, the management of recovery

operations, and the coordination of emergency response activities with Federal, State, and local

agencies. The common MWROG EOF is currently (i.e., in 2003) located in the applicant's

Cantera facility, west of Chicago, in Warrenville, Illinois. The EOF was designed with the

following considerations in mind:

* The location provides optimum functional and availability characteristics for carrying out

the overall strategic direction of the applicant's onsite and support operations,

determining public protective actions to be recommended to offsite officials, and

coordinating with Federal, State, and local organizations.

* The EOF is well engineered and of sufficient size to accommodate about 50 people.

* The EOF is equipped with reliable voice communications capabilities to the TSC, OSC,

control room, NRC, and State and local EOCs. In addition, the EOF has facsimile

transmission capability.

* Equipment is provided to gather, store, and display data needed in the EOF to analyze

and exchange information on plant conditions within the facility. The EOF technical data

system receives, stores, processes, and displays information sufficient to perform

13-40
assessments of the actual and potential onsite and offsite environmental consequences

of an emergency condition.

* The EOF has (and will have for the EGC ESP facility) ready access to plant records,

procedures, and emergency plans needed for effective overall management of the

applicant's emergency response resources.

Section 1 F(1), "Overview, Operations Centers," in IPRA Volume I fully describes the SEOC and

its use in directing and controlling response functions. The IPRA describes the role of IEMA. in

coordinating and directing response, the State agencies participating at the SEOC, agency

roles, physical characteristics of the facility, and communications systems. The SEOC

operations can also be conducted from the State forward command post (SFCP).

Sections 1C and 2E in IPRA Volume Vill describe the county and municipal emergency

response functions that take place at the DeWitt County EOC. Volume VilI of IPRA describes

the location and operation of the EOC in coordinating county and municipal response and in

coordinating with the SEOC or the SFCP.

13.3.3.9.2 Regulatory Evaluation

In Section 1.1 of the EGC ESP Emergency Plan, the applicant stated that it developed the plan

to comply with the requirements of 10 CFR 52.17, using the guidance in Supplement 2. In

Section 1.2 of the EGC ESP Emergency Plan, the applicant stated that the EGC ESP

'Emergency Plan, in conjunction with future implementing and administrative procedures,

documents the methods by which the applicant's emergency preparedness program meets the

planning standards in 10 CFR 50.47(b) and the requirements in Appendix E to 10 CFR Part 50.

The staff finds that the applicant identified the regulatory requirements and guidance applicable

to the proposed major features of emergency plans for an ESP application.

In its review of the application, the staff considered the regulatory requirements in 10 CFR

52.17(b)l'2)(i), 10 CFR 52.18, and Sections III, IV.B, and IV.E of Appendix E to 10 CFR Part 50.

Under 1 0 CFR 52.1 7(b)(2)(i), an applicant for an ESP may propose major features of

emergency plans for NRC review and approval, in consultation with FEMA, in the absence of

complete and integrated emergency plans. Under 10 CFR 52.18, after consultation with FEMA,

the NRC will determine whether the major features of emergency plans submitted under

10 CFR 52.17(b)(2)(i) are acceptable. RS-002 and Supplement 2 provide guidance concerning

the review and evaluation of emergency planning information given in an ESP application.

Supplemant 2 also provides specific evaluation criteria for major features of emergency plans,

including the criteria that are apply to major feature H, "Emergency Facilities and Equipment."

Major feature H calls for the applicant to describe a TSC, onsite OSC, and EOF, in accordance

with the guidance in NUREG-0696. The following are the general guidance criteria from

NUREG-0696 for these facilities:

The TSC is an onsite facility located close to the control room that shall provide plant

management and technical support to the reactor operating personnel located in the

control room during emergency conditions. It shall have technical data displays and

plant records available to assist in the detailed analysis and diagnosis of abnormal plant

13-41
conditions and any significant release of radioactivity to the environment. The TSC shall

be the primary communications center for the plant during an emergency.

* The OSC is an onsite assembly area separate from the control room and the TSC

where licensee operations support personnel shall report to in an emergency. There

shall be direct communications between the OSC and the control room, and between

the OSC and the TSC, so that the personnel reporting to the OSC can be assigned to

duties in support of emergency operations.

* The EOF is a near-site support facility for the management of the overall licensee

emergency response (including coordination with Federal, State, and local officials),

coordination of radiological and environmental assessments, and determination of

recommended public protective actions. The EOF shall have appropriate technical data

displays and plant records to assist in the diagnosis of plant conditions to evaluate the

potential or actual release of radioactive materials to the environment.

In addition, major feature H calls for the ESP application to describe an EOC for each offsite

organization for use in directing and controlling response functions.

13.3.3.9.3 Technical Evaluation

The staff finds that the ESP application adequately describes the State and local EOCs for use

in directing and controlling response actions.

In Sections 8.1.2, 8.1.3, and 8.2 of the EGC ESP Emergency Plan, the applicant provided

general descriptions of the OSC, TSC, and EOF and equipment. With regard to the applicant's

response to RAI 13.3-12, the applicant did not address the adequacy of the facilities and

related equipment in support of emergency response. In addition, the applicant did not

address, with specificity, such facility and equipment details such as location, size, structure,

function, habitability, communications, staffing and training, radiological monitoring,

instrumentation, data system equipment, power supplies, technical data and data systems, and

record availability and management. In Open Item 13.3-3, the staff identified the need for

additional specific information related the OSC, TSC, and EOF. In its submission to the NRC

dated April 26, 2005, the applicant responded to Open Item 13.3-3. The applicant stated that

as indicated in its response to RAI 13.3-12, the EGC ESP addresses evaluation criterion V.H.1

of Supplement 2 to NUREG-0654/FEMA-REP-1 in Section 8.1 of the emergency plan and

provides the EGC ESP discussion of the major features of the TSC and OSC. Because the

COL application is expected to reference a certified design that has already addressed the

details of the design of these facilities, the ESP does not include these details. The specific

designs vary; thus, providing these details in the ESP could result in discrepancies with the tobe-selected certified design. The COL application will address any details not included in the

combined to-be-referenced ESP and design certification document.

Similarly, Section 8.2 of the EGC ESP Emergency Plan provides the discussion of the

major features of the EOF to address evaluation criterion V.H.2 of Supplement 2 to

NUREG-0654/FEMA-REP-1. As indicated in Section 8.2, the EGC ESP facility intends to use

the existing common EOF currently located in the EGC Cantera facility in Warrenville, Illinois.

This facility supports the existing Clinton unit, as well as other existing units in Illinois, and has

13-42
been previously approved as an acceptable centralized EOF, as addressed in SECY-02-0033,

"Amergen's Request to Consolidate the Clinton Power Station Emergency Operations Facility

(EOF) into the Centralized EOF Operated by Exelon Generation Co.," and its associated

Commission staff requirements memorandum. Since the EOF is already established to support

numerous nuclear facilities, the only impact is incorporating the appropriate documents and any

necessary communication inputs. Thus, including the EGC ESP facility in the existing EOF is

expected to have minimal impact. Completion of the activities will occur at the COL stage arid

these and other NUREG-0696 criteria can be readily confirmed by inspection at that time

(consistent with the process utilized for the previously licensed facilities).

Based cn the additional information provided above, the staff considered the part of Open

Item 13.3-3 related to the EOF to be resolved. However, the applicant did not provide

sufficient information to resolve the portions of Open Item 13.3-3 related to the OSC and TSC.

13.3.3.9.4 Conclusions

As discussed above, the applicant did not describe in sufficient detail the facilities and related

equipment in support of emergency response for the OSC and TSC, as specified in RS-002

and Supplement 2. The applicant did not address, with specificity, such facility and equipment

details such as location, size, structure, function, habitability, communications, staffing and

training, radiological monitoring, instrumentation, data system equipment, power supplies,

technical data and data systems, and record availability and management for the OSC and

TSC. Based upon its review, the staff concludes that the proposed major feature H is not

consistent with the guidance in RS-002 and Supplement 2. Therefore, this feature is

unacceptable. EGC provided other information in the application that is outside the scope of

the staff's review of this feature and is not discussed in this SER. Therefore, the staff did nol

make findings regarding its acceptability.

13.3.3. 10 Accident Assessment (Major Feature I)

13.3.3.10.1 Technical Information in the Application

In Sections 3.1.1.1.7 and 9.1.3, "National Weather Service," of the EGC ESP Emergency Plan,

the applicant stated that meteorological information can be acquired and used through the

NWS. Available data will include existing and forecast wind directions, wind speed, and

ambient air temperature. Appendix A to the EGC ESP Emergency Plan identifies an

arrangement with Murray and Trettle, Inc., for meteorological support. In Section 5.3 of the

EGC ESP Emergency Plan, the applicant established, in conjunction with State and county

authorities, the contents of the initial notification message transmitted during a classified

emergency. Meteorological information contained in 'this message will include wind direction

and speed. Section 5.4 of the EGC ESP Emergency Plan states that followup messages will

also contain the same information as that provided in the initial notification message.

Section 9.2.3, "State Monitoring Capabilities," of the EGC ESP Emergency Plan explains that

the State of Illinois can currently dispatch its own field monitoring teams to track the airborne

radioactive plume. The State also has the ability and resources to coordinate with Federal and

utility monitoring teams to compare sample results. Appendix A to the EGC ESP Emergency

Plan includes letters confirming the State of Illinois commitment to implement IPRA.

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Sections 1 E and 3A(8) of IPRA Volume I explain that the State of Illinois, in the form of IDNS,

has the responsibility and resources to dispatch its own field monitoring teams to perform field

monitoring within the.plume exposure EPZ. The State also has the ability and resources to

coordinate with Federal and utility monitoring teams. Section 3A(8) also details the IDNS

response, that will deploy a radiological assessment field team (RAFT) to perform plume

exposure rate verification, air sampling, and sampling of food, water, milk, and other media. If

requested by IDNS, DOE and other Federal and State agencies may provide additional field

teams. The RAFT conducts field monitoring using suitable radiation detection instruments in

the downwind portion of the EPZ. The team analyzes samples in a mobile laboratory utilizing a

gamma spectroscopy system. The team is also responsible for the assessment of radioactive

plume pathways, and they direct other field teams in determining the composition and location

of the plume and in collecting of samples.

Sections 1 D, 2F, and 20, "DeWitt County, Radiological Considerations," of IPRA Volume VIII

state that IEMA is responsible for performing confirmatory accident assessment. This includes,

in part, deployment of field survey teams for radiation exposure monitoring and sample

collection.

Section 3.1.1.1.4 of the EGC ESP Emergency Plan states that, if the applicant or the State of

Illinois deemed assistance from DOE to be necessary or desirable, the State of Illinois would

notify the appropriate DOE operations office.

Section 1 E of IPRA Volume I explains that the State of Illinois has the responsibility and

resources to dispatch its own field monitoring teams to track the radioactive airborne plume.

The State also has the ability and resources to coordinate with Federal and utility monitoring

teams.

13.3.3.10.2 Regulatory Evaluation

In Section 1.1 of the EGC ESP Emergency Plan, the applicant stated that it developed the plan

to comply with the requirements of 10 CFR 52.17, using the guidance in Supplement 2. In

Section 1.2 of the EGC ESP Emergency Plan, the applicant stated that the EGC ESP

Emergency Plan, in conjunction with future implementing and administrative procedures,

documents the methods by which the applicant's emergency preparedness program meets the

planning standards in 10 CFR 50.47(b) and the requirements in Appendix E to 10 CFR Part 50.

The staff finds that the applicant identified the regulatory requirements and guidance applicable

to the proposed major features of emergency plans for an ESP application.

In its review of the application, the staff considered the regulatory requirements in 10 CFR

52.17(b)(2)(i), 10 CFR 52.18, and Sections III and IV.A, IV.B, IV.C, IV.D, and IV.E of

Appendix E to 10 CFR Part 50. Under 10 CFR 52.17(b)(2)(i), an applicant for an ESP may

propose major features of emergency plans for NRC review and approval, in consultation with

FEMA, in the absence of complete and integrated emergency plans. Under 10 CFR 52.18,

after consultation with FEMA, the NRC will determine whether the major features of emergency

plans submitted under 10 CFR 52.17(b)(2)(i) are acceptable. RS-002 and Supplement 2

provide guidance concerning the review and evaluation of emergency planning information

given in an ESP application. Supplement 2 also provides specific evaluation criteria for the

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major features of emergency plans, including those that apply to major feature 1, "Accident

Assessment."

Major feature I calls for the applicant to describe the methods, systems, and equipment for

assessing and monitoring actual or potential offsite consequences of a radiological emergency

condition. The applicant should also describe the capability and resources associated with

acquiring meteorological information and performing field monitoring, as well as contacts and

arrangements with offsite organizations (including Federal and State resources).

13.3.3.10.3 Technical Evaluation

In the E:GC ESP Emergency Plan, the applicant provided a description of the contacts and

arrangEments made with offsite organizations for acquiring and evaluating meteorological

information. The applicant also described how suitable meteorological data will be made

available to the State.

The EGC ESP Emergency Plan and IPRA Volumes I and VIII describe the contacts and

arrangements made for field monitoring within the plume exposure EPZ. The EGC ESP

Emergency Plan and IPRA Volume I describe contacts and arrangements to locate and trac'k

the airborne radioactive plume, using either or both Federal and State resources.

13.3.3.10.4 Conclusions

As discussed above, the applicant described adequate methods, systems, and equipment for

assessing and monitoring actual or potential offsite radiological consequences of a radiological

emergency condition at the ESP site, including associated contacts and arrangements. Based

on its review, the staff concludes that the proposed major feature I is consistent with the

guidance in RS-002 and Supplement 2. Therefore, this feature is acceptable and meets the

requirements of 10 CFR 52.17(b)(2)(i), 10 CFR 52.18, and Sections III, IV.A, IV.B, IV.C, IV.D',

and IV.E of Appendix E to 10 CFR Part 50, insofar as it describes the essential elements of

advanced planning that the applicant considered for accident assessment, as set forth above!.

EGC provided other information in the application that is outside the scope of the staff's review

of this feature and is not discussed in this SER. Therefore, the staff did not make findings

regarding its acceptability.

13.3.3.11 Protective Response (Major Features J)

13.3.3.1-1.1 Technical Information in the Application

Figure 2.2-1 of the EGC ESP Emergency Plan identifies three relocation centers, including the

Illinois State University field house, Monticello High School, and Richland Community College!.

These facilities provide multiple alternatives for relocating evacuated site personnel depending

on wind direction and other factors that may impede relocation of evacuated site personnel.

Figures 2.2-1 and 2.3-1, "Evacuation Routes to Relocation and Congregate Care Centers," of

the EGC ESP Emergency Plan show evacuation routes. Section 10.1.1, "Evacuation

Locations," of the EGC ESP Emergency Plan states that personal transportation, if available,

will normally be used. The applicant will identify personnel without transportation and provide

transportation, as necessary. In RAI 13.3-8, the staff requested that the applicant discuss the

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means it will use to transport visitors and nonessential personnel without transportation in the

event of a site evacuation. In response to RAI 13.3-8, the applicant stated that Section 10.1.1

of the EGC-ESP Emergency Plan discusses this: -Section 10.1.1 explains that visitors on site

will assemble with and follow the instructions of their escorts. Both visitors and nonessential

personnel will be transported by the same conveyance they were brought to the site, typically

by bus or personal vehicle. Determinations of personnel and visitors without vehicles can be

made at the assembly area, and these individuals provided transportation, as necessary (e.g.,

they could be paired with other nonessential personnel for evacuation from the site by personal

vehicle).

Section 10.1.3, "Evacuation," of the EGC ESP Emergency Plan states that evacuation will

commence in accordance with future EGC ESP facility procedures as directed by the

emergency director or his/her designee, unless one of the following conditions exists:

* Severe weather conditions threaten safe transport.

* A significant radiological hazard would be encountered.

* A security threat occurs that would have an adverse impact on the personnel while

leaving the site.

* A condition similar to these in magnitude occurs that, in the opinion of the station

emergency director, would adversely affect the site personnel.

Section 10.1.6, "Mechanism for Implementing Protective Action Recommendations," of the

EGC ESP:Emergency Plan discusses a mechanism for implementing protective action .

recommendations to the offsite agencies responsible for implementing protective actions for the

general public within the 10-mile EPZ. Section 10.2, "Protective Actions Recommendations," of

the EGC ESP Emergency Plan states that, for incidents involving actual, potential, or imminent

releases of radioactive material to the atmosphere, the U.S. Environmental Protection Agency's

(EPA) 400-R-92-001, "Manual of Protective Action Guides and Protective Actions for Nuclear

Incidents," dated May 1992 (hereafter referred to as EPA 400); Supplement 3 to

NUREG-0654/FEMA-REP-1, dated July 1996; and Volume 4 of the NRC's "Response

Technical Manual," Revision 4, dated March 1996 (hereafter referred to as RTM-96), will be

used as the basis for the general public protective action recommendations.

Section 6.0, "Analysis of Evacuation Times," of the 1993 ETE provides the results of the

analysis. The ETE analysis was conducted for peak populations under a variety of scenarios.

The applicant calculated the ETEs for winter weekday, winter weeknight, summer weekday,

and summer weekend. These scenarios were evaluated for normal and adverse weather

conditions in accordance with Revision 1 of NUREG-0654/FEMA-REP-1.

Section 1.2, "Site Location and Emergency Planning Zones (EPZ)," of the 1993 ETE provides a

description of the nuclear power plant's general location, and Figure 1.2, "EPZ Evacuation

Network," of the 1993 ETE is a map depicting the EPZ boundaries. Section 1.1, "General," of

the ETE generally discusses how the analysis was conducted. The applicant developed the

ETEs by using existing population data and the NETVAC computer simulation model.

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Figures 2.1-1 and 2.2-1 of the EGC ESP Emergency Plan show the plume exposure pathway

planning zone, EPZ subareas, evacuation routes, and relocation centers. In RAI 13.3-20(k),

the staff requested the applicant to clarify the location of the registration and congregate

care centers. The applicant responded to RAI 13.3-20(k) in its submission to the NRC

dated January 24, 2005. In its submission, the applicant stated that the three items

listed-Section 1.3 of the 1993 ETE, Map C of IPRA Volume Vill, and Figure 2.3-1 of the EGC

ESP Emergency Plan-all correctly specify locations for evacuated persons to gather, but each

use difierent terminology. The following table shows the differences in terminology used.

Source Terminology

1993 FETE Study Reception Centers

Map C: of IPRA Volume VilI Registration and Congregate Care Shelters

Figure 2.3-1 of the EGC ESP Emergency Registration and Congregate Care Centers

Plan

Because of the difference in terminology, the EGC ESP Emergency Plan will be revised to

reflect the terminology used in IPRA Volume Vil. For example, "registration and congregate!

care centers" will be revised to "registration and congregate care shelters," in Section 2.3.1, in

the title of Figure 2.3-1, and in Section 10.1.8.1, "Evacuation Routes and Destinations.'

Additionally, each source specifies evacuation locations that comply with the other sources,

except for one discrepancy. For example, the 1993 ETE study directs evacuees to reception

centers located in Bloomington (North), Champaign (East), Decatur (South), and Lincoln

(West), Illinois. Map C of IPRA Volume Vill shows congregate care shelters in each of these

cities. However, Figure 2.3-1 of the EGC ESP Emergency Plan only labels the following

registration and congregate care centers:

* I'SU Horton Field House (located in Bloomington, Illinois),

* Farkland College (located in Champaign, Illinois)

* Steven Decatur Middle School (located in Decatur, Illinois).

Therefore, Figure 2.3-1 of the EGC ESP Emergency Plan will be revised to include the

Lincoln Community High School as the registration and congregate care shelter for the

city of Lincoln,lllinois (west of EGC ESP site).

Sections 2.1 and 2.2 of the 1993 ETE describe the general assumptions, that include

automobile occupancy factors, method of determining roadway capacities, and method of

estimating populations.

The applicant used the computer model NETVAC to develop the ETEs. Sections 2.2 and 2.3 of

the 1993 ETE describe the methodology. Section 5.5 of the 1993 ETE also describes the

evacuation simulation and the structure and major features associated with NETVAC.

The 1993 ETE estimates permanent residents using 1990 census tract and block data.

Section 3.1, "Permanent Residents," and Tables 1.1, "Townships/Incorporated Areas Partially

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or Entirely within the Clinton EPZ," and 1.2, "Subareas within the Clinton EPZ," of the 1993 ETE

present the data. Census block maps of the EPZ were used to update and distribute the total

1990 population.within each township or incorporated area and sector. The distribution of the

total permanent resident population was based on land allocation using the detailed census

block maps. The 1993 ETE estimates 12,404 permanent residents in the CPS EPZ.

Section 2.3.2.1, "Permanent Population," of the 1993 ETE states that the resident population

within the plume exposure pathway EPZ is 12,358. Sections 3.1.1, "Auto-owning Permanent

Population," and 3.1.2, 'Transport-dependent Permanent Population," of the 1993 ETE

describe the assumptions regarding the auto-owning and transport-dependent populations.

The auto occupancy assumption for auto-owning and transport-dependent populations is one

vehicle per household.

In RAI 13.3-20(d), the staff requested that the applicant discuss the basis for neighbors and

State/local authorities contributing one vehicle per household for the transport-dependent

(nonauto-owning) population. The applicant responded to RAI 13.3-20(d) in its submission to

the NRC dated January 24, 2005. In its submission, the applicant stated that the DeWitt

County ESDA indicates that the transport-dependent residential population within the city of

Clinton will evacuate via buses provided by the city, plus assistance from auto-owning residents

(generally neighbors or relatives). The buses will evacuate residents from a designated set of

pickup locations in the city. The buses will evacuate residents from Clinton to the reception

center in Decatur. According to ESDA, the number of buses available should be able to

evacuate transport-dependent residents in a single pass. If residents arrive at pickup points

after the buses have departed, one or more buses would return to Clinton to evacuate any

remaining residents. It is assumed that the small number of transport-dependent residents in

other subareas will evacuate with assistance from neighbors or relatives. The 1993 study

assigned one vehicle per household for the entire residential population, including transportdependent households. The 1993 study also assumed the distribution of mobilization times for

the transport-dependent population to be the same as for the general residential population.

The analysis of evacuation times for special facilities the applicant provided in response to

RAI 13.3-20(c) indicates that the population of special facilities located in the city of Clinton will

mobilize and evacuate in less time than the general population. The ETEs for the general

population in Clinton are, therefore, considered representative (or conservative) for transportdependent residents.

Section 3.2, "Seasonal Residents," of the 1993 ETE also includes information on seasonal

residents, who are residents that reside in the area on a temporary basis. The applicant

obtained the seasonal residence (assuming three people per housing unit) from the

1990 census. The population was determined to be 54 people within the EPZ.

Section 3.3, 'Transient Population," of the 1993 ETE describes the transient population, that

includes people in the workforce, hotels/motels, and recreational areas. Tables 3.3, 'Transient

Population Distribution within the Clinton EPZ: Winter Weekday;" 3.4, "Transient Population

Distribution within the Clinton EPZ: Winter Weeknight;" 3.5, 'Transient Population Distribution

within the Clinton EPZ: Summer Weekday;" and 3.6, 'Transient Population Distribution within

the Clinton EPZ: Summer Weekend" present the total transient population. Appendix 1,

'Transient and Special Facility Population Data," to the 1993 ETE lists the transient population

and the corresponding facilities. The applicant estimated the transient population for each of

the scenarios evaluated (winter weekday, winter weeknight, summer weekday, summer

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weekend). For purposes of estimating the total number of vehicles associated with the

transient population segment, the applicant used an auto occupancy factor of 1 employee per

vehicle for all work places, except at CPS, where the applicant used an average occupancy

factor of 1.5 persons per vehicle. For the hotel/motel population, the applicant assumed that

there would be one vehicle per hotel/model unit. The applicant assumed three persons per

vehicle at all recreational facilities, except Little Galilee Christian Assembly Church Camp and

the Calvary United Pentecostal Christian Camp where buses are provided.

In RAI 13.3-20(s), the staff asked the applicant to explain why it assumed the automobile

occupancy rate to be different for CPS workers than that for other factories. The applicant

responded to RAI 13.3-20(s) in its submission to the NRC dated January 24, 2005. In its

submission, the applicant stated that site-specific information on automobile occupancy was

available for CPS, but was not readily available for other employers. In the absence of sitespecific information, a conservative default value of one person per vehicle was used to

estimate ETEs.

In addition, Section 2.3.2.3 of the EGC ESP Emergency Plan discusses changes to the

transient population since the 1993 ETE. The applicant developed the estimates used in the

ESP application from 2002 survey data. Table 2.3-2 of the EGC ESP Emergency Plan provides

a summary of the transient population included in the counts.

Section 13.3.1.1 of this SER discusses the applicant's analysis of the transient population

associated with the Apple and Pork Festival.

The 1993 ETE describes the special facility population in Section 3.4, "Special Facilities

Population," and Appendix 1. Tables 3.7, "Special Facilities Population -Distribution within the

Clinton EEPZ: Winter Weekday;" 3.8,"Special Facilities Population Distribution within the Clinton

EPZ: Winter Weeknight;" 3.9, "Special Facilities Population Distribution within the Clinton EF'Z:

Summer Weekday;" and 3.10, "Special Facilities Population Distribution within the Clinton EF'Z:

Summer Weekend" of the 1993 ETE also present the special facility population totals by sector

for all scenarios analyzed. The 1993 ETE assumes a vehicle occupancy factor for students of

60 persons per bus. The analysis also assumes the vehicle occupancy factor for hospitals,

nursing homes, and correctional facilities to be 40 people per bus.

In RAI 13.3-20(l), the staff asked the applicant to explain its assumed automobile occupancy

factors o: 60 students per bus and 40 residents per bus for special facility populations. The

staff asked the applicant to provide specific information regarding whether vans or ambulances

will be needed in addition to the buses. If vans and ambulances are needed, the applicant

should provide information on whether they are included in the vehicle estimate. The applicant

responded to RAI 13.3-20(l) in its submission to the NRC dated January 24, 2005. In its

submission, the applicant stated that the values of 60 students per bus for schools and

40 persons per bus for health care facilities were assigned based on information provided by

the county agencies. The use of buses versus vans is primarily a logistical issue, since one bus

is (for traffic purposes) equivalent to four autos, while a van, with roughly half the capacity of a

bus, is equivalent to two autos. For health care facilities (hospitals and nursing homes), one

ambulance (or wheelchair van) is assigned for every two nonambulatory patients or residents.

These vehicles have been included in the analysis for special facilities. Additional information

related to the analysis of special facility evacuation times is included in Attachment A, "Analysis

13-49
of Special Facility Evacuation Times," to the applicant's submission to the NRC dated

January 24, 2005.

In RAI 13.3-20(r), the staff asked the applicant to discuss the availability of buses and drivers

and the process for mobilizing the migrant worker and transport-dependant populations during

an evacuation, as well as whether these populations can be evacuated in a single trip or if

return trips are necessary. The applicant responded to RAI 13.3-20(r) in its submission to the

NRC dated January 24, 2005. In its submission, the applicant stated that the 1993 ETE study

did not include the migrant worker population (estimated at 65 persons). According to the

DeWitt County ESDA, most migrant workers are transported by bus. The buses generally

remain on site with the workers, and therefore, would be available for an evacuation. For the

1993 ETE study, the transport-dependent resident population was assigned the same trip

generation time distribution as the remainder of the resident population. According to the

DeWitt County ESDA, buses will be used to evacuate the transport-dependent residential

population in the city of Clinton. Adequate buses and drivers are available to accomplish the

evacuation of this population in a single trip, but return trips might be necessary if additional

people arrive at pickup locations after buses have departed.

Section 2.3.2.3 of the EGC ESP Emergency Plan also states that migrant farm workers are

included in the transient population statistics because of the nature of the farming in the region.

In RAI 13.3-20(t), the staff asked the applicant to provide trip generation times for the migrant

worker population and information on the automobile occupancy rate for migrant workers. The

applicant responded to RAI 13.3-20(t) in its submission to the NRC dated January 24, 2005. In

its submission, the applicant stated that the 1993 ETE study did not include the migrant worker

population (estimated at 65 persons). The county agencies do not consider these workers

transport dependent. If they were to be included in the NETVAC analysis, the standard

workforce mobilization time (30 to 60 minutes) would apply to these workers.

Section 2.3.2.3.1 of the EGC ESP Emergency Plan discusses changes to the special facility

population that have occurred since the 1993 ETE. The applicant developed the estimates

used in the ESP application from 2002 survey data. In RAI 13.3-20(q), the staff asked the

applicant to provide a reference for community college enrollment. The applicant responded to

RAI 13.3-20(q) in its submission to the NRC dated January 24, 2005. In its submission, the

applicant stated that it based the population estimates for Richland Community College

Extension in Clinton on numbers of classes and class size provided by the college. The college

currently provides up to 15 classes in the winter and spring, and 6 classes in the summer.

Each class has up to 15 students.

Section 5.1, "Evacuation Analysis Cases," and Table 5.1, "Clinton EPZ Analysis Areas," of the

1993 ETE describe the analysis areas for the time estimates. The applicant prepared time

estimates for the areas within 2 miles of the CPS, for 67.5-degree sectors from 0-5 miles and

0-10 miles from the plant, and for the entire Clinton plume exposure EPZ. Tables 6.1, 6.2, 6.3,

and 6.4 provide ETE data following a keyhole approach with a simultaneous evacuation of the

2-mile radius and combinations of three sectors for each condition. This approach is adequate

for determining the ETE.

Section 6.1 of the 1993 ETE describes the locations where queuing is likely to occur under the

various scenarios.

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Section 7.2, "Evacuation Traffic and Access Control Locations," of the 1993 ETE describes the

locations identified in the NETVAC simulation where traffic management personnel may be

necessary during the evacuation. In RAI 13.3-20(m), the staff requested that the applicant

provide information on whether passthrough traffic affects the roadway capacity and the ETE.

within the plume exposure pathway EPZ evacuation routes. The applicant responded to

RAI 13.3-20(m) in its submission to the NRC dated January 24, 2005. In its submission, the

applicant stated that the NETVAC simulations do not include any "background" or

"passthrDugh" traffic. At the start of the simulation, the network is free of traffic. The applicant

assumed that access control would prevent through traffic from entering the EPZ during the

evacuation.

In RAI 13.3-20(o), the staff asked the applicant to discuss the roadway characteristics, traffic

control measures, and area types that support the NETVAC model runs. The applicant

responded to RAI 13.3-20(o) in its submission to the NRC dated January 24, 2005. In its

submission, the applicant stated that no new NETVAC model runs were made for the ESP

application. The 1993 study report documents the roadway characteristics and area types used

in the analysis. (Attachment C, "Detailed NETVAC Output for Selected Scenarios," to the ECiC

submission also documents these parameters.) As explained in Section 2.4, the applicant

determined that the CPS ETE performed in 1993 is valid for current conditions. The NETVAC,

runs were made with existing (normal) traffic controls in effect. The applicant's response to

RAI 13.3-20(g) provides additional information related to traffic control measures.

Section 2.3.3 of the EGC ESP Emergency Plan describes the analysis conducted to test the

validity of the 1993 road network capacities and the currbrit state of the road network. The

applicant evaluated the EPZ zones for changes in the infrastructure, drove the principal

roadways, and conducted a direct comparison of some of the link evaluation routes and nodes.

The appl cant noted no major differences.

Figure 1.2 in the 1993 ETE shows the EPZ evacuation network and codes. The sector and

quadrant boundaries are numbered and are indicated on the map.

Section 4.0 and Appendix 3 to the 1993 ETE provide a description of the road network and th a

roadway network listing and capacities. The table in Appendix 3 indicates the evacuation route

segments and their characteristics, including capacity. In RAI 13.3-20(e), the staff requested

that the applicant clarify whether the characteristics for each segment analyzed in the

1993 ETE are for the narrowest section or bottleneck, if the roadway is not uniform. The

applicant responded to RAI 13.3-20(e) in its submission to the NRC dated January 24, 2005. In

its submission, the applicant stated that when roadway conditions are not uniform over the

length of a link, roadway dimensions (e.g., lane width, side width) represent the most restrictive

conditions over the link. In general, multiple links are used when a significant change in

roadway conditions is encountered (e.g., change in lane width, addition or deletion of a lane,

change in speed limit).

The NETVAC model input files in Appendix 3 to the 1993 ETE assign the area type (AT)

identified as "4," or "residential," for 100 percent of the EPZ. In RAI 13.3-20(n), the staff asked

the applicant to explain why the NETVAC model input files in Appendix 3 assign the AT

identified as "4," or "residential," for the entire plume exposure pathway EPZ. The applicant

responded to RAI 13.3-20(n) in its submission to the NRC dated January 24, 2005. In its

13-51
submission, the applicant stated that most of the EPZ is rural or residential. Three of the four

area types (central business district, fringe area, outlying business district) are characteristic of

larger cities or towns. If a roadway is used predominantly by through traffic, "residential" is the

appropriate classification for the link, even if the road traverses a business district. The links

and intersections in the center of Clinton, the largest city or town in the EPZ (population 7485),

are not considered to comprise a central business district.

Section 6.0 of the 1993 ETE provides the results of the analysis. The analysis for the

1993 ETE was calculated for peak populations under a variety of scenarios. The applicant

calculated ETEs for winter weekday, winter weeknight, summer weekday, and summer

weekend. The applicant evaluated each of these scenarios for normal and adverse weather

conditions, in accordance with Revision 1 of NUREG-0654/FEMA-REP-1.

Sections 2.2 and 2.3 of the 1993 ETE describe the method for computing the total evacuation

time. The time estimates are based on a time distribution of evacuation events. Section 5.4

and Figure 5.1 of the 1993 ETE describe the assumptions used for the evacuation preparation

times and departure distributions. Section 5.5 provides a description of the general structure

and major features associated with NETVAC.

However, to better understand the assumptions used in the methodology for developing the

distributions in Section 5.4, "Evacuation Preparation Times and Departure Distributions," of the

1993 ETE, the staff asked the applicant, in RAI 13.3-20(d), to provide site-specific data

regarding how many nonauto-owning households are in the plume exposure pathway EPZ.

The staff also asked the applicant to provide the methodology for determining the transportdependent population. In addition, the staff asked the applicant to provide an estimate of the

number of auto-owning residents versus transport-dependent residents, as well as information

on the initiation/mobilization time distribution for transport-dependent population.

The applicant responded to RAI 13.3-20(d) in its submission to the NRC dated January 24,

2005. In its submission, the applicant provided estimates of the number of auto-owning and

transport-dependent households by subarea for the EPZ, that are provided in Table B-1,

"Estimates of Transport-Dependent Population in Clinton Station EPZ," of Attachment B,

"Transport-Dependent Population," to the letter. The applicant also stated that Table B-1

summarizes the estimated number of transport-dependent households by subarea. The

number of transport-dependent households in the EPZ is 302. (According to the data provided

in Attachment B, the actual number is 301 instead of 302.) Most of these households are

located in the city of Clinton (in Subarea 7). The 2000 census (SF-3) tabulates the number of

vehicles per household; transport-dependent households were estimated based on the reported

number of occupied households with no vehicles. The applicant used the census data on

average household size and vehicles per household at the block group level to estimate values

for each subarea. The 1993 study assumed the distribution of mobilization times for the

transport-dependent population to be the same as for the general residential population. The

ETEs for the general population in Clinton are, therefore, considered representative (or

conservative) for transport-dependent residents.

Section 5.4 and Figure 5.1, "Notification/Departure/Mobilization Time Distributions," of the

1993 ETE describe the assumptions used for the evacuation preparation times and departure

distributions. The applicant did not provide or discuss distribution times for the transport13-52
depencent population. The mobilization distribution for hospitals and nursing homes is

considered to be the same as the distribution for the correctional facility. In RAI 13.3-20(d), the

staff asked the applicant to provide a separate estimate of the time required to evacuate the!

transport-dependent population and information on the initiation/mobilization time distribution for

transport-dependent population. The applicant responded to RAI 13.3-20(d) in its submission

to the NRC dated January 24, 2005. In its submission, the applicant stated that the 1993 study

assigned one vehicle per household for the entire residential population, including transportdependent households. The 1993 study also assumed the distribution of mobilization times for

the transport-dependent population to be the same as for the general residential population.

The ETEs for the general population in Clinton are, therefore, considered representative (or

conservative) for transport-dependent residents.

The NETVAC model is acceptable for analysis of traffic queue and identification of traffic

delays. Figure 1.2 of the ETE indicates the traffic queue locations. In RAI 13.3-20(u), the staff

asked the applicant to provide on-road travel and delay times, as well as the estimated number

of cars evacuating, for each segment. The applicant responded to RAI 13.3-20(u) in its

submission to the NRC dated January 24, 2005. In its submission, the applicant provided

detailed listings of NETVAC output for two evacuation scenarios (winter day adverse weather

and summer weekday fair weather) in Attachment C to the submittal. These listings indicate

the queue length and flow ("departures") by time step for each link in the roadway network. The

departures for exit nodes indicate the number of vehicles leaving the EPZ during each time

step.

Figure 5.1 of the 1993 ETE presents the notification and mobilization time distributions. In

RAI 13.'3-20(v), the staff asked the applicant to provide the percentage of the population as a

function of time, since the 1993 ETE does not include the additive reporting format for time

estimates when probability distributions are used. The applicant responded to RAI 13.3-20(v) in

its submission to the NRC dated January 24, 2005. In its submission, the applicant provided a

graph displaying the number of vehicles evacuating as a function of time for the winter day

adverse weather scenario as Figure C-1, "Predicted Rate of Vehicles Leaving the EPZ for

Winter Cay Adverse Weather," in Attachment C.

In RAI 1:3.3-16, the staff asked the applicant to provide a description of the method(s) used to

confirm evacuation and the estimated time required for confirmation of evacuation. In response

to RAI 13.3-16, the applicant stated that several methods are available for confirmation of

evacuation. One method is random sample telephone surveys with success based on the

number of positive responses (i.e., someone still at home) within the expected range. The time

required for such confirmation is dependent on the number of persons available to attempt

telephone contact and the number of homes to be sampled. These can be varied as desired,,

and, therefore, specific time estimates are not meaningful and have not been performed.

In RAI 13.3-14, the staff asked the applicant to provide the results of the review of the draft

ETE stucy by State and local organizations. In response to RAI 13.3-14, the applicant stated

that it conducted the 1993 ETE for the exclusive use of the State and local organizations in

developing their respective emergency plans. The results of the review state that the

draft ETE. represents a reasonable and reliable approach to the guidance detailed in

NUREG-0654/FEMA-REP-1. The results also state that, given the small population base within

the EPZ (i.e., a 10-mile radius of CPS), the projected evacuation time frames are appropriate in

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most instances and acceptable from an emergency preparedness and planning standpoint.

The applicant included each comment resulting in an adaptation of the ETE in the final version

of the ETE.

Figures 2.2-1 and 2.3-1 of the EGC ESP Emergency Plan show evacuation routes.

Figure 2.2-1 of the EGC ESP Emergency Plan identifies three relocation centers, including the

Illinois State University field house, Monticello High School, and Richland Community College.

Maps A, "Clinton Traffic and Access Control Map," and C, "Clinton Sheltering and Evacuation

Map," in IPRA Volume I show evacuation routes, sheltering and evacuation areas, and

relocation centers. The local plan described in IPRA Volume Vil contains maps indicating the

evacuation/sheltering areas and relocation centers. In RAI 13.3-13(e), the staff asked the

applicant to provide references to maps in the local emergency plans that show evacuation

routes. In response to RAI 13.3-13(e), the applicant stated that maps A through E in

Section 1 E of IPRA Volume Vill show the identified routes. In addition, Section 2J of IPRA

Volume VIII generally discusses evacuation.

Figure 2.3-2 of the EGC ESP Emergency Plan is a map showing population distribution around

the site with the information presented in sector format.

Section 1A, "General Information, Site Information," of IPRA Volume Vil states, "the 2000

permanent population within five miles of the CPS is 1,480.. .a projected total of 11,300 persons

living between five and ten miles...," resulting in a total of 12,780 for the entire EPZ. Figure 1,

"Clinton Station EPZ 2000 Permanent Residential Population Figures," in Section IA of IPRA

Volume Vil lists the total population as 13,268. In addition, Section 3C, "Shelter Guide, EPZ

Population," of IPRA Volume Vil lists the EPZ population by township, that also totals 13,268.

Section 5.2.1, "Onsite," of the EGC ESP Emergency Plan states that, when an emergency is

declared, reclassified, or terminated, an announcement will be made over the plant PA system

or by other means. If the EGC ESP facility is a dual unit, the unaffected unit control room will

be notified of the emergency declaration or change. The CPS control room will also be notified

of the emergency declaration or change. These notifications will include the declaration of the

emergency classification and response actions that site personnel are to take. In RAI 13.3-6,

the staff asked the applicant to discuss the means that it will use for notifying transient and

resident population in the owner-controlled area. In response to RAI 13.3-6, the applicant

stated that Section 5.2, "Notification and Mobilization of Emergency Response Personnel," of

the EGC ESP Emergency Plan does not address the means that will be used to notify transient

and resident population in the owner-controlled area because this section is intended to

address notification of the ERO personnel. However, the plant PA system and the siren

systems would also notify the non-ERO personnel in the owner-controlled area, including

transient and resident populations. Sections 5.5.1 and 10.1 of the EGC ESP Emergency Plan

also discuss the means that will be used to notify transient and resident population, including

sirens (both station alarms/siren system) and the alert notification system (ANS) and the EAS

(i.e., local radio stations).

Section 1G, "Overview, Notification of the Public," of IPRA Volume I outlines the system for

notification of the public. The primary system is an outdoor warning system (sirens), that

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county officials activate. Public announcements made over mobile PA systems can supplement

the sirens.

Section 2G(1)(b), "Clinton Power Station EPZ Siren Warning System," of IPRA Volume VilI

states, "When appropriate, the DeWitt County/Clinton ESDA Coordinator will initiate the

activation of the Clinton Power Station EPZ Siren Warning System." Section 2.1 references

Annexes 2A through 2E and Chapter 3, "Sheltering Guide," for the notification of special

facilities. Section 2P is the prescripted messages for mobile PA systems and local emergency

information radio stations. Annexes 2A through 2F in IPRA Volume Vill are the checklist

procedures for DeWitt County, the towns of Clinton, Weldon, and Wapella, DeWitt Village, and

the support counties, respectively. The support counties do not have responsibility for notifying

the EP2' population. The risk jurisdiction procedures specify the methods necessary for

notifying special facilities. The DeWitt County sheriff's procedures call for mobile PA systems

to be used if the sirens were to fail. The Clinton police department chief has a "mobile public

address warning scripts" attachment to the procedures.

Section 2A of IPRA Volume Vil states that the notification of the public will be through the CPS

EPZ prompt notification system and commercial radio. This prompt notification system consists

of a siren warning system throughout the CPS EPZ.

Section 5C of IPRA Volume I describes the public education material distributed annually. The

public information booklets are also used to identify persons who have special concerns

(e.g., the mobility impaired) related to their ability to follow protective actions that may be

recommended.

Attachment 1, "Department Assignments and Responsibilities," of Annex 2A in IPRA

Volume Vil identifies the Health Department administrator as being responsible for notifying

mobility-impaired individuals, assisting in the identification of nonambulatory patients, and

determining the total number of patients that would require transportation. Attachment 5,

"Clinton Power Station Special Facilities," of IPRA Volume Vil is a list of the agencies that are

responsible for contacting the facilities. The list includes recreational areas, schools, industries,

group homes for the developmentally disabled, medical facilities, day care centers, preschools,

and motels.

Attachment 4, "Mobility Impaired Individuals Shelter-in-place, Evacuation and Return

Instructions," of Annex 2B of IPRA Volume Vil is a town of Clinton checklist procedure for

notifying mobility-impaired individuals if shelter-in-place has been recommended. The checklist

also includes instructions for the evacuation and return of mobility-impaired individuals. The

same attachment is included in Annex 2C, "Weldon Checklist Procedures," for the town of

Weldon; Annex 2D, 'Wapella Checklist Procedures," for the town of Wapella; and Annex 2E,

"DeWitt V/illage Checklist Procedures," for DeWitt Village.

Section .2B, "Sheltering Guide, Protective Action Instructions," of IPRA Volume Vil is a set of

instructions for the county jail, mobility-impaired population, population with special

transportation requirements (both medical needs and transients), and school students.

Section 1 E(4), "Overview, Basic Functions, Protective Actions," of IPRA Volume Vil states the

following:

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When conditions warrant, IDNS will recommend that all facilities within the

1 0-mile EPZ that are incapable of timely evacuation (e.g., hospitals and nursing

homes) administer.potassium iodide (KI) to all individuals in the facility. IDNS will

also recommend at that time that emergency workers in the EPZ take KI....

Details of these steps are described in IDNS SOPs.

Section 20(3), "DeWitt County, Radiological Considerations, Potassium Iodide," of IPRA

Volume VilI states, "The recommendation to administer KI to emergency personnel and

immobile populations, if warranted, will normally be furnished to the DeWitt County DCO

[dosimetry control officer] by the IEMA Liaison for dissemination to affected departments and

municipalities." Section 1 D in IPRA Volume Vil discusses the response for State agencies that

have district or regional offices in the Clinton area. Annexes 2A though 2F in IPRA Volume VilI

detail the procedures for implementing the recommendation to administer KI.

Section 1 E(4) of IPRA Volume I states, "If evacuation is recommended, the public will be

advised to leave their homes and go to congregate care shelters located in host communities

where they may remain until it is safe to return to their homes." Section 1 E(4) also discusses

the proposed means of relocating the public.

Sections 2J and 3B, Annexes 2A through 2F, Appendix C, "Clinton Power Station EPZ

Evacuation Guide," and Maps A, "Clinton Traffic and Access Control Map," and C, "Clinton

Sheltering and Evacuation Map," of IPRA Volume Vil address the proposed means of

relocation. Buses, ambulances, and sheriff's department vehicles will be used for the mobilityimpaired population.

Appendix D, "Registration Centers and Congregate Care Shelters," to IPRA Volume Vil lists

the registration centers and congregate care shelters. Map C indicates the location of the

centers, that are more than 20 miles from the site. Section 1 C of IPRA Volume VIII gives

general information about the congregate care shelters, while Section 1 E, "General Information,

Maps," lists the maps. Appendix C to IPRA Volume Vil is a list of the host communities for

each subarea and the primary evacuation routes.

In RAI 13.3-13(f), the staff requested that the applicant describe the State and local

governments' concepts for using the traffic capacities of evacuation routes for implementing

protective measures. In response to RAI 13.3-13(f), the applicant stated that the 1993 ETE

(that does take into account the traffic capacities of the evacuation routes) is considered in the

planning process when establishing the boundaries of the subareas. For instance, during an

actual emergency, Illinois Department of Transportation (IDOT) representatives are available

in the SEOC and SFCP to provide up-to-the-minute information on road repairs and traffic

congestion. In addition, Section 3A(1 1), "Agency Responsibilities, State Agencies,

Transportation," of IPRA Volume I discusses IDOT's responsibilities. The County Highway

Department performs a similar function.

Section 1 E(4) of IPRA Volume I states, "traffic and access control procedures are utilized to

control traffic for all shelter-in-place and evacuation situations and to control access into

sheltered and evacuated areas." Section 3A(2), "Agency Responsibilities, State Agencies,

Illinois Commerce Commission," of IPRA Volume I details the Illinois Commerce Commission's

responsibilities. Section 3A(6), "Agency Responsibilities, State Agencies, Illinois Department of

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Military Affairs," of IPRA Volume I details the Illinois Department of Military Affairs'

responsibilities. Section 3A(7), "Agency Responsibilities, State Agencies, Illinois Department of

Natural Resources," of IPRA Volume I details the Illinois Department of Natural Resources'

(IDNR) responsibilities.

Section 1D of IPRA Volume Vil details the regional response of the State agencies, primarily in

the assistance of access control. Annexes 2A through 2F in IPRA Volume Vil provide details

of the assignment of traffic/access control to the sheriff's department and the checklists

associated with their activities. Appendix B, 'Traffic and Access Control Guide," to IPRA

Volume VIII lists the control posts and guidance (i.e., which direction to direct the traffic or

prevent the traffic from flowing). Map A shows all of the points in the EPZ.

Section 3A(6) of IPRA Volume I includes information for the Illinois Department of Military

Affairs and information concerning the use of wreckers and crews that can clear highways of

debris and vehicles. Section 3A(7) of IPRA Volume I includes information for the IDNR, as Nvell

as information on assisting the evacuation by accommodating evacuees who intend to camp

out or live in recreation vehicles on IDNR lands. Section 3A(1 1) of IPRA Volume I includes

information for the IDOT and information concerning the use of department resources to control

access to Federal and State highways.

Section 1 D of IPRA Volume Vil details the regional response of the State agencies, primarily in

the assistance of traffic and access control. Attachment 1 to Annex 2A in IPRA Volume I

assigns the highway engineer the responsibility to ensure evacuation routes are clear of snow,

obstacles, and debris. Annexes 2B through 2F to IPRA Volume I contain similar assignments in

each of the towns, that should be included in the ESP application references.

In RAI 13.3-13(g), the staff asked the applicant to describe the State and local organizations'

concepts for using ETEs when considering the evacuation of various sectors and distances. In

response to RAI 13.3-13(g), the applicant stated that IPRA does not directly address such

concepts. However, Section 3A(1 1) of IPRA Volume I discusses the IDOT responsibilities, that

include ensuring the expeditious and safe movement of traffic. The County Highway

Department performs a similar function. In addition, the planning process considers the 199:3

ETE when establishing the boundaries of the subareas. For instance, during an actual

emergency, IDOT representatives will be available in the SEOC and SFCP to provide up-to-theminute information on road repairs and traffic congestion.

Section n E(4) of IPRA Volume I states the following:

Protective actions include shelter-in-place, evacuation, traffic and access control,

and food, water, and milk control. Protective Action Guides (PAGs) are

projected personnel radiation dose values at which certain protective actions

should be implemented.... Plume exposure pathway PAGs are taken from the

"EPA Manual of Protective Action Guides and Protective Actions for Nuclear

Incidents."

In RAI 13.3-13(h), the staff asked the applicant to describe the IDNS standard operating

procedures (SOPs) relating to the basis for choosing a recommended protective action for the

plume. In response to RAI 13.3-13(h), the applicant stated that Section 2J i of IPRA

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Volume Vill provides this information. In addition, Section 1 E(4) of IPRA Volume I discusses

the basis for protective action recommendations.

Section 1 E(5)(b), "Overview, Basic Functions, Parallel Actions, Radiation Exposure Control," of

IPRA Volume I states the following:

Evacuees arriving at designated monitoring and decontamination centers

(generally co-located with primary congregate care facilities) will be monitored for

radioactive contamination and decontaminated, as necessary. The monitoring

and decontamination of evacuees, emergency workers and their vehicles will be

conducted by personnel under IDNS supervision, utilizing portal and hand-held

monitoring instruments and decontamination equipment provided by IDNS for

that purpose. Medical treatment, if required for a contaminated individual, will be

provided under the State's emergency medical services delivery system with

monitoring and decontamination support provided by IDNS staff.

Section 3C(1), "Agency Responsibilities, Private Organizations, American Red Cross," of I PRA

Volume I details the American Red Cross' responsibility to provide mass care services for the

evacuees and emergency workers. Its services will be provided in accordance with its current

policies and procedures (i.e., including a registration component).

Section 3A(8) of IPRA Volume I details the IDNS responsibilities, including the monitoring and

decontamination of evacuees.

Section 2J, paragraph 3.f, of IPRA Volume Vil states, "the local chapter of the American Red

Cross has the responsibility of registering all evacuees in congregate care shelters in the host

areas. Standard record keeping methodology will be used in registering evacuees."

Section 2J(4), "DeWitt County, Evacuation," paragraph 4, of IPRA Volume Vill states,

"provisions will be made for monitoring and decontamination of evacuees at host area

congregate care shelters."

13.3.3.11.2 Regulatory Evaluation

In Section 1.1 of the EGC ESP Emergency Plan, the applicant stated that it developed the plan

to comply with the requirements of 10 CFR 52.17, using the guidance in Supplement 2. In

Section 1.2 of the EGC ESP Emergency Plan, the applicant stated that the EGC ESP

Emergency Plan, in conjunction with future implementing and administrative procedures,

documents the methods by which the applicant's emergency preparedness program meets the

planning standards in 10 CFR 50.47(b) and the requirements in Appendix E to 10 CFR Part 50.

The staff finds that the applicant identified the regulatory requirements and guidance applicable

to the proposed major features of emergency plans for an ESP application.

In its review of the application, the staff considered the regulatory requirements in 10 CFR

52.17(b)(2)(i), 10 CFR 52.18, and Sections 1II, IV.A, IV.B, IV.D, and IV.E of Appendix E to

10 CFR Part 50. Under 10 CFR 52.17(b)(2)(i), an applicant for an ESP may propose major

features of emergency plans for NRC review and approval, in consultation with FEMA, in the

absence of complete and integrated emergency plans. Under 10 CFR 52.18, after consultation

with FEMA, the NRC will determine whether the major features of the emergency plans

13-58
submitted under 10 CFR 52.17(b)(2)(i) are acceptable. RS-002 and Supplement 2 provide

guidance concerning the review and evaluation of emergency planning information given in an

ESP application. Supplement 2 also provides specific evaluation criteria for the major features

of emergency plans, including those that apply to major feature J, "Protective Response."

Major feature J calls for the applicant to describe protective actions within the 10-mile EPZ for

the public and emergency workers, including evacuation routes, transportation, and handling of

evacuees. The application should identify guidance for the choice of protective actions,

consistent with Federal guidance, as well as the bases and mechanisms for recommending

protective actions to State and local authorities. The application should describe each

organization's concept for implementing protective actions and describe contacts and

arrangements with offsite agencies. In addition, the applicant should prepare an ETE for the

10-mile EPZ.

13.3.3.11.3 Technical Evaluation

The staff finds the clarifications provided by the applicant in response to RAls 13.3-20(e), (k),

(I), (n), (q), (s) to be acceptable. The staff finds that the additional information related to the

1993 ETE for Clinton provided by the applicant in response to RAls 13-3-20(m), (o), (r), (t) is

consistent with the guidance in Supplement 2 and is therefore acceptable. The staff finds the

addition al data and information provided by the applicant in response to RAls 13.3-20(d), (e),

(f), (g), (h), (u), (v), and RAls 13.3-6, 13.3-8, 13.3-14, and 13.3-16 are also consistent with the

guidance in Supplement 2 and are, therefore, acceptable.

The application adequately describes the evacuation routes and transportation for onsite

individuals to suitable offsite locations, including alternatives for inclement weather, high traffic

density, and specific radiological conditions.

The application describes a mechanism for recommending protective actions to the appropriate

State and local authorities, in accordance with EPA 400. The applicant references RTM-96.

However, the NRC developed this manual for use in providing licensee oversight in the eveni of

an emergency. Therefore, the staff did not consider the applicant's reference to RTM-96 in ius

review.

The application contains a vicinity map showing the plant location, along with a detailed map of

the plume exposure pathway EPZ. The map is legible and identifies transportation networks,

topographical features, and political boundaries.

The application includes all assumptions used in the analysis, that are automobile occupancy

factors, the method of determining roadway capacities, and the method of estimating

populations.

The application describes the method of analyzing the evacuation times and the algorithm used

and provides a source for obtaining further information or documentation. NETVAC is an

adequate model for use in ETE development. The applicant provides input files that are

consistent with the ETE statements on evacuation routing and traffic loading.

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The number of permanent residents is estimated using the U.S. Census data and other reliable

data, adjusted as necessary, for growth. These population data are translated into two

subgroups, those using autos and those without autos. The number of vehicles used by

permanent residents is estimated using an appropriate auto occupancy factor. Special

attention is given to those households not having automobiles. The public transport-dependent

population is considered as a special case.

Estimates of transient populations are developed using local data such as peak tourist volumes

and employment data for large factories. This population segment, along with the permanent

population subgroup using automobiles, constitutes the general population group for which an

ETE is made.

An estimate for the special facility population group is done on an institution-by-institution basis.

The means of transportation are described. Schools are also included in the special facility

population segment.

Although the application does not provide all combinations of radial sectors and ring distances

as specified in Appendix 4, "Evacuation Time Estimates within the Plume Exposure Pathway

Emergency Planning Zone," to Revision 1 of NUREG-0654/FEMA-REP-1, there are sufficient

data to be representative of the guidance. Operationally, the subareas, not radial sectors and

rings, are used for protective action decisionmaking.

The application adequately describes the different combinations of areas (and zones) used in

the ETEs, including the inner area (and inner zone). Hence, the ETE for the outer areas

(zones) will include the simultaneous evacuation of the adjacent inner areas (zones).

The subareas described in the application, that require ETEs, encompass the entire area within

the plume exposure EPZ. The boundaries of the subareas are based upon the same factors as

the EPZ (i.e., demography, topography, land characteristics, access routes, and local

jurisdictions). To the extent practical, the sector boundaries do not divide densely populated

areas. Special facilities are also noted on these maps, to the extent that their locations can be

geographically specified. Populations are provided by evacuation areas. Separate totals are

provided for permanent residents, transient populations, and special facility population.

Tables 6.1, 6.2, 6.3, and 6.4 in the application provide ETE data following a keyhole approach

with a simultaneous evacuation of the 2-mile radius and combinations of three sectors for each

condition. This approach is adequate for determining ETEs.

The application provides a map showing only those roads used as primary evacuation routes.

Each segment of the network is numbered for reference. The sector and quadrant boundaries

are also indicated.

A table is provided indicating all the evacuation route segments and their characteristics,

including capacity. The characteristics of a segment are given for the narrowest section (or

bottleneck), if the roadway is not uniform in the number of lanes throughout the segment.

Each of the evacuation time components is presented in the application along with the total

evacuation time. The analysis considered both normal and adverse conditions. The applicant

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identified the adverse frequency used in the 1993 ETE, and this condition is severe enough to

define tie sensitivity of the analysis to the selected events.

The application describes critical assumptions that underlie the time estimates (e.g., day versus

night, workday versus weekend, peak transient versus off-peak transient, and evacuation on

adjacent sectors versus nonevacuation). The relative significance of alternative assumptions is

addressed, especially with regard to time-dependent traffic loading of the evacuation roadway

network segments.

The application specifies the method of computing total evacuation time. The analysis uses

distribution functions and provides estimates of the likelihood that each stage in the evacuation

sequence will be accomplished in a given period of time. The applicant developed distribution

functions for notification of the various categories of the evacuee population. There are

separate distributions for auto-owning households, school populations, and transit-dependent

populations.

On-road travel and delay times are calculated. An estimate of the time required to evacuate

that segment of the nonauto-owning population, that is dependent upon public transport, is

made in a similar manner to that used for the auto-owning population. This estimate includes

consideration of special services that might be initiated to serve this population subgroup.

Estimates for special facilities are made with consideration for the means of mobilization of

equipment and manpower to aid in evacuation. This includes the need for designated persons

to delay their evacuation to shut down industrial facilities. Each special facility is treated on an

individual basis. Weather conditions and time of day conditions are considered. Consideration

is given :o the impact of peak populations, including behavioral aspects.

The 1993 ETE summarizes the maximum times for each component and for each sector. The

percentage of the population as a function of time is reported.

The time required for confirmation of evacuation is estimated. Specific recommendations for

actions that could be taken to significantly improve evacuation time are given. A review of the

draft ETEE submittal by the principal (State and local) organizations involved in emergency

response. for the site was solicited, and comments resulting from the review were included in

the final submittal.

The appl cation includes, in the EGC ESP Emergency Plan and State and local plans, maps

showing svacuation routes, evacuation areas, shelter areas, and relocation centers in host

areas. The application includes maps identifying population distribution around the site by

evacuation subareas and describes the means for notifying all segments of the transient and

resident population.

State and local plans contain the following:

* a proposed means for protecting those persons whose mobility may be impaired

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* a proposed means for the use of radioprotective drugs for emergency workers and

institutionalized persons within the plume exposure EPZ whose immediate evacuation

may be infeasible orvvery difficult

* a proposed means of relocation

* a potential relocation center in host areas that are at least 5 miles, and preferably

10 miles, beyond the boundaries of the plume exposure EPZ

* control and access to evacuated areas and organization responsibilities for such control

* an identification of, and means for, dealing with potential impediments to the use of

evacuation routes and contingency measures

In Open Item 13.3-4, the staff requested that the applicant provide additional information related

to the 1993 ETE, as requested in RAls 13.3-20(k) through (v), was needed. In addition, the

staff noted that the applicant had not adequately addressed the estimated time required for

confirmation of evacuation (RAI 13.3-16).

In its submission to the NRC dated April 4, 2005, the applicant responded to Open Item 13.3-4.

The applicant also stated that it had submitted a response to RAls 13.3-20(k) through (v) to

the NRC on January 24, 2005. The applicant estimated the time required to confirm evacuation

based on visual confirmation by ground vehicles, a specific method included in

NUREG-0654/FEMA-REP-1. The applicant then calculated the evacuation confirmation times

as the time required for emergency vehicles to conduct a "windshield survey" of the evacuated

subareas, road by road, at an average travel speed of 15 mph. U.S. Census TIGER

(Topologically Integrated Geographic Encoding and Referencing system) files determine the

miles of roadway in each subarea. Based on discussions with IEMA, the applicant assumed

that confirmation of evacuation would be performed using 25 vehicles. (More than 100 traffic

and access control points have been designated for the EPZ and subareas. As the evacuation

nears completion, some of the resources dedicated to traffic management will be available to

perform other duties, such as evacuation confirmation.) The table titled, "Estimated

Confirmation Times for EGC ESP EPZ," in the 1993 ETE summarizes the miles of roadway in

each protective action recommendation evacuation zone and the estimated times for

evacuation confirmation (rounded to the nearest 5 minutes). Based on the additional

information related to the 1993 ETE provided in the applicant's responses to RAls 13.3-20(k)

through (v) and the estimated time required for confirmation of evacuation, the staff considered

Open Item 13.3-4 to be resolved.

In Open Item 13.3-5, the staff requested that the applicant provide additional information

concerning the protective measures identified in State and local emergency plans, including a

description of the State and local governments' approach to using the traffic capacities of

evacuation routes for implementing protective measures, a description of the State and local

organizations' approach to using ETEs when considering the evacuation of various sectors and

distances, and a description of the IDNS SOPs that serve as the basis for choosing a

recommended protective action for the plume exposure pathway, as requested in

RAls 13.3-13(e) through (h). The applicant provided acceptable responses to RAls 13.3-13(e)

through (h) as discussed above.

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Another aspect of Open Item 13.3-5 involved the adequacy of the information provided by the

applicant, in its response to RAI 13.3-14, related to the review of the draft ETE submitted by the

State and local organizations involved in emergency response for the site. In its submission to

the NRC dated April 4, 2005, the applicant responded to this aspect of Open Item 13.3-5. In its

submission, the applicant stated that the highway traffic capacities identified in the ETE are

considered a tool for developing the State and local plans and procedures, but they are not a

critical consideration during protective action decisionmaking. The State bases its protective

action recommendations to localities primarily on reactor conditions and predictive modeling,

with the aim of implementing preemptive protective actions before any radioactive release

occurs. Thus, the projected timeframe (i.e., the ETE) for a given scenario is of less concern

than the actual environmental conditions that might exist at the time of the emergency. The

emergency plans and public information materials predesignate evacuation routes taking into

account: the various scenarios for wind direction and subarea designations.

The applicant also stated that there are provisions for adjusting the evacuation routes during an

actual emergency or an exercise. For example, IPRA, Volume VilI, Chapter 2, Section J,

indicates that the specific evacuation routes are determined through coordination of the DeWitt

County EOC and IEMA; local officials then arrange the traffic and access control posts as

discussed in subsections J.3.b and J.3.d. Under actual (and exercise) emergency conditions,

the State and localities adjust the available and desirable routes to the current circumstances,

using traffic and access control points to divert evacuees to the appropriate routes so as to

avoid traffic moving within and across the plume path and to avoid impediments. These

techniques are demonstrated during FEMA-evaluated exercises. There are no specific

:directions br procedures for these techniques because the conditions under which the action

would be taken are dictated by circumstances and the knowledge of the local officials of the

road networks in their communities.

The original response to RAI 13.3-14 indicates that "each comment resulting in an adaptation of

the ETE was appropriately included in the final version of the ETE." The applicant also stated

that it intended this statement to reflect that it had provided the draft ETE to the State

organizations involved in emergency response for the site for comment, that the State provided

comments on the draft ETE, and that the applicant had appropriately incorporated these

comments into the final ETE delivered to the State.

Based on the additional information related to protective measures in State and local

emergency plans and the review of the draft ETE by local and State organizations involved in

emergency response for the site in its response to RAI 13.3-14, the staff considers Open

Item 13.3-5 to be resolved.

Volumes I and Vill of the IPRA describe the means for registering and monitoring evacuees at

reception centers in host areas.

13.3.3.11.4 Conclusions

As discussed above, the applicant described a range of protective actions for the plume

exposure pathway EPZ for both the public and emergency workers, including guidance for the

choice of protective actions that are consistent with Federal guidance and protective actions fDr

the ingestion exposure pathway EPZ. Based on its review, the staff concludes that the

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proposed major feature J is consistent with the guidance in RS-002 and Supplement 2.

Therefore, this feature is acceptable and meets the requirements of 10 CFR 52.17(b)(2)(i),

10 CFR 52.18, and Sections 1II, IV.A, IV.B, IV.D, and IV.E of Appendix E tolO CFR Part 50,

insofar as it describes the essential elements of advanced planning that the applicant

considered for accident assessment, as set forth above. The applicant provided other

information in the application that is outside the scope of the staff's review of this feature and is

not discussed in this SER. Therefore, the staff did not make findings regarding its acceptability.

13.3.3.12 Radiological Exposure Control (Major Feature K)

13.3.3.12.1 Technical Information in the Application

Section 11.1, "Emergency Exposure Guidance," of the EGC ESP Emergency Plan states that,

in emergency situations, workers may receive exposure under a variety of circumstances to

assure safety and protection of others and of valuable property. These exposures can be

justified if the maximum risks or costs to others that are avoided by their actions outweigh the

risks that the workers are subjected to. Table 11.1-1, "Emergency Exposure Guidance," of the

EGC ESP Emergency Plan provides the emergency worker dose limits. The emergency

director must authorize dose extensions beyond the limits imposed by 10 CFR Part 20,

"Standards for Protection against Radiation." Section 11.2, "Emergency Radiation Protection

Program," of the EGC ESP Emergency Plan describes guidance on dose limits during an

emergency.

Section 11.1 of the EGC ESP Emergency Plan states that the station emergency director shall

have the nondelegable responsibility for authorizing personnel exposure levels under

emergency conditions in accordance with the EPA emergency worker and lifesaving protective

action guides (PAGs). Whenever possible, the concurrence of the radiation protection manager

(RPM) should be secured before individuals are exposed to dose equivalents beyond the

EPA 400 lower limit. Section 11.2 of the EGC ESP Emergency Plan describes an onsite

radiation protection program to be implemented during an emergency.

Section 11.2.1, "Personnel Monitoring," of the EGC ESP Emergency Plan describes the use of

thermoluminescent dosimetry (TLD) and personnel self-reading dosimeters capable of

measuring expected exposures to monitor emergency workers. The capability exists to process

TLDs 24 hours per day in emergencies, if necessary.

Section 1 E(5)(b) of IPRA Volume I states that IDNS is responsible for all aspects of radiation

exposure control. The RAFT exposure control officer (ECO) is responsible for protecting

emergency workers from excessive exposure to ionizing radiation. The ECO is also

responsible for maintaining a full legal record of exposure. Detailed monitoring of emergency

workers is accomplished through the use of dosimetry, bioassay, and whole body counting, as

warranted. The ECO will issue dosimetry and instructions for use to emergency workers. At

the end of each day's assignment, State emergency workers will turn in their dosimetry to their

ECO for processing.

Sections 20(1), "DeWitt County, Radiological Considerations, Dosimetry Control," and 1 D and

Annexes 2A through 2F of IPRA Volume VIII state that the local dosimetry control officer (DCO)

issues a direct-read dosimeter, a TLD, a bottle of KI, and instructions for use of dosimetry and

13-64
KI to all emergency workers. Workers are instructed to read their dosimeters every 30 minutes,

unless otherwise directed. Emergency workers record their exposure on a radiation exposure

record. Emergency workers are instructed to report an exposure of 3 roentgen R) to their

respon;ible DCO. The DCO will contact the IEMA liaison at the DeWitt County EOC for

exposure control guidance. Section 1 E(4) of IPRA Volume I states that the 3-R reporting limit

may be adjusted downward if conditions warrant, based on actual or projected doses under

emergency conditions.

Annexes 2A through 2F in IPRA Volume Vill require that, as instructed or at the end of their

assigned mission, emergency workers turn in their dosimetry and exposure control logs to the

DCO. Section 20(1) of IRPA Volume VilI states that TLDs and radiation exposure records

should be returned to IEMA for processing.

In addition, the RPMs (as appropriate) will maintain emergency worker dose records in

accordance with future emergency and radiological protection procedures. Emergency workers

will be instructed to read their dosimeters frequently, and TLDs may be processed with

increased periodicity.

Section 1 E(5)(b) of IPRA Volume I states that the monitoring of the State of Illinois emergency

workers is accomplished through the use of dosimetry, bioassay, and whole-body counting, as

warranted. Section 3A(8) of IPRA Volume I states that, to perform tasks associated with the

radiological response to a nuclear accident, IDNS maintains a comprehensive inventory of

appropriate equipment, and that all emergency response equipment and instruments are

inspected, inventoried, and operationally checked once each quarter. In RAI 13.3-13(i), the

staff asked the applicant to describe how the State will acquire and distribute dosimeters, bol:h

direct-reading and permanent record devices. In response to RAI 13.3-13(i), the applicant

stated that Sections 2H and 20(1) in IPRA Volume Vil describe how the State will acquire and

distribute dosimeters. In addition, Section 3A of IPRA Volume I provides information regarding

dosimetty for State agency personnel who have field assignments, such as Illinois State police

(ISP), IONR, and IDOT. Section 1 D of IPRA Volume Vil also discusses dosimetry for the ISP,

IDNR, and lOOT districts and regions specific to the CPS.

Section 20(1) of IPRA Volume Vill states that IEMA distributes dosimetry equipment and forms

to DCOs and then receives the TLDs and radiation exposure records after use.

Sections 1 E(4) and 3A(8) of IPRA Volume I state that IDNS is responsible for all aspects of

radiation exposure control. The RAFT ECO is responsible for protecting emergency workers

from excessive exposure to ionizing radiation. IDNS has adopted the exposure limits for

emergency workers found in EPA 400 (identified in the following table). Section 20(2), "DeWitt

County, Radiation Exposure Control," of IPRA Volume Vill states that the following exposure

limits are observed for all emergency workers within the State of Illinois:

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13.3-1 State of Illinois Dose Limits for Emergency Workers

-Dose Limit (Rem) | Dose Limit Approved for:

5 All activities

10 Protection of valuable property

25 Lifesaving or protection of large populations

>25 Lifesaving or protection of large

populations, only on a voluntary basis to

persons fully aware of the risks involved

In addition, for emergency worker exposure control purposes, IEMA has established a 3-1l

notification limit. If an emergency worker's exposure approaches 3 R, he or she must report to

his or her DCO or ECO. The DCO/ECO will expeditiously notify IEMA, that will provide further

instructions in accordance with SOPs.

Section 11.2.3, "Contamination and Decontamination," of the EGC ESP Emergency Plan states

that, during emergency conditions, normal plant contamination control criteria will be adhered to

as much as possible. However, these limits may be modified by the applicable RPM in

accordance with existing radiological protection procedures, should conditions warrant.

Section 1 E(5)(b) and Section 20(4), uDeWitt County, Decontamination," of IPRA Volume VIII

state that evacuees and emergency workers will be monitored for radioactive contamination

and, if necessary, decontaminated at designated congregate care facilities. Section 3A(8)

states that RAFT monitoring and decontamination teams are responsible for directing

decontamination activities and for the radiation monitoring of emergency personnel, vehicles,

and equipment. They will ensure that procedures are followed to avoid the unwarranted spread

of radioactive contamination and will coordinate with other agencies, as necessary.

Section 1 E(5)(b) of IPRA Volume 1 states that monitoring will be performed utilizing portal and

hand-held monitoring instruments. The IDNS provides decontamination equipment. In

RAI 13.3-130), the staff asked the applicant to describe the State and local organizationspecific action levels for determining the need for decontamination of emergency workers,

equipment and vehicles, and the general public and their possessions. In response to

RAI 13.3-13(), the applicant stated that Section 20(4) of IPRA Volume VIII provides such a

description. Section 1 E(4) of IPRA Volume I also provides a general statement about

decontamination.

Section 11.2.5, "Decontamination of Relocated Personnel," of the EGC ESP Emergency Plan

states that nonessential onsite personnel may be evacuated to an offsite relocation center or

assembly area. Radiological control personnel at that location will monitor evacuees and

determine the need for decontamination. Existing and temporary facilities to limit contamination

and exposure will be utilized and established at the site as necessary during an emergency

situation. In the event that decontamination of evacuees is not possible locally, personnel will

be sent to designated locations for monitoring and decontamination. Provisions for extra

* clothing will be made, and suitable decontaminates will be available for the expected type of

contamination, particularly with regard to skin contamination.

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Section 11.2.3.1, "Contamination Control Means," of the EGC ESP Emergency Plan states that

personnel found contaminated will normally be attended to at decontamination areas located on

site. Temporary decontamination areas can also be set up inside at various locations.

Decontamination showers and supplies will be provided on site with additional personnel

decontamination equipment and capabilities. Shower and sink drains in the controlled area will

be routed to the miscellaneous waste processing system, where the liquid will be processed

and monitored before discharge. Potentially contaminated emergency vehicles will be surveyed

before they are allowed to leave the EGC ESP facility or offsite assembly area. If the survey

area is riot suitable for monitoring and decontamination because of radiological or other

concerns, vehicles will be surveyed at an alternate location. Section 11.2.4 of the EGC ESP

Emergency Plan, "Contamination Control Measures," also states that, if personnel leaving

contaminated areas are found contaminated above acceptable levels, they will be

decontaminated in accordance with future EGC ESP facility procedures. If normal

decontamination procedures do not reduce personnel contamination to acceptable levels, the

case will be referred to a competent medical authority.

Supplies, instruments, and equipment that are in contaminated areas or have been brought i'to

contaminated areas will be monitored before removal. If found contaminated, they will be

decontaminated using normal EGC ESP facility decontamination techniques or they may be

disposed of as radioactive waste.

Sections 11.2.3.1 and 11.2.4 of the EGC ESP Emergency Plan discuss the means for

decontaminating personnel, vehicles, supplies, instruments, and equipment. In RAI 13.3-9, the

staff asked the applicant to describe the means for decontaminating personnel wounds. In

response to RAI 13.3-9, the applicant stated that the means for decontaminating personnel

wounds will be wound specific and determined on a case-by-case basis. Life-threatening

wounds will be decontaminated at the John Warner Hospital's "hot" emergency room by trained

medical personnel with the support of station radiological control personnel. Nonlife-threatening

wounds wvill be decontaminated by radiological control personnel, with the assistance of

emergency response personnel (e.g., emergency medical technicians or ambulance personnel,

using procedures for decontamination of personnel with skin or clothing contamination.

In RAI 1.3.3-13(k), the staff asked the applicant to describe the State and local organizations'

means fcr radiological decontamination of emergency personnel wounds, supplies, instruments,

and equipment. In response to RAI 13.3-13(k), the applicant stated that Section 20(4) of.

IPRA Volume VIII describes the State and local organizations' means for radiological

decontamination of emergency personnel wounds, supplies, instruments, and equipment. This

section o01 IPRA also states that such personnel will be transported to a health facility.

Section 1 E(4) of IPRA Volume I also provides a general statement about decontamination.

13.3.3.12.2 Regulatory Evaluation

In Section 1.1 of the EGC ESP Emergency Plan, the applicant stated that it developed the plan

to comply with the requirements of 10 CFR 52.17, using the guidance in Supplement 2. In

Section 1.2 of the EGC ESP Emergency Plan, the applicant stated that the EGC ESP

Emergency Plan, in conjunction with future implementing and administrative procedures,

documents the methods by which the applicant's emergency preparedness program meets the

planning standards in 10 CFR 50.47(b) and the requirements in Appendix E to 10 CFR Part 5().

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The staff finds that the applicant identified the regulatory requirements and guidance applicable

to the proposed major features of emergency plans for an ESP application.

In its review of the application, the staff considered the regulatory requirements in 10 CFR

52.17(b)(2)(i), 10 CFR 52.18, and Sections 1II, IV.A, IV.B, and IV.E of Appendix E to 10 CFR

Part 50. Under 10 CFR 52.1 7(b)(2)(i), an applicant for an ESP may propose major features of

emergency plans for NRC review and approval, in consultation with FEMA, in the absence of

complete and integrated emergency plans. Under 10 CFR 52.18, after consultation with FEMA,

the NRC will determine whether the major features of emergency plans submitted under

10 CFR 52.1 7(b)(2)(i) are acceptable. RS-002 and Supplement 2 provide guidance concerning

the review and evaluation of emergency planning information given in an ESP application.

Supplement 2 also provides specific evaluation criteria for the major features of emergency

plans, including those that apply to major feature K, "Radiological Exposure Control."

Major feature K calls for the applicant to describe an onsite radiation protection program and

the means for determining and controlling radiological exposures to emergency workers and

volunteers (on site and off site), including a decision chain for authorizing exposures in excess

of EPA dose limits. The application should also describe specific action levels and the means

for radiological decontamination of personnel (including wounds), vehicles, equipment,

supplies, and possessions.

13.3.3.12.3 Technical Evaluation

The staff finds the applicant provided sufficient information regarding decontaminating wounds,

supplies, instruments, and equipment in response to RAls 13.3-9 and 13.3-13(k) and is,

therefore, acceptable.

In the EGC ESP Emergency Plan, the applicant adequately described guidance for dose limits

appropriate to removing injured persons, undertaking corrective actions, performing

assessment actions, performing field radiological measurements in the plume EPZ, providing

first aid, performing personnel decontamination, providing ambulance service, and providing

medical treatment services.

In the EGC ESP Emergency Plan, the applicant described an onsite radiation protection

program to be implemented during emergencies, including methods to implement dose limits.

The applicant used the general guidance on dose limits for workers performing emergency

services found in EPA 400.

The EGC ESP Emergency Plan and IPRA Volumes I and Vil describe how each organization

will determine the doses received by emergency personnel involved in any nuclear accident,

including volunteers.

The EGC ESP Emergency Plan and the State and local plans describe a decision chain for

each organization for authorizing emergency workers to incur exposures in excess of the EPA

dose limits for workers performing emergency services.

The EGC ESP Emergency Plan describes how the applicant will acquire and distribute

dosimeters, both direct-reading and permanent record devices.

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However, the staff identified in Open' Item 13.3-6 that the applicant's responses to

RAls 13.3-13(i) through (k) did not provide additional information about how the State will

acquire and distribute dosimeters, both direct-reading and permanent record devices. The

applicant also did not provide additional information related to the State and local organizationspecific action levels for determining the need for decontamination of emergency workers,

equipment and vehicles, and the general public and their possessions. Further, the applicant

did not describe local and State organizations' means for radiological decontamination of

emergency personnel wounds, supplies, instruments, and equipment. In its submission to the

NRC dated April 26, 2005, the applicant responded to Open Item 13.3-6. The applicant stated

that the State (IEMA) maintains a statewide inventory of approximately 9000 direct-read

dosimelers and approximately 9000 TLDs (for permanent record). Over 90 percent of this

inventory is prepositioned (predistributed) with the response organizations identified in the plan

for distribution to emergency workers when an emergency is declared. For example, dosimetry

control actions for various groups are described under the "Parallel Actions" discussions in

IPRA, Volume Vil, Sections D.1, D.2, D.3, D.4, D.5, and 0.1. Included with the dosimetry is an

individual 14-d supply of KI. The dosimetry is field tested and calibrated in accordance with

FEMA guidance and replaced when necessary. IEMA has the capability to read the TLDs in the

field and in-house for an initial dose determination, and has established a contract with the

supplier to read the devices for a certified record.

The contamination "action level' is defined in IEMA procedures as 'twice-background."

The State reserves the right to make case-by-case determinations on whether equipment,

vehicles, and personal possessions can be released with contamination levels above the twicebackground threshold (e.g., critical emergency equipment, fixed contamination).

The means for radiological decontamination are also embodied in IEMA's operational

procedu'es and are part of the process associated with monitoring evacuees and emergency

workers. Evacuees are directed to reception centers where monitoring occurs either by or

under the supervision of trained IEMA staff. These dedicated facilities have decontamination

showers and designated areas outside for the decontamination of vehicles and other

equipment. These same facilities will be available for use by emergency workers. (Note: The

radiological accident field teams' personnel dispatched to take plume measurements and

collect environmental samples return to their independent operations center for monitoring arid,

if necessary, decontamination.)

The reference to "wounds" in the staff's question relates to the availability of medical services.

The standing procedures provide that anyone (evacuee or emergency worker) injured and

potentially contaminated will be directed to a designed hospital for treatment and their wounds

handled in accordance with accepted contamination control protocols. If the patient originates

at a reception center, IEMA will provide monitoring personnel to accompany the individual to the

treatment facility. In any instance that a patient self-presents and the hospital is concerned

about contamination issues, hospital staff can request assistance from IEMA.

The Department of Nuclear Safety Standard Operating Procedures 4-SOP-29 and 4-SOP-30

provide IEEMA functional instructions for establishing and operating an evacuee and emergency

worker monitoring and decontamination center and for dealing with potentially contaminated

vehicles and other equipment.

13-69
Based upon the additional information provided in the applicant's responses to RAls 13.3-13(i)

through (k), that are related to how the State will acquire and distribute dosimeters (both directreading and-permanent record devices); the State and local organization-specific action levels

for determining the need for decontamination of emergency workers, equipment and vehicles,

and the general public and their possessions, as well as State and local organizations' means

for radiological decontamination of emergency personnel wounds, supplies, instruments, and

equipment, the staff considers Open Item 13.3-6 to be resolved.

13.3.3.12.4 Conclusions

As discussed above, the applicant described the means for controlling radiological exposures to

emergency workers in an emergency. Based on its review, the staff concludes that the

proposed major feature K is consistent with the guidance in RS-002 and Supplement 2.

Therefore, this feature is acceptable and meets the requirements of 10 CFR 52.1 7(b)(2)(i),

10 CFR 52.18, and Sections III, IV.A, IV.B, and IV.E of Appendix E to 10 CFR Part 50, insofar

as it describes the essential elements of advanced planning that the applicant considered for

radiological exposure control, as set forth above. The applicant provided other information in

the application that is outside the scope of the staff's review of this feature and is not discussed

in this SER. Therefore, the staff did not make findings regarding its acceptability.

13.3.3.13 Medical and Public Health Support (Major Feature L)

13.3.3.13.1 Technical Information in the Application

Section 12.1 of the EGC ESP Emergency Plan states that arrangements, confirmed by letter of

agreement every two or more calendar years, will also be maintained by the corporate office of

a qualified major medical facility that is well equipped and staffed for dealing with persons

having radiation injuries. John Warner Hospital in Clinton, Illinois, will be the primary supporting

medical facility for injured persons who are contaminated with radioactivity. Whenever

necessary, such persons will be transferred to this major hospital facility for extended

specialized treatment. Section 12.1 also states that the applicant will have medical consultants

available to the hospital staff who will provide the direction of the special care necessary for the

treatment of persons having radiation injuries, as described in Section 3.4.5 of the EGC ESP

Emergency Plan.

Section 12.3, "Medical Services Facilities," of the EGC ESP Emergency Plan states that, since

radiation injuries involve specialized diagnosis and treatment, EGC corporate emergency

preparedness personnel maintain an agreement with the REAC/TS. Section 3.4.5 of the EGC

ESP Emergency Plan provides additional information related to REAC/TS. REAC/TS is a

radiological emergency response team of physicians, nurses, health physicists, and necessary

support personnel on 24-hour call to provide consultative or direct medical or radiological

assistance at the REAC/TS facility or at the accident site. Specifically, the team has expertise'

in and is equipped to conduct medical and radiological triage; decontamination procedures and

therapies for external contamination and internally deposited radionuclides, including chelation

therapy; diagnostic and prognostic assessments of radiation-induced injuries; and radiation

dose estimates by methods that include cytogenetic analysis, bioassay, and in vivo counting.

13-70
Sections 1 H, "Overview, Medical Services," and 1 E(5)(e), "Basic Functions, Parallel Actions:,

Emergency Medical Services," of IPRA Volume I explain that hospitals statewide are provided

with a telephone number, maintained on a 24-hour basis by IDNS, that medical personnel can

use to obtain advice or technical assistance. In accordance with the Illinois Emergency Medical

Services Act, an individual who may be contaminated as a result of a reactor accident will be

transported to an assigned medical treatment facility.

Section 2A of IPRA Volume Vill states that IEMA and IDNS maintain a listing of hospitals with

specific capabilities to treat radiologically contaminated and injured individuals. The IDNS

maintains a listing of all medical facilities within the State with capabilities related to the

evaluation of radioactive exposure and uptake, including those hospitals under contract to the

nuclear utilities for the treatment of onsite injured and exposed or contaminated personnel.

13.3.3.13.2 Regulatory Evaluation

In Section 1.1 of the EGC ESP Emergency Plan, the applicant stated that it developed the plan

to comply with the requirements of 10 CFR 52.17, using the guidance in Supplement 2. In

Section 1.2 of the EGC ESP Emergency Plan, the applicant stated that the EGC ESP

Emergency Plan, in conjunction with future implementing and administrative procedures,

documents the methods by which the applicant's emergency preparedness program meets the

planning standards in 10 CFR 50.47(b) and the requirements in Appendix E to 10 CFR Part i50.

The staff finds that the applicant identified the regulatory requirements and guidance applicable

to the proposed major features of emergency plans for an ESP application.

In its review of the application, the staff considered the regulatory requirements in 10 CFR

52.17(b)(2)(i), 10 CFR 52.18, and Sections III, IV.C, and IV.E of Appendix E to 10 CFR Part 50.

Under 1 0 CFR 52.1 7(b)(2)(i), an applicant for an ESP may propose major features of

emergency plans for NRC review and approval, in consultation with FEMA, in the absence of

complete and integrated emergency plans. Under 10 CFR 52.18, after consultation with FEMIIA,

the NRC will determine whether the major features of emergency plans submitted under

10 CFR !52.17(b)(2)(i) are acceptable. RS-002 and Supplement 2 provide guidance concerning

the review and evaluation of emergency planning information given in an ESP application.

Supplement 2 also provides specific evaluation criteria for major features of emergency plans,

including those that apply to major feature L, "Medical and Public Health Support."

Major feature L calls for the applicant to describe contacts and arrangements made for medical

services for contaminated, injured individuals, as well as to develop lists indicating the locations

and capabilities of emergency medical services facilities.

13.3.3.13.3 Technical Evaluation

In the EGC ESP Emergency Plan and State and local plans, the applicant described the

contacts and arrangements made for local and backup hospital and medical services having the

capability to evaluate radiation exposure and uptake.

The State plan notes that lists exist to indicate the location of public, private, and military

hospitals and other emergency medical services facilities within the State, or contiguous States,

that are considered capable of providing medical support for any contaminated, injured

13-71
individual. The listing includes the name, location, type of facility and capacity, and any special

radiological capabilities. Contacts and arrangements made in developing these lists are

described.

13.3.3.13.4 Conclusions

As discussed above, the applicant described the contacts and arrangements for medical

services for contaminated, injured individuals, including local and backup hospital and medical

services having the capability for evaluating radiation exposure and uptake. Based on its

review, the staff concludes that the proposed major feature L is consistent with the guidance in

RS-002 and Supplement 2. Therefore, this feature is acceptable and meets the requirements

of 10 CFR 52.17(b)(2)(i), 10 CFR 52.18, and Sections III, IV.C, and IV.E of Appendix E to

10 CFR Part 50, insofar as it describes the essential elements of advanced planning that the

applicant considered for medical and public health support, as set forth above. The applicant

provided other information in the application that is outside the scope of the staff's review of this

feature and is not discussed in this SER. Therefore, the staff did not make findings regarding

its acceptability.

13.3.3.14 Radiological Emergency Response Training (Major Feature 0)

13.3.3.14.1 Technical Information in the Application

Section 15.1, "Assurance of Training," of the EGC ESP Emergency Plan states that the

emergency plan training program will assure the training, qualification, and requalification of

individuals who may be called upon for assistance during an emergency. In addition, lesson

plans and study guides will describe specific emergency response task training, prepared for

each emergency plan position. The ERO training program will contain the lessron plans, study

guides, and written tests. Responsibilities for implementing the training program will be

contained in the EGC ESP facility procedures. Section 15.5, "General, Initial, and Annual

Training Program Maintenance," of the EGC ESP Emergency Plan describes the

responsibilities for the training and retraining of the ERO personnel, as well as their initial

qualification and requalification. Section 15.1 outlines the training to be provided to support

organizations that may be called upon to provide assistance in the event of an emergency.

Section 15.4, "Emergency Response Organization Training Program," of the EGC ESP

Emergency Plan states that the applicant's ERO personnel who will be responsible for

implementing this plan will receive specialized training. Section 15.2, "Functional Training of

the Emergency Response Organization," of the EGC ESP Emergency Plan states that, in

addition to general and specialized classroom training, members of the applicant's ERO will

receive periodic performance-based emergency response training.

Section 15.4.1, "Directors, Managers, and Coordinators within the Facility and Corporate

Emergency Response Organization," of the EGC ESP Emergency Plan describes the

specialized internal training that will be provided for directors, managers, and coordinators

within the facility and corporate ERO.

Section 6B, "Preparedness Functions," of IPRA Volume I and Section 2L, "DeWitt County

Training," of IPRA Volume Vill explain that all State and local emergency personnel receive

annual initial and refresher training provided jointly by IEMA and IDNS. The training is

13-72
comprehensive and covers the operational and technical aspects of IPRA, basics of radiological

response, and the specific duties that each organization and individual are responsible for. *The

training program includes command and coordination, protective actions, and parallel actions.

Section 15.4.2, "Personnel Responsible for Accident Assessment," of the EGC ESP Emergency

Plan describes the specialized internal training that will be provided for personnel responsible

for accident assessment.

Section 6B of IPRA Volume I and Section 2L of IPRA Volume Vill explain that, at the State

level, IDNS performs accident assessments and is responsible for conducting a confirmatory,

independent assessment of the accident. State accident assessment personnel work out of the

IDNS Radiological Emergency Assessment Center located in Springfield, Illinois. Annual initial

and refresher training to all staff is provided on basic radiation principles, detection, and the

IPRA concept of operations.

Section 15.4.3, "Radiological Monitoring Teams and Radiological Analysis Personnel," of the?

EGC E.SP Emergency Plan describes the specialized internal training that will be provided for

radiological monitoring teams and radiological analysis personnel.

Section 6B of IPRA Volume I and Section 2L of IPRA Volume Vil state that the RAFT performs

the field radiological functions of confirmatory accident assessment, monitoring, and

decontamination. Upon request, ISP District 6 and 8 will monitor for possible radioactive

release during an incident at CPS before the arrival of the RAFT. In a joint effort, IEMA and

IDNS provide annual initial and refresher training to all State -and local personnel.

Section 15.4.4, "Police, Security, and Fire Fighting Personnel," of the EGC ESP Emergency

Plan describes the specialized internal training that will be provided for security and firefighting

personnel. Section 15.4.4.1, "Local Police and Fire Fighting Personnel," of the EGC ESP

Emergency Plan states that local police and fire departments will be invited to receive training,

as outlined in Section 15.1.

Section 6B of IPRA Volume I and Section 2L of IPRA Volume Vil state that all State, local

police, security, and firefighting personnel receive the Annual Emergency Response Training Prograrn provided by IEMA. The training focuses on the operational aspects of the plan and

addresses the unique radiological emergency response skills that workers would not normally

acquire as part of their usual job. The training also addresses subjects of a technical nature

such as KI, contamination/decontamination, and a hands-on practical application phase

covering the operation and maintenance of dosimetry equipment.

Section 15.3, "First Aid Response," of the EGC ESP Emergency Plan describes the specialized

internal training that will be provided for first aid and rescue personnel.

Section 61B of IPRA Volume I and Section 2L of IPRA Volume Vil state that all first aid and

rescue team personnel receive the Annual Emergency Response Training Program provided by

IEMA. The training focuses on the operational aspects of the plan and addresses the unique

radiological emergency response skills that workers would not normally acquire as part of

their usual job. The training also addresses subjects of a technical nature such as KI,

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contamination/decontamination, and a hands-on practical application phase covering operation

and maintenance of dosimetry equipment.

Section 15.4.7, "Local Support Service Personnel," of the EGC ESP Emergency Plan states

that local support service personnel providing assistance during an emergency will be invited to

receive the training, as outlined in Section 15.1 of the EGC ESP Emergency Plan.

Section 6B of IPRA Volume I and Section 2L in IPRA Volume VilI state that all local support

services personnel receive the Annual Emergency Response Training Program provided by

IEMA. The training focuses on the operational aspects of the plan and addresses the unique

radiological emergency response skills that workers would not normally acquire as part of

their usual job. The training also addresses subjects of a technical nature such as KI,

contamination/decontamination, and a hands-on practical application phase covering operation

and maintenance of dosimetry equipment.

Section 15.4.8, "Medical Support Personnel," of the EGC ESP Emergency Plan states that

onsite medical service personnel will receive specialized training in the handling of

contaminated victims and hospital interface. In addition, offsite ambulance and hospital

personnel will be offered annual training in accordance with the program described in

Section 15.1 of the EGC ESP Emergency Plan.

Section 6B of IPRA Volume I and Section 2L of IPRA Volume Vil state that, in accordance with

the guidance of Revision 1 of NUREG-0654/FEMA-REP-1, IDNS maintains a listing of all

medical facilities within the State with capabilities related to the evaluation of radioactive

exposure and uptake, including those hospitals under contract to the nuclear utilities for the

evaluation and treatment of onsite injured and exposed or contaminated personnel. The IDNS

provides a guide for handling, transporting, evaluating, and treating patients accidentally

exposed to radiation or contaminated with radioactive materials. Offsite ambulance and

hospital personnel will be offered annual training based on this guidance.

Section 15.4.10, 'Communication Personnel," of the EGC ESP Emergency Plan describes the

specialized internal training that will be provided for communications personnel.

Section 6B of IPRA Volume I and Section 2L of IPRA Volume Vil state that, at the State and

county level, public information personnel receive the Annual Emergency Response Training

Program provided by IEMA. The training covers all operational and technical aspects of IPRA.

State and county plans do not include the major features of specific training for personnel

responsible for disseminating emergency information. Information is also provided annually to

the media in the vicinity of the powerplant.

13.3.3.14.2 Regulatory Evaluation

In Section 1.1 of the EGC ESP Emergency Plan, the applicant stated that it developed the plan

to comply with 10 CFR 52.17, using the guidance in Supplement 2. In Section 1.2 of the EGC

ESP Emergency Plan, the applicant stated that the EGC ESP Emergency Plan, in conjunction

with future implementing and administrative procedures, documents the methods by which the

applicant's emergency preparedness program meets the planning standards in 10 CFR

50.47(b) and the requirements in Appendix E to 10 CFR Part 50. The staff finds that the

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applicant identified the regulatory requirements and guidance applicable to the proposed major

features of emergency plans for an ESP application.

In its review of the application, the staff considered the regulatory requirements in 10 CFR

52.17(b)(2)(i), 10 CFR 52.18, and Sections IlIl, IV.A, and IV.F of Appendix E to 10 CFR Part 50.

Under 10 CFR 52.1 7(b)(2)(i), an applicant for a ESP may propose major features of emergency

plans for NRC review and approval, in consultation with FEMA, in the absence of complete and

integrated emergency plans. Under 10 CFR 52.18, after consultation with FEMA, the NRC will

determine whether the major features of emergency plans submitted under 10 CFR

52.17(b)(2)(i) are acceptable. RS-002 and Supplement 2 provide guidance concerning the

review and evaluation of emergency planning information given in an ESP application.

Supplement 2 also provides specific evaluation criteria for major features of emergency plaris,

including those that apply to major feature 0, "Radiological Emergency Response Training."

Major feature 0 calls for the applicant to describe a radiological emergency response training

program for personnel who would implement the radiological emergency response plans.

13.3.3.14.3 Technical Evaluation

The EGC ESP Emergency Plan and IPRA Volumes I and VIII adequately describe a training

program for instructing and qualifying personnel who will implement radiological emergency

response plans. Specialized initial training and periodic retraining is provided for the following

categories of personnel:

* directors or coordinators of the response organizations

* personnel responsible for accident assessment

* radiological monitoring teams and radiological analysis personnel

* police, security, and firefighting personnel

* first aid and rescue personnel

* local support services personnel, including civil defense/emergency services personnel

* medical support personnel

* personnel responsible for transmission of emergency information and instructions

13.3.3.14.4 Conclusions

As discussed above, the applicant described a radiological emergency response training

program for those who may be called on to assist in an emergency, including a training

program for instructing and qualifying personnel who would implement the radiological

emergency response plans. In addition, the applicant described specialized initial training and

periodic retraining. Based on its review, the staff concludes that the proposed major feature 0

is consistent with the guidance in RS-002 and Supplement 2. Therefore, this feature is

acceptable and meets the requirements of 10 CFR 52.17(b)(2)(i), 10 CFR 52.18, and

Sections !ll, IV.A, and IV.F of Appendix E to 10 CFR Part 50, insofar as it describes the

essential elements of advanced planning that the applicant considered for radiological

emergency response training, as set forth above. The applicant provided other information in

the application that is outside the scope of the staff's review of this feature and is not discussed

in this SEFR. Therefore, the staff did not make findings regarding its acceptability.

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13.3.3.15 Responsibility for the Planning Effort: Development, Periodic Review, and

Distribution of Emergency Plans (Major Feature P)

13.3.3.15.1 Technical Information in the Application

Section 16.1, "Emergency Preparedness Staff Training" of the EGC ESP Emergency Plan

describes the training of each member of the emergency preparedness staff as involving at

least one of the following activities at least once a calendar year:

* training courses specific or related to emergency preparedness

* observation of, or participation in, drills and/or exercises at other facilities

* participation in industry review and evaluation programs

* participation in regional or national emergency preparedness seminars, committees,

workshops, or forums

* specific training courses in related areas, such as systems, equipment, operations,

radiological protection, or problem identification and resolution

Section 6B of IPRA Volume I and Section 2L of IPRA Volume Vill state that State and county

personnel responsible for the IPRA planning functions receive annual initial and refresher

training provided jointly by IEMA and IDNS. This comprehensive training covers the operational

and technical aspects of IPRA, the basics of radiological response, and the specific duties that

each organization and individual are responsible for.

Section 16.2, "Authority for the Emergency Preparedness Effort," of the EGC ESP Emergency

Plan states that the applicant's officers will be responsible for the safe and reliable operation of

the EGC ESP facility. The issuance and control of this plan and the activities associated with

emergency preparedness at EGC will be the overall responsibility of the Vice President of

Licensing and Regulatory Affairs. In RAI 13.3-1 0, the staff asked the applicant to identify by

title the individual who will have overall authority and responsibility for radiological emergency

response planning. In addition, the staff asked the applicant to identify an emergency planning

coordinator with responsibility for developing and updating of emergency plans and for

coordinating these plans with other response organizations.

In response to RAI 13.3-10, the applicant stated that the Vice President of Licensing and

Regulatory Affairs will have overall authority and responsibility for radiological response

planning, as indicated in Section 16.2 of the EGC ESP Emergency Plan. However,

Section 16.3, "Responsibility for Development and Maintenance of the Plan," identifies the

emergency planning coordinator as the emergency preparedness manager, who has certain

authority and responsibilities, as discussed in Section 16.3.1.1, "Program Administration," of

the EGC ESP Emergency Plan. Section 16.3.1.1 states that the MWROG emergency

preparedness manager is responsible for developing and maintaining the emergency plan.

Section 6C, "Preparedness Functions, Plan Maintenance and Updating," of IPRA Volume I

indicates that IEMA and IDNS are responsible for overseeing the updating of the IPRA,

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including the plans, SOPs, and training modules. In RAI 13.3-13(l), the staff requested the title

of the individual(s) at the State level with the overall authority and responsibility for radiological

emergency response planning. In response to RAI 13.3-13(l), the applicant stated that,

ultimately, the Governor has the overall authority and responsibility. However, within IEMA,

Section 3A(3) of IPRA Volume I provides the requested information and identifies that IEMA is

respons ble for emergency planning, and the director of IEMA is responsible for the direction

and control of IEMA operations.

Section :2N, "DeWitt County, Emergency Plan Maintenance," of IPRA Volume VIII states that

DeWitt County defers responsibility for maintenance and updating IPRA to IEMA. The DeWitt

County/Clinton ESDA coordinator is responsible for coordinating the planning, updating, and

maintenance of the DeWitt County section of IRPA Volume VIII. Furthermore, each agency

head is responsible for updating its agency's sections.

Section 16.3 of the EGC ESP Emergency Plan states that the MWROG emergency

preparedness manager will be responsible for the overall Radiological Emergency

Preparedness Program associated with the EGC ESP site. Section 16.3.1.1 of the EGC

ESP Emergency Plan states that the emergency preparedness manager is responsible for

developing and maintaining the emergency plan, developing and maintaining 10 CFR 50.54(q)

evaluations of changes to emergency planning documents, and ensuring integration of plans

between the applicant and offsite agencies.

In RAI 13.3-13(m), the staff requested the title of the individual(s) at the State level who is

designated as the emergency planning coordinator with responsibility for developing and

updating emergency plans and coordinating these plans with other. response organizations. In

response to RAI 13.3-13(m), the applicant stated that, although no title is provided in

Section 6C of IPRA Volume I, this section identifies that IEMA and IDNS are responsible for

these activities. Appropriate IEMA and IDNS documents (e.g., procedures and position

descriptions) provide the specific titles. The respective directors of IEMA and IDNS are the

positions with the identified responsibility.

Section 2N of IPRA Volume VIII states that, in DeWitt County, the Dewitt County/Clinton ESDA

coordinator is assigned this responsibility.

Section 16.4, "Emergency Plan and Agreement Revisions," of the EGC ESP Emergency Plan

states that the Exelon Nuclear Standardized Radiological Emergency Plan and supporting

agreements will be reviewed on an annual basis. The annual plan review/update will include

required changes identified during audits, assessments, training, drills, and exercises. The

MWROG emergency preparedness manager will be responsible for determining which

recommended changes are incorporated into a plan or emergency procedure revision. In those

years when the review does not warrant a revision, a letter to that effect will be issued. In

RAI 13.3-11, the staff requested that the applicant submit a description of the process for

updating Ihe agreements that support the Exelon Nuclear Standardized Radiological

Emergency Plan. In response to RAI 13.3-11, the applicant stated that agreements supporting

the Exelon Nuclear Standardized Radiological Emergency Plan are reviewed on an annual

basis, as identified in the first sentence of Section 16.4 of the EGC ESP Emergency Plan (i.e.,

the phrase "and supporting agreements" is included specifically to identify that annual reviews

are also applicable to the agreements). As indicated in the second sentence, this review

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includes updating as necessary. The process for updating an agreement is the same as the

process for obtaining the original agreement.

Section 6C of IPRA Volume I states that, at the State level, IEMA ensures that each State

agency reviews its portion of the plan annually, and any changes deemed necessary by lessons

learned during the drills and exercises and from actual emergency response, as well as those

resulting from agency reorganization, address, and telephone changes, will be made during the

IPRA update process. The IEMA is also responsible for ensuring that the same requirement is

met at the local level.

Section 2N of IPRA Volume Vil states that changes at the local level are reported to the DeWitt

County ESDA coordinator, who keeps a record of changes and forwards them to IEMA.

Section 16.5, "Emergency Plan Distribution," of the EGC ESP Emergency Plan states that the

emergency plan for the EGC ESP facility will not be distributed for implementation. The final

emergency plan and future EGC ESP facility implementing procedures will be distributed on a

controlled basis, before initial fuel loading, to the ERFs, selected Federal, State, and local

agencies, and other appropriate locations. Controlled document holders will be issued revision

changes upon approval. Procedures that control the revision of the emergency plan will require

the use of revision bars and individual page identifications (i.e., section of plan and revision

number).

Sections 6C of IPRA Volume I and Section 2N of IPRA Volume Vil state that all State, local,

and private organizations, upon review and update of their sections of the plan, are required to

forward to IEMA either a statement saying that no changes are necessary or a copy of their

portions with all revisions clearly marked and dated.

The table of contents for the EGC ESP Emergency Plan is provided on pages iii-xi.

Appendix B, "Requirements Matrix," to the EGC ESP Emergency Plan contains a crossreference of the planning standards and evaluation criteria in Supplement 2. In RAI 13.3-19,

the staff asked the applicant to provide an updated version of Table B-1, "Requirements

Matrix," of Appendix B to the EGC ESP Emergency Plan. In response to RAI 13.3-19, the

applicant stated that it updated Table B-1 of Appendix B to the EGC ESP Emergency Plan to

include the revisions that the NRC identified in this RAI.

There are tables of contents at the beginning of each section for the State and local plans. The

State and local plans also contain a "Planning Standards and Evaluation Criteria Correlation

Document," that includes a cross-reference to Revision 1 of NUREG-0654/FEMA-REP-1.

13.3.3.15.2 Regulatory Evaluation

In Section 1.1 of the EGC ESP Emergency Plan, the applicant stated that it developed the plan

to comply with the requirements of 10 CFR 52.17, using the guidance in Supplement 2. In

Section 1.2 of the EGC ESP Emergency Plan, the applicant stated that the EGC ESP

Emergency Plan, in conjunction with future implementing and administrative procedures,

documents the methods by which the applicant's emergency preparedness program meets the

planning standards in 10 CFR 50.47(b) and the requirements in Appendix E to 10 CFR Part 50.

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The staff finds that the applicant identified the regulatory requirements and guidance applicable

to the proposed major features of emergency plans for an ESP application.

In its review of the application, the staff considered the regulatory requirements in 10 CFR

52.17(b)(2)(i), 10 CFR 52.18, and Sections Ill, IV.A, IV.F, and IV.G of Appendix E to 10 CFR

Part 50. Under 10 CFR 52.17(b)(2)(i), an applicant for an ESP may propose major features of

emergency plans for NRC review and approval, in consultation with FEMA, in the absence of a

complete and integrated emergency plan. Under 10 CFR 52.18, after consultation with FEMIA,

the NRC will determine whether the major features of emergency plans submitted under

10 CFR 52.17(b)(2)(i) are acceptable. RS-002 and Supplement 2 provide guidance concerning

the review and evaluation of emergency planning information given in an ESP application.

Supplement 2 also provides specific evaluation criteria for major features of emergency plans,

including those that apply to major feature P, "Responsibility for the Planning Effort:

Development, Periodic Review, and Distribution of Emergency Plans."

Major feature P calls for the applicant to describe the development, review, distribution, and

update of emergency plans. The ESP application should also designate an emergency

planning coordinator for each organization and identify (by title) individuals with emergency

planning responsibility. In addition, the application should describe training for those

responsible for the planning effort.

13.3.3.15.3 Technical Evaluation

The staff finds the applicant's clarification of the authority and responsibility for radiological

response planning in response to RAls 13.3-1 0 and 13.3-13(l) and (m) consistent with the

guidance in Supplement 2 and, therefore, acceptable. The staff finds the additional information

related to the process for updating agreements in the response to RAI 13.3-11 and the upda:es

to the cross-reference matrix in response to RAI 13.3-19 to be acceptable.

The EGG ESP Emergency Plan and IPRA Volumes I and VIII adequately describe (1) the

training of individuals responsible for the planning effort, (2) the individual with the overall

authority and responsibility for radiological emergency response planning, (3) the designation of

an emergency planning coordinator with responsibility for the development and updating of

emergency plans, (4) the coordination of these plans with other response organizations, (5) the

update of emergency plans and agreements, as needed, (6) the process for approved changes

to the emergency response plans to be forwarded to all organizations and appropriate

individuals with responsibility for the implementation of the plans, (7) the dating and marking of

revised pages to show where changes have been made, and (8) a specific table of contents.

The EGC ESP Emergency Plan contains a matrix that adequately cross-references the criteria

in Supplement 2. Volumes I and VIII of IPRA contain a matrix that appropriately crossreferences the criteria in Revision 1 of NUREG-0654/FEMA-REP-1, rather than the criteria in

Supplement 2.

13.3.3.15.4 Conclusions

As discussed above, the applicant described the responsibilities for plan development and

review, as well as for distribution and update of emergency plans. In addition, the applicant

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identified those responsible for the planning effort and described the training they receive.

Based on its review, the staff concludes that the proposed major feature P is consistent with the

guidance in RS-002 and Supplement 2. Therefore, this feature is acceptable and meets the

requirements of 10 CFR 52.17(b)(2)(i), 10 CFR 52.18, and Sections III, IV.A, IV.F, and IV.G of

Appendix E to 10 CFR Part 50, insofar as it describes the essential elements of advanced

planning that the applicant considered for assigning responsibility for the planning effort,

including development, periodic review, and distribution of emergency plans, as set forth above.

The applicant provided other information in the application that is outside the scope of the

staff's review of this feature and is not discussed in this SER. Therefore, the staff did not make

findings regarding its acceptability.

The EGC ESP Emergency Plan contains a matrix that adequately cross-references the criteria

in Supplement 2. Volumes I and Vil of IPRA contain a matrix that appropriately crossreferences the criteria in Revision 1 of NUREG-0654/FEMA-REP-1, rather than the criteria in

Supplement 2.

13.6 Industrial Security

The NRC staff reviewed the physical security aspects of the ESP application to determine

whether the site characteristics are such that adequate security plans and measures can be

developed.

13.6.1 Technical Information in the Application

SSAR Section 3.4.1.6 states that, to accommodate the recommended 360 feet of distance from

vital equipment to the protected area (PA) fence, as specified in Regulatory Guide (RG) 4.7,

Revision 2, "General Site Suitability Criteria for Nuclear Power Stations," issued April 1998, the

actual ESP facility footprint may extend beyond the depicted ESP footprint. The application

indicates that the site characteristics are such that applicable NRC regulations, guidance

documents, and orders can be met. This conclusion is based on the fact that the Clinton.

owner-controlled area (OCA) is sufficiently large to provide adequate distances between vital

areas and the probable location of a security boundary.

In RAI 3.4.1.6-1, the staff asked the applicant to provide a scale drawing of the ESP site in

relation to the PA boundary, the OCA boundary, the shore of Clinton Lake, and other features

such as roads and railroad lines. In response, the applicant provided a figure indicating that the

OCA is large enough to meet the 360-foot distance criterion.

SSAR Section 3.4.1.6 also states that EGC has a security program in place for the existing unit

and that there are no identified impediments to the eventual development of an adequate

security plan for EGC's ESP facility. In addition, Section 3.4.1.6 states that sufficient distance

is available to satisfy the criteria of 10 CFR 73.55 and the revised design-basis threat.

Sections 2.2 and 3.5.1.6 of the SSAR discuss the potential hazards (e.g., fluids, explosives,

munitions, and chemicals stored or transported near the site).

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13.6.2 Regulatory Evaluation

According to NRC regulations, applicants for an ESP must address characteristics of the

proposed site that could affect the establishment of an effective security program. Specifically,

1 0 CFR 52.17 requires that site characteristics comply with 10 CFR Part 100. Pursuant to

10 CFR 100.21 (f), site characteristics must allow the development of adequate security plans

and measures. Revision 2 of RG 4.7 provides amplifying guidance and notes that 10 CFR

73.55 describes physical protection requirements for nuclear power plants.

SSAR Section 3.4.1.6 states that RG 4.7 provides applicable guidance and, in response to

RAI 1.5-1, the applicant stated that RS-002 identifies the NRC regulations applicable to its ESP

SSAR. RS-002 identifies 10 CFR 100.21(f) and 10 CFR 73.55 as the applicable regulations.

The staff reviewed this portion of the application for conformance with the applicable

regulations and considered the corresponding regulatory guidance.

13.6.3 Technical Evaluation

The staff reviewed the application and the responses to the RAIs and examined aspects of the

application during a site visit. The proposed ESP site is located on the shore of Clinton Lake in

DeWitt County, Illinois, near a licensed nuclear power reactor (Clinton Power Station) owned by

AmerGen Energy, LLC, an affiliate of the applicant. Using the criteria set forth in 10 CFR

100.21 (f), the staff identified and considered various characteristics of the site that could affect

the establishment of adequate security plans and measures. Specifically, the staff considered

pedestrian land approaches, vehicular land approaches, railroad approaches, water

approaches, potential high-ground adversary advantage areas, nearby road transportation

routes, nearby hazardous materials facilities, nearby pipelines, and culverts that could provide a

pathway into the PA.

With respect to pedestrian and water approaches, the staff found that various figures in the

application (e.g., Figure 1.2-4) identify the ESP site footprint within which all safety-related

structures would be located if one or more reactors were constructed. In RAI 3.4.1.6-1, the

staff asked the applicant to provide a scale drawing to allow the NRC staff to assess

conformance with RG 4.7, which specifies that there should be a minimum of 360 feet for

appropriate barriers, detection equipment, and isolation zones to protect vital equipment. In

response, the applicant provided Figure 3.4-1, which shows that the distances between the

planned locations of vital equipment and structures and the OCA boundary would permit the

development of adequate security plans and measures. The staff concluded that the distance

from possible locations of vital equipment and structures (which might be located anywhere in

the site footprint identified by the applicant because the ESP application does not describe a

specific design) to the OCA boundary is sufficiently large to locate barriers, detection

equipment, and isolation zones consistent with RG 4.7.

With respect to vehicular land and railroad approaches, the staff identified and evaluated

existing rDads, rail spurs, and site terrain features. The staff concluded that the location of

existing roads and site terrain features does not preclude the establishment of adequate vehicle

control measures to prevent potential adversaries from getting close to vital equipment or

protect against a vehicle.bomb. This conclusion is based on the fact that the OCA is sufficiently

large to enable the establishment of a vehicle checkpoint that has adequate standoff distance

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from the possible location of vital equipment to mitigate vehicle bomb overpressure effects.

The ESP facility would not use the same vehicle checkpoint that was used during the May 2004

site visit for the existing operating facility. The staff identified railroad lines and spurs and found

no features that would preclude the development of adequate security plans or measures. The

staff also confirmed during the site visit that it is feasible to implement a vehicle barrier system

over the terrain on all borders of the site.

With respect to deliberate vehicle explosions on nearby transportation routes, the staff analyzed

a gasoline tanker explosion of 8500 gallons of gasoline on Illinois Highway 54 at a point threefourths of a mile from the proposed site, which is the nearest approach to the site from a

highway. The analysis demonstrated that such an event would not result in an overpressure

greater than 1 psi at the site boundary (the pressure threshold for human eardrum rupture

is 5 psi, which is also the first point of human incapacitation per U.S. Army Technical

Manual 5-1300, "Structures to Resist the Effects of Accidental Explosions," issued

November 1990). According to RG 1.91, Revision 1, "Evaluations of Explosions Postulated To

Occur on Transportation Routes Near Nuclear Power Plants," issued February 1978, 1 psi of

peak positive overpressure is a conservative threshold. Below 1 psi, no significant damage

would be expected for structures, components, and systems of concern.

With respect to nearby hazardous materials facilities and nearby pipelines, the staff found that

the distances to those facilities and pipelines and the hazardous materials identified associated

with them were of such a nature that they did not pose an impediment to the development of

adequate security plans or measures.

The staff examined the overall site terrain with respect to natural features and existing

manmade features such as culverts that potential adversaries could use to their advantage; no

features that would preclude establishment of adequate security plans and measures were

found on the site.

The COL applicant will need to provide specific designs for protected area barriers, since such

design information is not available at the ESP stage. This is COL Action Item 13.6-1.

13.6.4 Conclusions

As described above, the staff examined the proposed ESP site characteristics to determine

whether they might affect the establishment of adequate security plans and measures. The

staff examined pedestrian, vehicle, and water approaches, including existing culverts, nearby

railroad lines, nearby hazardous materials facilities, nearby pipelines, and other transportation

routes and terrain features. Based on this evaluation, the staff concludes that the ESP site

characteristics would allow an applicant for a combined license or construction permit to

develop adequate security plans and measures for a reactor or reactors that the applicant might

construct and operate on the ESP site.

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15. ACCIDENT ANALYSES

15.1 Technical Information in the Application

In Section 3.3 of the site safety analysis report (SSAR), Exelon Generation Company (EGC or

the applicant) analyzed and provided the radiological consequences of design-basis accidents

(DBAs) -o demonstrate that a new nuclear unit(s) could be sited at the proposed early site

permit (ESP) site without undue risk to the health and safety of the public, in compliance with

the requirements of Title 10 of the Code of Federal Regulations (10 CFR), Section 52.17,

"Contents of Applications," and 10 CFR Part 100, "Reactor Site Criteria." The applicant did not

identify a particular reactor design to be considered for the proposed ESP site. Instead, the

applicant developed a set of reactor DBA source term parameters using surrogate reactor

characteristics. The applicant used these parameters, in conjunction with specific site

characteristics, to conduct the radiological consequences of DBAs for the purpose of assessing

the suitability of the proposed ESP site. These plant parameters collectively constitute a plant

parameter envelope (PPE).

The applicant developed a PPE using seven reactor designs, five water-cooled reactors and

two gas-cooled reactors, though it used source terms for only two of these designs as inputs to

the DBA analyses. The water-cooled reactors included in the PPE are (1) a version of the

Westinghouse Advanced Plant 1000 (AP I000), (2) the certified General Electric Advanced

Boiling-Water Reactor (ABWR), (3) the Atomic Energy of Canada Advanced CANDU Reactor

(ACR-700), (4) the General Electric Economic and Simple Boiling-Water Reactor (ESBWR),

and (5) tie Westinghouse-led International Reactor Innovative and Secure (IRIS) Reactor. The

ACR-700 is light-water cooled, but heavy-water moderated. The two gas-cooled reactors are

(1) the General Atomics Gas Turbine Modular Helium Reactor, and (2) the Pebble Bed Modular

Reactor. The applicant stated that the PPE values were not intended to be limited to these

reactor designs,.but rather to provide a broad overall outline of a design concept, which could

include other potential reactor designs if they fall within the parameter values provided in the

PPE.

In selecting DBAs for radiological consequence analyses, the applicant focused predominantly

on two light-water reactors, the certified ABWR and a version of the AP1000,1 to serve as

surrogates. The applicant stated that it selected these two reactor designs because they are

(or are based on) previously certified standard designs and have recognized bases for

postulated accident analyses. Using source terms developed from these two designs, the

applicant performed and provided radiological consequence analyses for the following DBAs:

* main steamline breaks (AP1000 and ABWR)

* reactor coolant pump locked rotor (AP1000)

* control rod ejection (AP1 000)

* control rod drop (ABWR)

* small line break outside containment (AP1000 and ABWR)

* steam generator tube rupture (APQ000)

As discussed later in this section, EGC originally referenced the version of the AP1000 design available at the time its ESP

application was submitted. Subsequently, EGC referenced the latest version of the AP1000 design (Revision 14 of the AP1000

Design Control Document) provided by Westinghouse in support of the final AP1000 design certification.

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* loss-of-coolant accidents (LOCAs) (AP1000, ABWR, ESBWR, and ACR-700)

* fuel handling accident (AP1000 and ABWR)

The applicant presented the radiological consequence assessment results in SSAR

Table 3.3-2. This table provides a summary of the postulated radiological consequences of the

DBAs identified above at the proposed exclusion area boundary (EAB) and the low population

zone (LPZ). The table also demonstrates that any potential doses would be within the

radiological dose consequence evaluation factors set forth in 10 CFR 50.34(a)(1). The

applicant provided the accident-specific source terms (i.e., release rates of radioactive materials

from the ESP footprint (PPE values) to the environment) and resulting site-specific dose

consequences for each DBA in the tables included in Chapter 3 of the SSAR.

In Request for Additional Information (RAI) 3.3.1-1, the staff noted that Westinghouse had

revised its x/O values in the AP1000 Design Control Document (DCD) since the applicant had

submitted its ESP application. The staff asked whether the applicant planned to use the

updated values in revising its application. The applicant responded in its submission to the U.S.

Nuclear Regulatory Commission (NRC) dated October 7, 2004, that it had elected not to update

the ESP application to incorporate the latest X/Q values in the AP1 000 design certification

because it had assessed the specific impact of the changes in X/Q values and found them to

have only a minor affect on the EAB and LPZ doses for the DBAs presented in the SSAR. The

applicant also stated that the ESP application used the X/Q values from Revision 2 of the

Westinghouse AP1 000 DCD, which was the most recently completed revision of the DCD at the

time the applicant submitted its ESP application.

In its submission to the NRC dated April 4, 2005, responding to Open Item 3.3-1, the applicant

changed its position and elected to update the ESP application to incorporate the latest

X/O values in the AP1000 design certification for the postulated LOCA only. SSAR Table 3.3-2

B provides the latest X/Q values the applicant used for the postulated LOCA. Subsequent to its

April 4, 2005, submission responding to Open Item 3.3-1, the applicant changed its position

again in its submission to the NRC dated July 14, 2005, and elected to further update the ESP

application to apply the latest x/C values in the AP1 000 DCD, Revision 14, which is the basis

for the AP1 000 design certification, to all DBAs, including the postulated LOCA. The staff

verified that the latest X/Q values the applicant used are the same as those in the AP1000 DCD

and in the final safety evaluation report (SER) prepared by the staff for the AP1000 design

certification.

In RAI 3.3.4-3, the staff noted that SSAR Section 3.3 provides total effective dose equivalent

(TEDE) values for the ABWR design, while the ABWR design is certified with the thyroid and

whole body doses specified in 10 CFR Part 100. The staff asked the applicant to explain how

the doses compare. In its response, the applicant provided revised tables in SSAR Chapter 3

that included the calculated thyroid and whole body doses, in addition to the estimated TEDE

values for the dose comparison. The staff finds the applicant's response acceptable.

In RAI 3.3.4-1, the staff asked the applicant to provide references and explain the methodology

it used to determine time-dependent activity releases for each DBA. The applicant provided the

requested references. In its response, the applicant stated that the respective DCDs present

the methodologies used for calculating time-dependent releases for the ABWR and AP1 000.

The staff finds the methodologies used in the respective DCDs to be acceptable. The applicant

further stated that for noncertified reactors the vendors have not provided the specific details of

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the methodology, but have provided time-dependent activity releases, which they consider to be

the best estimate of the limiting DBA activity releases. The staff finds the response acceptable.

In RAI 0.3.4-2, the staff asked the applicant to provide, for each DBA, the doses it used for the

EAB and the LPZ for the AP1 000, the ABWR, and the ACR-700 designs, as well as the ratios

of site-specific x/C values to design certification x/Qs used. In its response, dated

September 30, 2005, the applicant provided the requested information in a supplementary

table, "Tabulation of the Bases for the AP1 000 Design Basis Accident Offsite Doses at the EGC

ESP Site," as an attachment to the response to RAI 3.3.4-2. The table provided, for each DI3A,

the doses the applicant used for the EAB and the LPZ for the AP1 000. For the ABWR design,

the applicant stated that it did not base the doses provided on the ratios of the X/Q values, but

calculated them using the activity releases, the EGC ESP site-specific X/Q values, and the dose

conversion factors in Federal Guidance Reports 11 and 12. The applicant further stated thai it

projectei the offsite doses associated with the ESBWR and ACR-700 designs based on the

estimated activity releases to the environment provided by the vendors and the site-specific

x/Q values. The staff finds the applicant's response acceptable.

In RAI 3.3.2-1, the staff asked the applicant to clarify whether the 0- to 2-hour EAB doses

presented in the SSAR are for the 2-hour period with the greatest EAB doses. In its response,

the applicant stated that the greatest EAB dose occurs during the first 2 hours of the accident

for the ABWR, AP1000, and ACR-700 designs; however, the period from 1 to 3 hours yields the

greatest EAB dose from a LOCA for the AP1 000 design. The applicant clarified this information

in the application. The staff finds the applicant's response acceptable.

15.2 Recgulatorv Evaluation

In RAI 1.5-1, the staff asked the applicant to provide a comprehensive listing of NRC

regulations applicable to its ESP SSAR. In its response to RAI 1.5-1, the applicant stated that

NRC Review Standard (RS)-002, "Processing Applications for Early Site Permits,"

Attachment 2, identifies the NRC regulations applicable to its ESP SSAR. In response to

RAI 1.5-I, and in SSAR Table 1.5-1, the applicant identified the following applicable NRC

regulations and guidance cited in Chapter 15 of RS-002, Attachment 2, regarding reactor

accident radiological consequence analyses:

* 11CFR52.17

* 10 CFR Part 100

* 10 CFR 50.34, "Contents of Applications; Technical Information"

* Regulatory Guide (RG) 1.3, 'Assumptions Used for Evaluating the Potential Radiological

Consequences of a Loss-of-Coolant Accident for Boiling Water Reactors," issued Juna

1974

* R'3 1.25, "Assumptions Used for Evaluating the Potential Radiological Consequences of

a Fuel Handling Accident in the Fuel Handling and Storage Facility for Boiling and

Pressurized Water Reactors," issued March 1972

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* RG 1.145, "Atmospheric Dispersion Models for Potential Accident Consequence

Assessments at Nuclear Power Plants," issued November 1982

* RG 1.183, "Alternative Radiological Source Terms for Evaluating Design-Basis

Accidents at Nuclear Power Reactors," issued July 2000

* NUREG-0800, "Standard Review Plan for the Review of Safety Analysis Reports for

Nuclear Power Plants," issued July 1981

* Technical Information Document (TID)-14844, 'Calculation of Distance Factors for

Power and Test Reactor Sites," issued March 1962

The staff reviewed this portion of the application for conformance with the applicable

regulations and considered the corresponding regulatory guidance. In its evaluation, the staff

used the relevant dose consequence evaluation factors found in 10 CFR 50.34(a)(1) to

determine the acceptability of the site, in accordance with 10 CFR 52.17(a)(1).

The regulations in 10 CFR 52.17(a)(1) require that ESP applications contain an analysis and

evaluation of the major structures, systems, and components of the facility that bear

significantly on the acceptability of the site under the radiological consequence evaluation

factors identified in 10 CFR 50.34(a)(1). In addition, the ESP site characteristics must comply

with the requirements of 10 CFR Part 100. The regulations in 10 CFR 50.34(a)(1)(ii)(D) require

the following for a postulated fission product release based on a major accident:

* An individual located at any point on the boundary of the exclusion area for any 2-hour

period following the onset of the postulated fission product release would not receive a

radiation dose in excess of 25 rem TEDE.

* An individual located at any point on the outer boundary of the LPZ, who is exposed to

the radioactive cloud resulting from the postulated fission product release (during the

entire period of its passage), would not receive a radiation dose in excess of 25 rem

TEDE.

Because EGC has not selected a reactor design to be constructed on the proposed ESP site,

the applicant used a PPE approach to demonstrate that it meets these requirements. A PPE is

a set of plant design parameters that are expected to bound the characteristics of a reactor(s)

that may be constructed at a site, and it serves as a surrogate for actual reactor design

information. As discussed in RS-002 and Chapter 1 of this SER, the staff considers the PPE

approach an acceptable method for assessing site suitability. For the purposes of this analysis,

the applicant proposed fission product release rates from the ESP footprint (PPE values) to the

environment, and the staff reviewed the applicant's dose evaluation based on these release

rates.

15.3 Technical Evaluation

The applicant evaluated the suitability of the site under the radiological consequence evaluation

factors identified in 10 CFR 50.34(a)(1) using bounding reactor accident source terms and dose

consequences as a set of PPE values based predominantly on two surrogate designs, as well

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as site-.specific X/O values based on the ESP footprint. The following paragraphs describe the

staff's review of each aspect of this evaluation.

15.3.1 Selection of DBAs

The applicant selected the DBAs listed in Section 15.1 of this SER based on the proposed

AP1 000 design and the certified ABWR design, indicating that it chose these two reactor

designs because they have (or are based on) previously certified standard designs and have

recognized bases for postulated accident analyses. The staff finds that the applicant selected

DBAs that are consistent with those analyzed in NUREG-0800 and RG 1. 83. Therefore, the

staff finds that the applicant provided an acceptable DBA selection for evaluating the

compliance of the proposed ESP site with the dose consequence evaluation factors specified at

10 CFF 50.34(a)(1). The applicant stated that the DBAs analyzed in the proposed AP1000 and

certified ABWR DCDs are expected to bound the DBAs of the other reactors being considered

for the proposed ESP site. While it has not reviewed the designs other than the ABWR and

AP1 000 in detail, the staff believes that any conclusions drawn regarding the site's acceptability

based on the AP1 000 and ABWR designs are likely to be valid for the other reactor designs the

applicant is considering. Whether or not such designs are in fact bounded by these DBA

analyses would be subject to the staff's review during its consideration of any combined license

(COL) cr construction permit (CP) application that might be filed with respect to construction

and operation of a reactor design at the EGC ESP site.

15.3.2 Design-Specific (Postulated) X/O Values

In evaluating the AP1 000 design, the applicant originally used those X/Q values in the proposed

AP1 000 DCD, Revision 2, that were being reviewed by the staff at the time EGC submitted its

ESP application. Westinghouse subsequently revised the X/Q values in the AP1000 DCD. In

its submission to the NRC dated April 4, 2005, responding to Open Item 3.3-1, the applicant

updated the ESP application to incorporate the more conservative and latest X/Q values in the

AP1000 DCD, Revision 14, for the postulated LOCA only. For all other DBA radiological

consequence analyses, the applicant used X/Q values in the AP1 000 DCD, Revision 2.

Subsequent to the April 4, 2005, submission responding to Open Item 3.3-1, the applicant

changed its position again in its submission to the NRC dated July 14, 2005, and elected to

further update the ESP application to apply the latest X/Q values in the AP1000 DCD,

Revision 14, which is the basis for the AP1 000 design certification, to all DBAs, including the

postulated LOCA. The staff verified the latest X/Q values used by the applicant with those in

the AP1000 DCD and in the final SER prepared by the staff for the AP1000 design certification.

The latest X/Q values used by the applicant are shown in Table 15.3-1. The staff verified that

these X/C) values used by the applicant are the same as those in the AP1 000 design

certification document.

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Table 15.3-1 AP1 000 X/O Values (s/m3 )

Location and Time Interval y/Q Values

0 to 2 hour EAB 5.10x104

0 to 8 hour LPZ 2.20x104

8 to 24 hour LPZ 1.60x1 O4

1 to 4 day LPZ 1.00x104

4 to 30 day LPZ 8.00xl 05

In evaluating the ABWR, the applicant did not use the postulated X/Q values in the ABWR

certified DCD. Instead, the applicant calculated the radiological consequence doses using the

postulated activity releases in the ABWR DCD, the EGC ESP site-specific X/Q values, and the

dose conversion factors in Federal Guidance Reports 11 and 12.

15.3.3 Site-Specific X/Qs

In Section 2.3.4 of this SER, the staff reviewed the site-specific X/Q values calculated and

provided by the applicant and performed an independent evaluation of atmospheric dispersion,

in accordance with the guidance provided in Section 2.3.4 of RS-002. In its review, the staff

concluded, as described in Section 2.3.4 of the draft SER, that the applicant needed to provide

appropriate meteorological data and appropriate distances from the postulated accident source

term release points within the proposed ESP site to the proposed EAB and LPZ outer boundary

for use in estimating the site-specific X/Q values. Section 2.3.4 of the draft SER identified this

issue as Open Item 2.3-3. The site-specific X/Q values are used in the radiological

consequence evaluations for the proposed ESP site, and therefore, Section 3.3.3.4 of the draft

SER identified this open item, in part, as Open Item 3.3-1.

In its submission to the NRC dated April 4, 2005, the applicant responded to Open Item 2.3-3

and the related part of Open Item 3.3-1. In this submission, the applicant recalculated the

short-term accident X/Q values using three complete years of meteorological data from January

2000 to December 2002 (instead of January 2000 to August 2002 data previously used) and

using a minimum distance of 805 meters to the EAB (instead of 1025 meters previously used).

The applicant stated that the 805-meter distance is the minimum distance to the proposed EAB

from any point on the PPE of the ESP facility footprint. The applicant provided recalculated site

specific X/Q values in Table 1.4-1 of the SSAR. Based on the recalculated site-specific

X/Q values submitted by the applicant, the staff considers Open Item 2.3-3 resolved (see

Section 2.3.4 of this final SER).

15.3.4 Source Terms and Radiological Consequence Evaluations

To evaluate the suitability of the site using the radiological consequence evaluation factors in

10 CFR 50.34(a)(1), the applicant provided the bounding reactor accident source terms as a set

of PPE values based on (1) the surrogate AP1000 and certified ABWR designs (as explained

below), and (2) the site-specific X/Qs based on the ESP footprint. The source terms are

expressed as the timing and release rate of fission products to the environment from the

proposed ESP site. The dose consequences are then derived from the source terms using

established methods.

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The AP1000 source terms are based on the guidance provided in RG 1.183. The

methodologies and assumptions used by Westinghouse, the AP1000 vendor, in its radiological

consequence analyses are consistent with the guidance provided in RG 1.183. The resulting

doses calculated by the applicant for the proposed ESP site using the AP1 000 source terms,

postulated site parameters assumed in the AP1 000 DCD, and EGC ESP site-specific X/Qs

calculated by the applicant meet the dose consequence evaluation factors specified in

10 CFR 50.34(a)(1) (i.e., 25 rem TEDE).

The methodologies and assumptions used by General Electric, the ABWR vendor, in its

radiological consequence analyses for the ABWR design are consistent with the guidance

provided in RGs 1.3 and 1.25. The ABWR source terms are based on the guidance in

TID-14E44. The resulting doses for the proposed ESP site using the ABWR source terms ard

the EGO ESP site-specific x/Qs calculated by the applicant meet the dose consequence

evaluation factors in 10 CFR 100.11, "Determination of Exclusion Area, Low Population Zone,

and Population Center Distance" (i.e., 300 rem to the thyroid and 25 rem to the whole body).

While the requirements of 10 CFR 100.11 are not applicable to ESPs, the staff notes that the

final rule at Appendix A, "Design Certification Rule for the U.S. Advanced Boiling Water

Reactor." to 10 CFR Part 52, "Early Site Permits, Design Certifications, and Combined Licenses

for Nuclear Power Plants," states the following:

The Commission has determined that with regard to the revised design-basis

accident radiation dose acceptance criteria in 10 CFR 50.34, the ABWR design

meets the new dose criteria, based on the NRC staff's radiological consequence

analyses, provided that the site parameters are not revised.

Therefore, the staff concludes that the certified ABWR design, in conjunction with the assumed

site parameters, meets the dose consequence evaluation factors specified in 10 CFR 100.21,

"Non-Seismic Site Criteria," and 10 CFR 50.34(a)(1).

In the draft SER, the staff stated that the applicant did not use appropriate meteorological data

or appropriate distances from postulated release points to the EAB and the LPZ outer boundary

to estimate the site-specific x/C values used in the radiological consequence evaluations.

Therefore, the radiological consequence evaluation for the proposed ESP site was unresolvei.

The staff identified this as Open Item 3.3-1.

In its submission to the NRC dated April 4, 2005, the applicant responded to Open Item 3.3-1.

The applicant stated that it had recalculated the site-specific X/O values and site-specific dose

consequences; the tables in Chapter 3 of the SSAR provided the recalculated values. Based

on the recalculated site-specific X/Q values and the resulting recalculated site-specific dose

consequences, the staff considers Open Item 3.3-1 resolved.

In determining the potential radiological consequence doses resulting from DBAs at the

proposed site, the applicant used the site-specific X/Q values, in conjunction with the DBA

radiological consequence doses and the postulated X/Q values provided in the proposed

AP1000 DCD, Revision 14. The proposed AP1000 design used the postulated X/Q values to

meet the radiological consequence evaluation factors identified in 10 CFR 50.34 (a)(1).

The X/Q values indicate the atmospheric dilution capability. Smaller X/O values are associated

with greater dilution capability, resulting in lower radiological doses. The radiological

15-7
consequence doses are directly proportional to the X/Q values. The applicant provided the sitespecific X10 values used in its radiological consequence analyses in Table 1.4-1 of the SSAR,

and the staff discussed and evaluated the site-specific X/Q values in Section 2.3.4 of the final

SER.

The applicant used the atmospheric dispersion computer code (PAVAN) to derive its

site-specific X/Q values at the EAB and LPZ for evaluating the radiological consequences. The

staff describes the PAVAN code calculations for the proposed EGC ESP site in more detail in

Section 2.3.4 of the final SER.

The applicant compared the ratios of the site-specific X/Q values to the values postulated in the

AP 000 DCD, Revision 14, to demonstrate that the radiological consequence doses at the

proposed site meet the requirements of 10 CFR 50.34. The estimated site-specific X/Q values

for the proposed site are lower than the values postulated in the AP 000 DCD. The proposed

AP 000 designs met the radiological consequence evaluation factors identified in 10 CFR

50.34(a)(1) with the postulated X/Q values. Accordingly, the resulting DBA radiological

consequence doses at the proposed site are lower than the doses provided in the AP1000

DCD, Revision 14, and therefore, meet the requirements of 10 CFR 50.34.

In evaluating the ABWR, the applicant did not use postulated X/Q values in its certified ABWR

DCD. Instead, the applicant calculated the radiological consequence doses using the

postulated activity releases in the ABWR DCD, the EGC ESP site-specific X/Q values, and the

dose conversion factors in Federal Guidance Reports 11 and 12 to meet the dose consequence

evaluation factors specified in 10 CFR 100.11.

The staff believes that the radiological consequences of the DBAs at the proposed site based

on the AP1 000 and ABWR designs are likely to be acceptable for the other reactor designs the

applicant is considering. Whether the final reactor design the applicant selects at the EGC ESP

site is, in fact, bounded by the acceptance here would be subject to review during the staff's

consideration of a COL or CP application. In accordance with 10 CFR 52.79(a)(1), the staff will

evaluate, at the COL stage, whether the design of the facility falls within the parameters

specified in the ESP, should the NRC issue one for the EGC ESP site.

The staff has verified the design-specific radiological dose consequences used by the applicant

and finds them to be consistent with those evaluated by the staff as part of the design

certification reviews. Furthermore, the staff finds that the references provided by the applicant

and the methodology used to determine timing and release rate of fission product source terms

to the environment (and resulting dose consequences) from the proposed ESP site are

acceptable. Therefore, the staff finds the source terms from the ESP (PPE values) to be

reasonable and acceptable. The staff intends to include the site-specific X/Q values as site

characteristics listed in Appendix A to any ESP that the NRC might issue for the EGC ESP site.

Based on its evaluation of the applicant's analysis methodology and inputs to that analysis, the

staff finds that the applicant's conclusion that the dose consequences for the chosen surrogate

designs comply with the dose consequence evaluation factors of 10 CFR 50.34(a)(1) to be

correct.

The staff identified the following site XIQ values as appropriate for inclusion in any ESP that the

staff might issue for the EGC ESP site:

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Table 15.3-2 Site-Specific X/Q Values

Location and Time Interval y/Q Value

0 to 2 hour EAB 2.52x104 s/rM3

0 to 8 hour LPZ 3.00x1 0-5 s/M3

8 to 24 hour LPZ 2.02x105 s/r 3

1 to 4 day LPZ 8.53x104 s/m3

4 to 30 day LPZ 2.48x1 04 s/m3

RS-002 calls for the staff to perform a confirmatory radiological consequence calculation.

However, the design-related inputs to the applicant's dose calculation were directly extracted

from design documentation previously submitted to, and reviewed by, the NRC in connection

with design certification applications. Because the applicant simply used the ratio of the sitespecific X/Q values to the postulated design X/Q values, the staff did not consider an

independent calculation to be useful or necessary, and therefore, did not perform one.

At the COL stage, in accordance with 10 CFR 52.79(a)(1), the staff will evaluate whether the

design cf the facility falls within the parameters specified in an ESP, should one be issued for

the EGC ESP site. Should the COL applicant reference a certified design as well as the ESP,

and should the site characteristic X/Q values specified in the ESP fall within the postulated X/Qs

for the chosen certified design, the staff will likely conclude that the COL applicant has satisfied

this requirement. Should the COL applicant reference the ESP but not a certified design, the

staff will evaluate the source term for the chosen design and will use that source term and the

site x/Qs determined at the ESP stage to determine whether the applicable regulations at

10 CFR 50.34 regarding dose consequence evaluation factors have been met. In the event of

the filing of a CP referencing the ESP, the staff will evaluate the design's source terms and u.Me

the site )/Qs from the ESP to determine compliance with the requirements of 10 CFR 50.34.

15.4 Conclusions

As set forth above, the applicant submitted its radiological consequence analyses using the

site-specific X/Q values and PPE source term values and concluded that the proposed ESP site

meets the radiological consequence evaluation factors identified in 10 CFR 50.34(a)(1).

Based ori the reasons set forth above, the staff finds that the applicant's PPE values for

source terms included as inputs to the radiological consequence analyses are reasonable.

FurthermDre, the staff finds that the applicant's site-specific X/Q values and dose consequence

evaluation methodology are acceptable.

Therefore, the staff concludes that the proposed distances to the EAB and the LPZ outer

boundary of the proposed ESP site, in conjunction with the fission product release rates to the

environment provided by the applicant as PPE values, are adequate to provide reasonable

assurance that the radiological consequences of the DBAs will be within the dose consequence

evaluation factors set forth in 10 CFR 50.34(a)(1) for the proposed ESP site. This conclusion is

subject to confirmation at the COL or CP stage that the design of the facility specified by the

COL or C: applicant falls within the ESP PPE values.

15-9
The staff further concludes that (1) the applicant demonstrated that the proposed ESP site is

suitable for power reactors with source term characteristics bounded by those of the ABWR and

AP1 000 without undue risk to the health and safety of the public, and (2) the applicant complied

with the requirements of 10 CFR 52.17 and 10 CFR Part 100.

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117. EARLY SITE PERMIT QUALITY ASSURANCE MEASURES

17.1 Introduction

The applicant (Exelon Generation Company (EGC)) chose not to supply information on the

quality assurance (QA) measures it applied to the early site permit (ESP) activities described in

its application. The applicant, responding to a request for additional information (RAI) from the

U.S. Nuclear Regulatory Commission (NRC), subsequently submitted information on the QA

measures EGC and its principal contractors applied to ESP activities. The NRC staff inspected

the applicant's QA measures between January 12 and 16, 2004. Subsequently, the staff

performed an in-office technical review to evaluate whether the applicant and its principal

contractors had applied adequate QA measures. The staff also conducted a review to

determine whether the applicant had adequately applied the guidance in Section 17.1.1 of

Review Standard (RS)-002, "Processing Applications for Early Site Permits," Attachment 2,

issued in 2004, to demonstrate the integrity and reliability of the data obtained during ESP

activities.

Under Title 10, Section 52.18, "Standard for Review of Applications," of the Code of Federal

Regulations (10 CFR 52.18), the staff must review ESP applications in accordance with the

applicable regulations of 10 CFR Part 50, "Domestic Licensing of Production and Utilization

Facilities," and its appendices, as well as 10 CFR Part 100, "Reactor Site Criteria," as they

apply to construction permits. The current regulations do not require ESP holders or applicants

to implement a QA program compliant with the requirements of Appendix B, "Quality Assurance

Criteria for Nuclear Power Plants and Fuel Reprocessing Plants," to 10 CFR Part 50. However,

the applicant is expected to implement QA measures equivalent in substance to the measures

described in Appendix B to 10 CFR Part 50. This will provide reasonable assurance that any

information derived from ESP activities that could be used in the design and/or construction of

structures, systems, and components (SSCs) important to safety will support satisfactory

performance of such SSCs once they are in service. Therefore, the staff evaluated quality

measures for those activities associated with the applicant's generation of site-related

information that could be used as input to the design of future SSCs to ensure that these

measures can provide reasonable assurance of the integrity and reliability of the information,

assuming that the applicant's QA measures are equivalent in substance to the criteria of

Appendix B to 10 CFR Part 50.

In accordance with 10 CFR 52.79(a)(1), if an application for a combined license (COL)

references an ESP, it must contain information sufficient to demonstrate that the design of the

facility falls within the parameters specified in the ESP. Therefore, the ESP applicant must

provide reasonable assurance of the reliability and integrity of the data contained in or

supporting the ESP application, which in turn supports the COL application.

Conformance with the QA measures described in Section 17.1.1 of RS-002, Attachment 2,

provides reasonable assurance that the applicant used adequate QA measures to support its

ESP application. The staff focused its review on whether the applicant's QA measures

adequately addressed the guidance in Section 17.1.1 of RS-002, Attachment 2, for each

applicable element (as determined by the applicant). The staff performed much of its

evaluation in an inspection conducted in January 2004 and documented in Inspection

Report 0520007/2004001, "Exelon Generation Company, LLC-NRC Inspection of Applicant

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and Contractor Quality Assurance Activities Involved with Preparation of the Application for an

Early Site Permit" (Agencywide Documents Access and Management System (ADAMS)

Accession No. ML040540622), in February 2004. For any element the applicant determined

was not applicable, the staff verified that the ESP activities did not rely on QA measures

associated with that element. The review focused on the applicant and its primary contractor,

CH2M HILL. Inspection Report 0520007/2004001 includes details on additional subcontractors

involved in the EGC ESP activities. Section 17.7 of this SER discusses the adequacy of the QA

measures used by these additional subcontractors.

In response to an RAI, the applicant submitted the description of the QA measures it applied to

the ESP activities. The staff reviewed the EGC general guidance to its subcontractors for the

quality measures applied to ESP activities. EGC Instruction AP-AA-1000, "Early Site Permit

Project Quality Assurance Instructions," Revision 0, issued in 2004 (hereafter referred to as the

instruction), states that activities related to the development of the application will be conducted

in accordance with 10 CFR Part 52, 'Early Site Permits; Standard Design Certifications; and

Combined Licenses for Nuclear Power Plants." The applicant's subcontractors conducted their

ESP activities in accordance with their own QA measures, by direction provided in procurement

documents, or in accordance with the primary contractor's required QA measures.

17.1.1 Technical Information in the Application (Organization)

The EGC application did not initially supply information about its QA organization, but the

applicant subsequently provided this information in response to an RAI. The applicant's

instruction identifies certain criteria of Appendix B to 10 CFR Part 50 that contain elements

associated with the control of ESP activities. The instruction states that the applicant will apply

elements from these criteria or verify that the controls applied to the ESP activities reflect these

elements. The applicant considered organization to be a criterion having elements associated

with the control of ESP activities.

The instruction states that EGC is responsible for the establishment and execution of an ESP

project QA plan. The applicant typically delegates to others, such as contractors or

consultants, the work of establishing and executing the QA plan, or part thereof, but retains

overall responsibility.

The instruction further states that an appropriate level of EGC management will have overall

responsibility for the ESP project. EGC management will have authority and responsibility to

establish a program such that the persons and organizations performing QA functions have

sufficient authority and organizational freedom to identify quality problems; to initiate,

recommend, or provide solutions; to verify implementation of solutions; and to have direct

access to such levels of management as may be necessary to perform these functions. The

instruction also states that individuals performing audits should possess experience, training, or

background at least sufficient to assess the quality of the product provided by the contractor.

The CH2M HILL "Project Quality Plan for Exelon Early Site Permit" (hereafter referred to as the

Project Quality Plan (PQP)) describes the organizational, programmatic, and procedural

requirements intended to result in a complete and accurate application and states that the

contractor will use, where appropriate, the pertinent elements of Appendix B to 10 CFR Part 50.

17-2
The POP states that, while EGC retains the overall responsibility for the completeness and

accuracy of the information to be provided in support of obtaining an ESP, it delegated the

initial gathering and analysis of that information to CH2M HILL. The PQP also establishes and

communicates the authority and duties of persons and organizations performing quality

management and provides an organization chart.

17.1.2 Regulatory Evaluation (Organization)

While the applicant is not required to develop an organization to comply with the criteria of

Appendix B to 10 CFR Part 50, Section 17.1.1 of RS-002, Attachment 2, contains guidance For

the staff to use in evaluating an ESP applicant's organization. The applicant's instruction

outlines the elements of an organization that the applicant applied to its ESP activities.

Paragraph 17.1.1.1 in RS-002, Attachment 2, Section 17.1.1, provides the QA measures that

constitute an acceptable organization. An acceptable organization should include (1) an

organization description and charts of the lines, interrelationships, and areas of responsibility

and authority for all organizations performing quality-related activities, including the applicant's

organization and principal contractors, (2) the relative location of the QA organization, degree of

independence from the organization performing ESP activities, and authority of the individuals

assigned the responsibility for performing QA functions, and (3) the organizational provisions

that exist for ensuring the proper implementation of QA controls.

17.1.3 Technical Evaluation (Organization)

17.1.3.1 Exelon Generation Company

The PQI1 identifies the authority and responsibilities of persons and organizations performing

quality management functions. The EGC project manager is primarily responsible for directing

the project staff to complete the ESP application.

The site safety analysis report (SSAR) lead had overall responsibility for the technical content

and completion of the report. The NRC staff interviewed individuals carrying out these

responsibilities. Based on these interviews and the review of project documentation, the staff

determined that the applicant's staffing for these positions is consistent with the descriptions in

the PQP. The PQP also describes the assignment of responsibilities to lead technical positions

for key project areas. Based on its review of the overall project documentation, the staff

determined that the PQP accurately describes these positions.

The applicant developed procedures specific to ESP activities, as detailed in Inspection

Report 0520007/2004001. The staff reviewed the program procedures and noted that the

procedures meet the guidance in Section 17.1.1 of RS-002, Attachment 2. The applicant

adequately described the ESP organization and personnel responsibilities.

The instruction indicates that EGC is responsible for the establishment and execution of a

project CIA plan for an ESP project, but that EGC typically delegates to others, such as

contractors, the work of establishing and executing the QA plan. The instruction further

indicates that EGC management will ensure that persons and organizations performing QA

functions have sufficient authority and organizational freedom to (1) identify problems in quality,

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(2) initiate, recommend, or provide solutions, and (3) verify implementation of solutions. The

instruction also indicates that EGC management will ensure that persons and organizations

performing QA functions have direct access to any level of management necessary to perform

these functions.

The staff interviewed the EGC QA audit personnel who conducted the audits of ESP activities

and reviewed their personnel training records. The applicant indicated that its project staff

received on-the-job training related to ESP activities. However, the applicant did not develop

formal training plans or maintain training records. The applicant stated that it had assembled

personnel for the project whose experience precluded the need for formal training. The staff

reviewed the resumes of several EGC ESP project personnel and found that the resumes

demonstrate satisfactory experience and education for each of the individuals reviewed.

17.1.3.2 CH2M HILL

The staff reviewed the CH2M HILL PQP. The applicant indicated that the PQP, prepared by

CH2M HILL and reviewed by EGC, provides quality controls to ensure that the preparation of

the EGC ESP application followed quality practices commensurate with the intended use of the

application and its content. CH2M HILL prepared procedures for those quality functions the

PQP described. The staff reviewed several CH2M HILL procedures in detail, as described in

Inspection Report 0520007/2004001, to ensure the adequacy of the procedures to perform their

stated purpose. The staff also determined that the procedures adequately identified the

organizational roles and responsibilities regarding managerial and administrative controls for

the project.

The staff reviewed training and qualification records for CH2M HILL personnel and other

contractors involved in ESP-related activities. The staff also reviewed the CH2M HILL

organizational structure and personnel responsibilities. The staff did not identify any issues.

17.1.4 Conclusion (Organization)

As set forth above, the staff reviewed the applicant's QA measures and those of its primary

contractor and concluded that both EGC and CH2M HILL have implemented an acceptable

organization which meets the guidance in Section 17.1.1 of RS-002, Attachment 2, and helps

provide reasonable assurance that any information derived from ESP activities that could be

used in the design and/or construction of SSCs important to safety will support satisfactory

performance of such SSCs once they are in service.

17.2 Quality Assurance Program

17.2.1 Technical Information in the Application (QA Program)

The EGC application did not initially supply information about the QA program, but the applicant

subsequently provided this information in response to an RAI. The applicant's instruction

identifies certain criteria of Appendix B to 10 CFR Part 50 that contain elements associated with

the control of ESP activities. The instruction states that the applicant would apply elements

from these criteria or verify that the controls applied to the ESP activities reflected these

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elements. The applicant considered the QA program to be a criterion having elements

associated with the control of ESP activities.

The instruction states that EGC will establish, for each ESP project, a POP that complies with

the requirements of this procedure and includes relevant and instructive elements from the

criteria in Appendix B to 10 CFR Part 50 identified herein. This PQP will also include other

controls and criteria that the applicant's project management has determined to be necessary

or desirable.

The instruction states that the primary contractor retained by EGC to prepare the ESP

application will typically prepare the POP and associated subtier documentation and EGC ESP

project management will approve these documents. The primary contractor's POP describes

the organizational, programmatic, and procedural requirements intended to result in a complete

and accurate application and states that the contractor will use, where appropriate, the pertinent

elements of Appendix B to 10 CFR Part 50.

The PQP details the quality processes that define the QA program. Attributes of the QA

program include (1) creating the PQP to identify the applicable quality requirements,

(2) establishing document and record control programs, (3) selecting personnel for the project

based on knowledge, skills, and abilities, (4) conducting or directing audits, (5) reviewing

reports, and (6) researching project contract requirements.

17.2.2 .Regulatory Evaluation (QA Program)

While the NRC does not require a QA program to comply with the criteria of Appendix B to

10 CFR Part 50, Section 17.1.1 of RS-002, Attachment 2, contains guidance for the staff to use

in evaluating an ESP applicant's QA program. The applicant's instruction describes the

elements of a project QA plan that the applicant applied to ESP activities.

Paragraph 17.1.1.2 in Section 17.1.1 of RS-002, Attachment 2, provides the QA measures that

constitute an acceptable level of control for ESP activities. The QA program should include

(1) a scope of QA controls adequate to ensure that appropriate quality controls are applied to

all site characterization data related to the design and analysis of SSCs important to safety that

might be constructed on the proposed site, (2) provisions to ensure proper definition of QA

controls, and (3) provisions to ensure the adequacy of personnel qualifications.

17.2.3 Technical Evaluation (QA Program)

This section of the safety evaluation report (SER) documents the staff's evaluation of the

applicant's and its primary contractor's overall QA program description. The following sections

of this SER provide a detailed review and evaluation of each applicable portion of the program.

17.2.3.1 Exelon Generation Company

The staff reviewed the applicant's instruction, which describes the elements of the ESP QA plan

prepared by CH2M HILL. The instruction identifies the pertinent elements of the criteria stated

in Appendix B to 10 CFR Part 50 that apply to controls for the ESP application. The instruction

also identifies responsibilities for the establishment and execution of the PQP for the ESP by

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others, such as contractors or consultants. The instruction states that EGC management

retains overall responsibility for the project, including the responsibility for attaining quality

objectives, and -that-persons-and organizations with QA functions have the organizational

freedom to identify quality-related problems. Additionally, the instruction states that the

individuals performing audits of the plan have the experience, training, or background

necessary to assess the quality of the product provided by the contractor. The staff reviewed

the resumes and training records of EGC individuals involved with QA plan oversight and audit

and found their qualifications and training to be adequate.

The staff reviewed the applicant's procedures that provide general guidance to its

subcontractors in applying the quality measures to ESP activities. The instruction states that

EGC will conduct activities related to the development of the application in accordance with

10 CFR Part 52. The applicant determined that the Exelon Nuclear Quality Assurance Topical

Report does not apply to ESP activities. However, the applicant did determine that elements of

certain criteria of Appendix B to 10 CFR Part 50 are applicable. As detailed in Inspection

Report 0520007/2004001, EGC delegated the ESP activities. The applicant's subcontractors

conducted their ESP activities in accordance with their own QA measures, by direction provided

in procurement documents, or in accordance with the lead contractor's required QA measures.

The staff found the guidance provided by the instruction to be adequate as an overall guide for

the conduct of ESP activities.

17.2.3.2 CH2M HILL

CH2M HILL led the compilation of information for the SSAR. CH2M HILL conducted such tasks

as seismic analysis, QA audit activities, environmental report preparation, and contract

preparation. The staff reviewed the PQP developed by CH2M HILL for the EGC ESP project.

The POP describes the quality program for the development of the ESP application. The PQP

states that CH2M HILL will develop the application in accordance with the requirements of

10 CFR Part 52. The POP describes the project organization, quality objectives and criteria,

and project quality processes. The PQP organizes the project quality processes around the

criteria found in Appendix B to 1.0 CFR Part 50 that were to be applied to the ESP activities

conducted by CH2M HILL. In addition, CH2M HILL developed procedures that amplify EGC

guidance on the conduct of ESP activities. Inspection Report 0520007/2004001 provides

additional information on the staff's review of these procedures.

The POP states that, while the applicant retained the overall responsibility for the completeness

and accuracy of the information provided in support of obtaining an ESP application, it

delegated the initial gathering and analysis of this information to CH2M HILL. The document

further states that the PQP provides adequate controls to ensure that the EGC ESP application

was prepared under quality practices commensurate with the intended use of the application

and its content. To that end, the PQP applied, as necessary, only certain elements of the

criteria set forth in Appendix B to 10 CFR Part 50, as well as other quality standards. As stated

in RS-002, Attachment 2, Section 17.1.1, an applicant may determine the applicable quality

measures. The staff reviewed the quality measures that CH2M HILL considered to be

applicable and determined that these measures are adequate for the activities conducted in

support of the EGC ESP activities.

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17.2.4 Conclusion (QA Program)

As set forth above, the staff reviewed the applicant's QA measures and those of its primary

contractor and concluded that these measures form an acceptable QA program which meets

the guidance in Section 17.1.1 of RS-002, Attachment 2, and helps provide reasonable

assurance that any information derived from ESP activities that is used in the design and/or

construction of SSCs important to safety will support satisfactory performance of such SSCs

once they are in service.

17.3 Design Control

17.3.1 Technical Information in the Application (Design Control)

The EGC application did not initially supply information on design controls, but it subsequently

provided this information in response to an RAI. The applicant's instruction identifies certain

criteria of Appendix B to 10 CFR Part 50 that contain the elements associated with the control

of ESP activities. The instruction states that the applicant would apply elements from these

criteria or verify that the controls applied to ESP activities reflect these elements. The applicant

did not consider design controls to be a criterion having elements associated with the control of

ESP activities.

The instruction states that the PQP will include controls for the development of and/or changes

to ESP project products. However, the instruction also states that, since no activities

associated with SSCs are to be conducted under this project, no QA measures are necessary

for the control of design processes.

The PQFP of the primary contractor describes the organizational, programmatic, and procedural

requirements intended to result in a complete and accurate application and states that the

contractor will use, where appropriate, the pertinent elements of Appendix B to 10 CFR Part 50.

The PQF' describes application development inputs, outputs, development review, and control

of development changes. The PQP states that the applicant will plan and control development

of the EISP application. Development planning will determine (1) stages of the development

process, (2) required review and verification and validation (V&V) activities appropriate to each

development state, and (3) responsibilities and authorities for development activities. The POP

states the controls for development of inputs and outputs.

According to the PQP, the applicant will manage interfaces among different groups involved in

development to provide effective communication and clear assignment of responsibilities. The

PQP also states that the applicant will review and approve documents prepared for the ESP

application, identify development changes, and maintain records of the changes.

In RAI 17.1.1-2, the staff asked the applicant to describe the QA measures it used to

authenticate and verify any data important to safety that it retrieved from Internet Web sites and

that support information in the SSAR that could affect the design, construction, or operation or

SSCs important to safety. In its response, the applicant stated that the measures it relied on lo

authenticate data retrieved from Internet Web sites include formal documentation of the Interret

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Web site used, peer review of the resulting application information, and independent

examination of the source.

17.3.2 Regulatory Evaluation (Design Control)

While the NRC does not require design controls to comply with the criteria in Appendix B to

10 CFR Part 50, Section 17.1.1 of RS-002, Attachment 2, contains guidance for the staff to use

in evaluating an ESP applicant's design controls. The applicant's instruction details the design

controls applied to ESP activities.

Paragraph 17.1.1.3 in Section 17.1.1 of RS-002, Attachment 2, provides the QA measures that

constitute an acceptable level of design control. Acceptable design controls should include

(1) the scope of activities that could affect design and construction activities for SSCs important

to safety that might be constructed on the site, (2) a definition of the organizational structure,

activity, and responsibility of the positions or groups responsible for design activities important

to safety (if any), (3) provisions to carry out design activities important to safety in a planned,

controlled, and orderly manner, (4) provisions for interface control between functional units of

the applicant's organization, (5) provisions to verify the technical adequacy of design

documents applicable to ESP activities that could affect SSCs important to safety, and

(6) provisions to control design changes applicable to ESP activities that could affect SSCs

important to safety.

17.3.3 Technical Evaluation (Design Control)

17.3.3.1 Exelon Generation Company

The EGC ESP application identified CH2M HILL as the primary contractor providing personnel,

systems, project management, and resources for the EGC ESP project. Further, CH2M HILL

procured engineering services and support for specific design control activities from

subcontractors, including Parsons Power Group, Inc. (Parsons), Geomatrix Consultants, and

GRL Engineers, Inc. (GRL). The staff reviewed and verified the adequacy of design control

activities for each of these companies. Section 17.7 of this SER provides additional details on

this topic.

The staff evaluated the applicant's response to RAI 17.1.1-2 concerning the QA measures it

used to authenticate and verify data that were retrieved from Internet Web sites and that

support information in the SSAR affecting the design, construction, or operation of SSCs

important to safety. In its response to the RAI, the applicant described the method used to

authenticate or verify the data. The staff found this method of authenticating Internet Web site

data to be acceptable. The staff stated that it would verify completion of the applicant's method

of authentication as part of its inspection program before developing the final SER. The staff

identified this item as Confirmatory Item 17.3-1.

The staff conducted a followup inspection of Confirmatory Item 17.3-1 on May 19, 2005, at the

applicant's offices in Kennett Square, Pennsylvania. The staff determined, through review of

supporting documentation, that the applicant had provided adequate QA measures to

authenticate and verify data retrieved from Internet Web sites that support information in the

SSAR that would affect the design, construction, or operation of SSCs important to safety.

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Specifically, the applicant's primary contractor (CH2M HILL) had technically qualified personnel

review data retrieved from Internet Web sites, using a documented process. Subject matter

experts reviewed the data again during an independent review conducted after the SSAR was

completed. Based on this inspection, the staff concludes that Confirmatory Item 17.3-1 is

resolved.

17.3.3.2 CH2M HILL

The applicant delineated the ESP work scope and quality requirements for CH2M HILL in a

contract:, as detailed in Inspection Report 0520007/2004001. The work scope identifies specific

sections of the ESP application for which CH2M HILL was responsible for performing design

control activities supporting analyses, evaluations, and procurement, as well as for ensuring

that personnel involved with the project were trained and knowledgeable about the QA design

control requirements. The staff reviewed CH2M HILL procedures and interviewed the

responsible project and QA managers.

The staff reviewed the PQP, which describes the quality program for the development of an

ESP application and outlines the ESP organizational, programmatic, and procedural

requirements. The PQP also defines responsibilities regarding the traceability and

appropriateness of information before its use in any design document.

The staff reviewed the PQP, as it relates to design control for ESP activities. The PQP

describes the project quality processes, including organizational authority, responsibilities for

completeness and accuracy of information, and gathering and analysis of information to support

ESP application development. The PQP describes ESP design control elements related to

Appendix B to 10 CFR Part 50. The PQP also provides for quality processes in the

communication of the quality requirements of the PQP to the project leads and training of

personnel used to perform activities affecting quality. The PQP describes development

planning to determine required review and V&V activities related to the ESP project. It also

provides for determination of functional and performance requirements and applicable statutory

and regulatory requirements. Additionally, it establishes criteria for the approval of

development inputs and outputs and the review and control of development changes, including

computer software control.

The staff also reviewed several CH2M HILL ESP design control procedures, as detailed in

Inspection Report 0520007/2004001. The staff concluded that the design control measures

described in the CH2M HILL PQP and other reviewed procedures and documents are

adequate.

17.3.4 Conclusion (Design Control)

As set forth above, the staff reviewed the CH2M HILL QA control measures and concluded that

the contractor implemented acceptable design controls which meet the guidance of

Section 17.1.1 of RS-002, Attachment 2, and help provide reasonable assurance that any

information derived from ESP activities that is used in the design and/or construction of SSCs

important to safety will support satisfactory performance of such SSCs once they are in service.

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17.4 Procurement Document Control

17.4.1 Technical Information in the Application (Procurement Document Control)

The EGC application did not supply information about procurement document control, but the

applicant subsequently provided this information in response to an RAI. The applicant's

instruction identifies certain criteria of Appendix B to 10 CFR Part 50 that contain the elements

associated with the control of ESP activities. The instruction states that the applicant will apply

elements from these criteria or verify that the controls applied to the ESP activities reflected

these elements. The applicant considered procurement document control to be a criterion

having elements associated with the control of ESP activities.

The instruction states that the PQP will include controls for the procurement of ESP project

products (including services). The instruction further states that the applicant will contract with

vendors to provide services in connection with ESP activities in accordance with appropriate

EGC nuclear supply management procedures for nonsafety-related services.

The PQP of the primary contractor describes the organizational, programmatic, and procedural

requirements intended to result in a complete and accurate application and states that the

contractor will use, where appropriate, the pertinent elements of Appendix B to 10 CFR Part 50.

The POP states that measures will be established to assure that the documents for

procurement of material, equipment, and services (whether purchased by CH2M HILL, its

contractors, or its subcontractors) suitably include or reference the applicable regulatory, design

bases, and other requirements necessary to assure adequate quality. The POP further states

that, to the extent necessary, procurement documents will require contractors or subcontractors

to provide a QA program that is at least consistent with the pertinent provisions of the POP.

17.4.2 Regulatory Evaluation (Procurement Document Control)

While the NRC does not require procurement document controls to comply with the criteria in

Appendix B to 10 CFR Part 50, Section 17.1.1 of RS-002, Attachment 2, contains guidance for

the staff to use in evaluating an ESP applicant's procurement document controls. The

applicant's instruction details the procurement document controls it applied to ESP activities.

Paragraph 17.1.1.4 in Section 17.1.1 of RS-002, Attachment 2, provides the QA measures that

constitute an acceptable level of procurement document controls. Acceptable procurement

document controls should include (1) provisions to ensure that procurement documents related

to ESP activities that could affect SSCs important to safety include or reference applicable

technical requirements and QA controls, and (2) provisions for review and approval of

procurement documents for ESP activities that could affect SSCs important to safety.

17.4.3 Technical Evaluation (Procurement Document Control)

17.4.3.1 Exelon Generation Company

The EGC project manager served as the contract administrator in authorizing all services

procured under the ESP application contract. During review of the contract file governing the

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ESP application, the NRC staff interacted with the project manager and the contract specialist

and found them knowledgeable about contract administration.

The staff reviewed the EGC agreement, which authorizes the primary contractor's scope of

work. The contract defines the scope of work to be performed. Quality requirements

incorporated as part of the contract stipulate that the scope of work should ensure that

individual tasks are accomplished with the appropriate level of quality controls, such that the

quality of the data would not be questioned during their subsequent use in the COL process, as

set forth in 10 CFR Part 52. The contract requires a detailed written description of the quality

control practices employed and the corresponding data or information to which these controls

were applied.

17.4.3.2 CH2M HILL

EGC selected CH2M HILL as the primary contractor for preparing the ESP application. The

CH2M HILL proposal specified that the existing CH2M HILL QA program, which implements its

quality management system (QMS), would be used for the ESP task to the extent applicable.

The proposal also specified that CH2M HILL would review and approve all reports and records

required by the application before forwarding them to EGC.

The NRC staff interviewed the CH2M HILL project manager and QA manager regarding

authorization of subcontract procurement. The CH2M HILL project manager authorizes CH2M

HILL procurement in coordination with the CH2M HILL procurement officer located in the CH2M

HILL Tucson, Arizona, office.

Based on its review of procurement purchase orders and interviews with authorizing contract

personnel, the staff found the authorizing individuals knowledgeable about EGC QA

requirements. Section 17.7 of this SER discusses specific details of the procurement controls

applied to each subcontractor.

17.4.4 Conclusion (Procurement Document Control)

As set forth above, the staff reviewed the QA measures employed by the applicant and its

primary contractor and concluded that they have implemented an acceptable level of

procurerrent document control, which meets the guidance of Section 17.1.1 of RS-002,

Attachment 2, and helps provide reasonable assurance that any information derived from ESF'

activities that is used in the design and/or construction of SSCs important to safety will support

satisfactory performance of such SSCs once they are in service.

17.5 Instructions, Procedures, and Drawings

17.5.1 Technical Information in the Application (Instructions, Procedures, and Drawings)

The EGC application did not initially supply information about the control of instructions,

procedures, and drawings, but the applicant subsequently provided this information in response

to an RAI. The applicant's instruction identifies certain criteria of Appendix B to 10 CFR Part 50

that contain the elements associated with the control of ESP activities. The instruction states

that the applicant would apply elements from these criteria or verify that the controls applied to

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ESP activities reflect these elements. The applicant considered control of instructions,

procedures, and drawings to be a criterion having elements associated with the control of ESP

activities.

The instruction states that the POP will include controls for ESP project activities to be

conducted in accordance with documented instructions, procedures, or drawings for which ESP

project management deemed such written controls to be necessary. In addition, the instruction

states that documented instructions, procedures, or drawings will control EGC activities

required by the POP. The primary contractor describes in its POP the organizational,

programmatic, and procedural requirements intended to result in a complete and accurate

application and will use, where appropriate, the pertinent elements of Appendix B to 10 CFR

Part 50.

The POP states that activities affecting quality will be prescribed by and accomplished in

accordance with documented instructions, procedures, or drawings of a type appropriate to the

circumstances. Instructions, procedures, or drawings will include appropriate quantitative or

qualitative acceptance criteria for determining that important activities have been satisfactorily

accomplished. The applicant will document work processes to the level required to complete

the work in a consistent manner that meets applicable guidance.

17.5.2 Regulatory Evaluation (Instructions, Procedures, and Drawings)

While the NRC does not require instructions, procedures, and drawings to comply with the

criteria of Appendix B to 10 CFR Part 50, Section 17.1.1 of RS-002, Attachment 2, contains

guidance for the staff to use in evaluating an ESP applicant's instructions, procedures, and

drawings. The applicant's instruction lists the controls for instructions, procedures, and

drawings it applied to ESP activities.

Paragraph 17.1.1.5 in Section 17.1.1 of RS-002, Attachment 2, provides the QA measures that

constitute an acceptable level of control for instructions, procedures, and drawings. Acceptable

controls for instructions, procedures, and drawings should include (1) provisions for ensuring

that ESP activities that could affect SSCs important to safety are prescribed by and

accomplished in accordance with instructions, procedures, or drawings, and (2) provisions for

including quantitative and qualitative acceptance criteria in instructions, procedures, and

drawings related to ESP activities that could affect SSCs important to safety.

17.5.3 Technical Evaluation (Instructions, Procedures, and Drawings)

17.5.3.1 Exelon Generation Company

The applicant developed program procedures specific to ESP activities, as detailed in

Inspection Report 0520007/2004001. The staff reviewed the program procedures and noted

that the procedures meet the guidance in Section 17.1.1 of RS-002, Attachment 2. Additionally,

the staff discusses the adequacy of instructions, procedures, and drawings in other technical

evaluation sections of this SER.

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17.5.3.2 CH2M HILL

The staff reviewed the PQP. According to the applicant, CH2M HILL prepared the POP, and

EGC reviewed it, to provide quality controls to ensure that the EGC ESP application was

prepared under quality practices commensurate with the intended use of the application and its

content. CH2M HILL prepared procedures for those quality functions described in the POP.

The staff reviewed several procedures, as detailed in Inspection Report 0520007/2004001, to

determine the adequacy of the procedures to perform their stated purpose. The staff found that

the instuctions, procedures, and drawings developed and used for ESP activities are adequate.

17.5.4 Conclusion (Instructions, Procedures, and Drawings)

As set f.orth above, the staff reviewed the QA measures employed by the applicant and its

primary contractor and concluded that they have implemented an acceptable level of control for

instructions, procedures, and drawings which meets the guidance of Section 17.1.1 of RS-002,

Attachment 2, and helps provide reasonable assurance that any information derived from E.SP

activities that is used in the design and/or construction of SSCs important to safety will support

satisfactory performance of such SSCs once they are in service.

17.6 Document Control

17.6.1 Technical Information in the Application (Document Control)

The EG(G application did not supply information on document control, but the applicant

subsequently provided this information in response to an RAI. The applicant's instruction

identifies certain criteria of Appendix B to 10 CFR Part 50 that contain elements associated with

the control of ESP activities. The instruction states that the applicant will apply elements from

these criteria or verify that the controls applied to ESP activities reflect these elements. The

applicant considered document control to be a criterion having elements associated with the

control of ESP activities.

The instruction states that the POP will include controls for issuance of documents related to

the ESP project. The instruction also states that the applicant will provide controls for review

and acceptance of completed project documents and that the POP will establish methods for

the control of changes to project documents, including a means for notifying appropriate

individuals of document changes.

The POP of the primary contractor describes the organizational, programmatic, and procedural

requirements intended to result in a complete and accurate application and states that the

contractor will use, where appropriate, the pertinent elements of Appendix B to 10 CFR Part 50.

The POP states that measures will be established to control the issuance of documents, such

as instructions, procedures, and drawings, including changes thereto, which prescribe all

activities affecting quality. These measures will assure that authorized personnel review

documents, including changes, for adequacy and approve them for release, and that these

documents are distributed to and used at the location where the prescribed activity is

performed. The same organization(s) that performed the original review and approval will

review and approve changes to those documents, unless the applicant designates another

responsible organization.

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17.6.2 Regulatory Evaluation (Document Control)

While the NRCdoes not require document control to-comply with-the criteria of Appendix B to

10 CFR Part 50, Section 17.1.1 of RS-002, Attachment 2, contains guidance for the staff to use

in evaluating an ESP applicant's document controls. In the instruction, the applicant provided

the document controls it applied to ESP activities.

Paragraph 17.1.1.6 in Section 17.1.1 of RS-002, Attachment 2, provides the QA measures that

constitute an acceptable level of document control. Acceptable document controls should

include provisions to ensure that documents related to ESP activities that would affect SSCs

important to safety, including changes, are reviewed for adequacy, approved for release by

authorized personnel, and distributed and used at the location where the prescribed activity is

performed.

17.6.3 Technical Evaluation (Document Control)

Section 17.5 of this SER gives a detailed discussion of the document controls applied by the

applicant. In addition, each section of this SER details the specific documents reviewed and

any relevant discussions of their adequacy. The staff considers the scope of the documents

reviewed to be adequate for the ESP activities that were conducted. The staff reviewed

documents that were reviewed and approved for issuance to ensure the document control

process was followed. The staff confirmed that the applicant and its primary subcontractor had

adequate controls in place to ensure the proper revision of a document.

17.6.3.1 Exelon Generation Company

Inspection Report 0520007/2004001 discusses the staff's review of the applicant's document

controls. The staff noted that procedures required that the EGC ESP project management

establish the necessary project documentation to control project activities consistent with

regulatory requirements. The staff found that the procedures provide adequate guidance for

document control and that the applicant had adequately implemented the procedural

requirements.

17.6.3.2 CH2M HILL

The applicant selected CH2M HILL as its primary contractor for preparing the ESP application.

In its proposal, CH2M HILL specified that it would apply the existing CH2M HILL QA program,

which implements its OMS, for the ESP task to the extent applicable and would also review and

approve all reports and records required by the application before sending them to EGC.

The CH2M HILL proposal specified that the company would develop and approve special

procedures for controlling processes used in data collection and report generation in

accordance with the CH2M HILL controlled document program. The ESP project team would

use these special procedures, together with existing procedures from CH2M HILL. Documents

pertaining to the quality systems and those used to direct work relating to contractual

requirements would be controlled. CH2M HILL applied the document control program to

internally generated documents, such as manuals, procedures, plans, work instructions, forms,

drawings, and records, as well as to documents of external origin, to ensure control of

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document creation and management. CH2M HILL designed this document management

system to ensure that only those procedures reviewed and approved by project management

were available at the point of use. Inspection Report 0520007/2004001 details the staff's

review of the adequacy of the primary contractor's procedures. The staff found the primary

contractor's document controls to be adequate.

17.6.4 Conclusion (Document Control)

As set fDrth above, the staff reviewed the QA measures employed by the applicant and its

primary contractor and concluded that they have implemented acceptable document controls,

which meet the guidance of Section 17.1.1 of RS-002, Attachment 2, and help provide

reasonable assurance that any information derived from ESP activities that could be used in the

design and/or construction of SSCs important to safety will support satisfactory performance of

such SSCs once they are in service.

17.7 Control of Purchased Material, Eguipment, and Services

17.7.1 1echnical Information in the Application (Control of Purchased Material,

Equipment, and Services)

The EGO, application did not initially supply information about control of purchased material,

equipment, and services, but the applicant subsequently provided this information in response

to an RAI. The applicant's instruction identifies certain criteria of Appendix B to 10 CFR Part 50

that contain elements associated with the control of ESP activities. The instruction states thst

the applicant will apply elements from these criteria or verify that the controls applied to ESP

activities reflect these elements. The applicant considered control of purchased material,

equipment, and services to be a criterion having elements associated with the control of ESP

activities.

The instruction states that the PQP will include controls for products, equipment, and services

purchased for the ESP project commensurate with the intended use of the products or services.

The instruction also states that any material, equipment, or services purchased directly by the

applicant in connection with the development of an ESP application will be in accordance with

EGC procedures.

In its PQO, the primary contractor described the organizational, programmatic, and procedural

requirements intended to result in a complete and accurate application. Where appropriate, the

contractor will use the pertinent elements of Appendix B to 10 CFR Part 50. The PQP states

that the primary contractor will establish measures to assure that purchased material,

equipment, and services (whether purchased directly or through contractors and

subcontractors) conform to the procurement documents. These measures will include

appropriate provisions for source evaluation and selection, objective evidence of quality

furnished by the contractor or subcontractor, inspection at the contractor or subcontractor

source, and examination of products upon delivery. 0CH2M HILL will assess the effectiveness of

the contractor and subcontractor quality control at intervals consistent with the importance,

complexity, and quantity of the product or services provided.

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17.7.2 Regulatory Evaluation (Control of Purchased Material, Equipment, and Services)

While the NRC does not'require the control of purchased material, equipment, and services to

comply with the criteria of Appendix B to 10 CFR Part 50, Section 17.1.1 of RS-002,

Attachment 2, contains guidance for the staff to use in evaluating an ESP applicant's control of

purchased material, equipment, and services. In the instruction, the applicant described the

control of purchased material, equipment, and services it applied to ESP activities.

Paragraph 17.1.1.7 in Section 17.1.1 of RS-002, Attachment 2, provides the QA measures that

constitute an acceptable level of control of purchased material, equipment, and services.

Acceptable controls of purchased material, equipment, and services should include

(1) provisions for the control of purchased material, equipment, and services related to ESP

activities that could affect SSCs important to safety that apply to selecting suppliers, as well as

to assessing the adequacy of quality, and (2) provisions to ensure onsite availability of

documented evidence of the conformance to procurement specifications of material and

equipment related to ESP activities that could affect SSCs important to safety before their

installation or use.

17.7.3 Technical Evaluation (Control of Purchased Material, Equipment, and Services)

Section 17.4 of this SER details the controls of purchased material, equipment, and services

applied by the applicant to its primary subcontractor. This section of the SER focuses on the

additional subcontractors that were engaged in ESP activities. The following discussion

addresses the scope of activities and the QA measures applied to those activities.

17.7.3.1 Parsons Energy & Chemicals Group

The overall scope of work conducted by Parsons includes review and assessment of existing

site data; review and assessment of plant parameter envelope (PPE) data; preparation of site

plot plan and facility description sections of the SSAR; preparation of the SSAR text for -

mechanical, structural, and electrical sections; and documentation for the effluents and designbasis accident sections of the SSAR.

Inspection Report 0520007/2004001 details the staff's review of Parsons' preparation of the

SSAR in support of the ESP application. The Parsons QA manual states that Parsons will meet

the requirements of Appendix B to 10 CFR Part 50; American National Standards

Institute (ANSI) N45.2, "Quality Assurance Program Requirements for Nuclear Facilities,"

issued in 1977; and American Society of Mechanical Engineers (ASME) NQA-1-2000, "Quality

Assurance Requirements for Nuclear Facility Applications," issued in 2000. Parsons conducted

its work under this document and supplementary procedures.

The staff reviewed the adequacy of the guidance for the accumulation, control, and

maintenance of QA records relating to the project. The staff also reviewed the organizational

responsibilities and lines of communication among the different engineering disciplines

established in each of the reviewed procedures. This included designation of personnel who

originated the initial design or input and the associated reviewers. A Parsons procedure

delineates guidelines for the review of specifications to produce design criteria and

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documentation used for the design of the project. The staff evaluated procedures for the

review of calculations, including spreadsheet/database utilities and computer analyses.

The staff noted that the QA manual provides administrative directives to project personnel and

includes the quality plan implemented for the project. The manual identifies organizational

structure and interfaces, outlines project personnel responsibilities, and defines design control,

interface control, and client-specific requirements. The manual recognizes the need for

controls and procedures for the work performed under this task based on the use of the data

generated. The manual states that it should be used for those portions of the work, such as

calculations, where the requirements of Appendix B to 10 CFR Part 50 apply. The manual also

details the specific areas that are applicable.

The staff found the QA manual and procedures to be adequate to cover the areas of ESP

activities that were the responsibility of Parsons.

17.7.3.2 Testing Services Corporation

Testing Services Corporation (TSC) provided engineering, technical, and laboratory services

associated with geotechnical activities. Geotechnical activities include site borings, sample

collection, testing, and inspection of soil and rock as used in engineering design and

construction. The staff reviewed the QA manual prepared by TSC for ESP activities. The TALC

manual includes a description of the TSC organization, the resumes of personnel who

conducted geotechnical activities, data reports and records, calibration records and procedures,

and procedures related to sample testing and onsite inspections. TSC performed site borings

and sample collections in accordance with the TSC manual. CH2M HILL reviewed and

approved the manual and found it to be prepared in accordance with the criteria required in tine

PQP and in American Society for Testing and Materials (ASTM) D3740, "Standard Practice for

Minimum Requirement for Agencies Engaged in the Testing and/or Inspection of Soil and Rock

as Used in Engineering Design and Construction," issued in 2001. Inspection

Report 0520007/2004001 details the staff's review of additional procedures related to the work

conducted by TSC.

TSC designated a licensed professional engineer as responsible for ensuring internal quality

reviews of work activities. The TSC QA manual includes a copy of the internal quality review

check sheet.

Other subcontractors, including Stratigraphics and GEOVision Geographical Services

(GEOVision), were involved in similar work. These subcontractors were also required to follow

the same ASTM standards and CH2M HILL procedures.

The staffs review of the procedures and the TSC QA manual found that the documents provide

a thorough description of the work processes and adequate QA measures.

17.7.3.3 Geomatrix

Geomatrix performed seismic and geologic data collection, site response studies, and the

determination of the safe-shutdown earthquake (SSE) for the ESP application. The staff

reviewed documentation related to calculations and analyses, software validation, verification

and control, and the Geomatrix purchase order. The staff also reviewed company personnel

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resumes and QA training records. Geomatrix personnel were trained and performed work

under CH2M HILL PQP procedures regarding software verification controls and documentation

and review of calculations and-analyses.

Geomatrix used software developed or modified by the company to perform calculations related

to the seismic analysis in the ESP application. The staff reviewed Geomatrix documentation,

which provides additional information regarding the V&V performed on the modified software.

The documentation explains procedures for software V&V performed by Geomatrix. The

documentation also includes a summary description of the V&V presentation provided by

Geomatrix personnel to the NRC staff. During the presentation, Geomatrix personnel

described the V&V procedures for two of the software codes used to perform the seismic

hazard analysis and explained the software modifications necessary to perform the ESP

calculations.

As further described in Inspection Report 0520007/2004001, Geomatrix performed verification

activities for its software before the start of the ESP project. In order to perform the ESP

calculations, the Geomatrix computer codes needed modifications to accept ground motion

models and seismic source parameters developed by the Electric Power Research Institute

(EPRI). The EPRI probabilistic seismic hazard analysis for the Seismic Owners Group is

acceptable for characterizing the seismic hazard for nuclear power plants, as stated in

Regulatory Guide (RG) 1.165, "Identification and Characterization of Seismic Sources and

Determination of Safe-Shutdown Earthquake Ground Motion," issued in 1997. Appendix B,

Section 3.2.1, to the ESP SSAR documents the results, which the staff reviewed.

The staff concluded that Geomatrix complied with the CH2M HILL PQP and that the design

control measures used by Geomatrix for seismic studies incorporated into the ESP application

are adequate.

CH2M HILL developed a procedure to outline the quality measures for Geomatrix to use in

conducting ESP activities. The procedure details the specific work to be conducted, such as

seismic hazard and geotechnical studies. The procedure states that Geomatrix will conduct the

work in accordance with the PQP. Additionally, the scope of work covered by the procedure

was intended to be consistent with the guidance provided in RGs 1.70, Revision 3, "Standard

Format and Content of Safety Analysis Reports for Nuclear Power Plants-LWR Edition,"

issued in 1978, and 1.165. The staff determined that the procedure provides adequate

guidance for the scope of work conducted.

17.7.3.4 GRL Engineers, Inc.

The staff reviewed the GRL QA manual. GRL conducted standard penetration test (SPT)

measurement work. The staff reviewed documentation that provides the extent of QA

measures applied to ESP activities. GRL performed its measurements in accordance with

ASTM D4945, "Standard Test Method for High-Strain Dynamic Testing of Piles," issued in

2000, concerning dynamic measurements. Measurement gauges and signal processing

equipment complied with the standard for dynamic measurements. In addition, GRL prepared

and reviewed engineering calculations in accordance with the GRL QA plan. The staff reviewed

the GRL QA plan and found the plan to be adequate for the GRL ESP activities.

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GRL pErformed SPTs in accordance with the GRL QA plan and Section 6.1 of ASTM D4945i for

dynamic measurements. A CH2M HILL field supervisor monitored the work performed and

verified that it was performed in accordance with the seismic field work plan. CH2M HILL

reviewed the GRL quality manual following completion of the GRL work and found that the

manual meets the requirements of the PQP. The staff found the primary contractor's controls

adequate for the scope of work GRL conducted.

17.7.3.5 Stratigraphics

Stratigraphics performed cone penetrometer measurements and testing used for the

geotechnical aspects of the ESP application. CH2M HILL monitored the work, which was

performed in accordance with the CH2M HILL PQP and ESP project quality field work plans.

The staff found the primary contractor's controls adequate for the scope of work conducted by

Stratigraphics.

17.7.3.6 University of Texas

The University of Texas (UT) performed soil sample resonant column and torsional shear

(RCTS) testing. The staff reviewed the UT testing report, which details procedures for

preparing, reviewing, and calibrating system equipment, and for system performance checks.

The procedures were designed to meet ASTM D3740. The UT engineering personnel were

trained and were supervised during performance of the tests.

The UT QA program policies contained in the report are in accordance with those previously

approved by the U.S. Department of Energy for the Yucca Mountain project soil and rock test:s,

also performed by UT. Documentation presented by UT describes technical and test

procedures for the RCTS testing performed in its soil dynamics laboratory. The staff also

reviewed an overview of the test program, theoretical background of RCTS tests, discussion of

the dynamic test results and reports, and validation procedures. The staff found no

deficiencies.

17.7.3.7 10 CFR Part 21Applicability

NRC Inspection Report 520007/2004001 identified Open Item 520007/2004001-02, concerning

the applicability of 10 CFR Part 21, "Reporting of Defects and Noncompliance," to ESP

applicants. This issue was generated during an NRC workshop held on August 27, 2003.

During that workshop, EGC representatives stated the company's position is that 10 CFR

Part 21 dDes not apply to ESP applicants. The NRC staff attending the workshop disagreed

with this position but indicated that it would further evaluate this issue and communicate a final

NRC position on the matter at a later date. The draft safety evaluation report (DSER) identifies

this as Open Item 17.1-1.

A June 22, 2004, letter to the Nuclear Energy Institute (NEI) (ADAMS Accession

No. ML040430041) and summaries of two public meetings with NEI on generic ESP issues

(September 9, 2004, ADAMS Accession No. ML042610277; November 10, 2004, ADAMS

Accession No. ML043290195) document the NRC position regarding the applicability of

10 CFR Part 21 to ESP applicants and holders.

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The NRC position is that safety-related design and analysis or consulting services must be

procured and controlled, or dedicated, in a manner sufficient to allow the ESP holder and its

contractors, as applicable, to comply with the reporting requirements of 10 CFR 50.55(e) and

10 CFR Part 21. If this were not done, the ESP holder would not be in compliance with

10 CFR 50.55(e) upon issuance of the ESP nor would its suppliers of such services be in

compliance with 10 CFR Part 21 at that time.

The staff conducted a followup inspection of Open Item 17.1-1 on May 19, 2005, at the

applicant's offices in Kennett Square, Pennsylvania. The staff determined through a review of

supporting documentation that the applicant had adequately implemented the requirements of

10 CFR Part 21 for safety-related design and analysis or consulting services supplied by the

primary contractor and subcontractors, that supported information in the SSAR that would affect

the design, construction, or operation of SSCs important to safety. Specifically, the applicant

revised its QA instructions to incorporate 10 CFR Part 21 requirements. The contracts were

revised to invoke 10 CFR Part 21 requirements for outstanding work being conducted by

subcontractors. Additionally, for closed contracts, the applicant sent letters to the respective

subcontractors requesting notification from a responsible company representative that EGC had

been informed of any outstanding defect or noncompliance with the services supplied (there

were none). Based on this inspection, the staff concludes that Open Item 17.1-1 is resolved.

17.7.4 Conclusion (Control of Purchased Material, Equipment, and Services)

As set forth above, the staff reviewed the QA measures employed by the applicant and its

contractors and concluded that they have implemented acceptable controls for purchased

material, equipment, and services which meet the guidance of Section 17.1.1 of RS-002,

Attachment 2, and help provide reasonable assurance that any information derived from ESP

activities that is used in the design and/or construction of SSCs important to safety will support

satisfactory performance of such SSCs once they are in service.

17.8 Identification and Control of Materials, Parts, and Components

17.8.1 Technical Information in the Application (Identification and Control of Materials,

Parts, and Components)

The EGC application did not initially supply information about the identification and control of

materials, parts, and components, but the applicant subsequently provided this information in

response to an RAI. The applicant's instruction identifies certain criteria of Appendix B to

10 CFR Part 50 that contain elements associated with the control of ESP activities. The

instruction stated that the applicant will apply elements from these criteria or verify that the

controls applied to the ESP activities reflect these elements. The applicant did not consider

identification and control of materials, parts, and components to be a criterion having elements

associated with the control of ESP activities.

The instruction states that identification and control of materials, parts, and components do not

apply to ESP activities because these activities do not involve fabrication, erection, installation,

and use of materials, parts, or components.

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The POP of the primary contractor describes the organizational, programmatic, and procedural

requirements intended to result in a complete and accurate application and states that the

contractor will use, where appropriate, the pertinent elements of Appendix B to 10 CFR Part 50.

The POP states that this quality criterion does not apply to ESP activities.

In RAI 17.1.1-3, the staff asked the applicant to explain why the identification and control of

materials, parts, and components do not apply to the development of the ESP application.

Alternatively, if this QA measure were to apply, the staff asked the applicant to describe the QA

measures it and its primary contractor used for the ESP application. In its response, the

applicant stated that the development of the ESP application does not involve the fabrication,

erection, installation, and use of materials, parts, or components. Thus, no QA measures are

necessa ry to prevent the use of incorrect or defective fabricated, erected, or installed materials,

parts, or components.

17.8.2 FRegulatory Evaluation (Identification and Control of Materials, Parts, and

Components)

While the NRC does not require the identification and control of materials, parts, and

components to comply with the criteria of Appendix B to 10 CFR Part 50, Section 17.1.1 of

RS-002, Attachment 2, contains guidance for the staff to use in evaluating an ESP applicant's

identification and control of materials, parts, and components. The applicant's instruction states

that the identification and control of materials, parts, or components do not apply to ESP

activities.

Paragraph 17.1.1.8 in Section 17.1.1 of RS-002, Attachment 2, provides the QA measures that

constitute an acceptable level of identification and control of materials, parts, and components.

Acceptable identification and control of materials, parts, and components should include

(1) provisions to identify and control materials, parts, and components related to ESP activities

that could affect SSCs important to safety, and (2) provisions to ensure that incorrect or

defective items are not used in ESP activities that could affect SSCs important to safety.

17.8.3 Tochnical Evaluation (Identification and Control of Materials, Parts, and

Components)

Neither the applicant nor its primary contractor invoked QA measures for the identification and

control of materials, parts, and components. The staff concluded, based on its review of the

applicant's response to RAI 17.1.1-3 and its observations during the inspection, that the

applicant and CH2M HILL did not conduct activities important to safety requiring identification

and control of materials, parts, and components.

17.8.4 Conclusion (Identification and Control of Materials, Parts, and Components)

As set forth above, the staff reviewed the need for QA measures by the applicant and its

primary contractor and concluded that, based on the scope of work for the ESP project, the

identification and control of materials, parts, and components are not required.

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17.9 Control of Special Processes

17.9.1 Technical Information in the Application (Control of Special Processes)

The EGC application did not initially supply information about the control of special processes,

but the applicant subsequently provided this information in response to an RAI. The applicant's

instruction identifies certain criteria of Appendix B to 10 CFR Part 50 that contain elements

associated with the control of ESP activities. The instruction states that the applicant will apply

elements from these criteria or verify that the controls applied to ESP activities reflect these

elements. The applicant did not consider control of special processes to be a criterion having

elements associated with the control of ESP activities.

The instruction states that control of special processes does not apply to ESP activities. In

accordance with the instruction, because no special processes such as welding, heat treating,

and nondestructive testing are involved in ESP activities, no measures are necessary for the

control of special processes.

The PQP of the primary contractor describes the organizational, programmatic, and procedural

requirements intended to result in a complete and accurate application and states that the

contractor will use, where appropriate, the pertinent elements of Appendix B to 10 CFR Part 50.

The PQP states that this quality criterion does not apply to ESP activities.

In RAI 17.1.1-3, the staff asked the applicant to explain why control of special processes does

not apply to the development of the ESP application. Alternatively, if this QA measure were to

apply, the staff asked the applicant to describe the QA measures it and its primary contractor

used for the ESP application. In its response, the applicant stated that the development of the

ESP application does not involve special processes, such as welding, heat treating, and

nondestructive testing. Thus, no QA measures are necessary for the control of special

processes.

17.9.2 Regulatory Evaluation (Control of Special Processes)

While the NRC does not require the control of special processes to comply with the criteria of

Appendix B to 10 CFR Part 50, Section 17.1.1 of RS-002, Attachment 2, contains guidance for

the staff to use in evaluating an ESP applicant's control of special processes. In Section 4.2.9

of the instruction, the applicant stated that the use of special processes does not apply to ESP

activities. I

Paragraph 17.1.1.9 in Section 17.1.1 of RS-002, Attachment 2, provides the QA measures that

constitute an acceptable level of control of special processes. Acceptable control of special

processes should include (1) provisions to ensure the acceptability of special processes used

for ESP activities that could affect SSCs important to safety, and (2) provisions to ensure that

qualified personnel using qualified procedures and equipment perform special processes

related to ESP activities that could affect SSCs important to safety.

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17.9.3 Technical Evaluation (Control of Special Processes)

Neither the applicant nor its primary contractor invoked QA measures for the control of special

processes. The staff concluded, based on its review of the applicant's response to

RAI 17.1.1-3 and its observations during the inspection, that the applicant and CH2M HILL did

not con Juct activities important to safety that required control of special processes.

17.9.4 Conclusion (Control of Special Processes)

As set forth above, the staff reviewed the need for QA measures by the applicant and its

primary contractor and concluded that, based on the scope of work for the ESP project, control

of special processes is not required.

17.10 I nspection

17.10.1 Technical Information in the Application (Inspection)

The EGC, application did not initially supply information about the control of inspection, but the

applicant subsequently provided this information in response to an RAI. The applicant's

instruction identifies certain criteria of Appendix B to 10 CFR Part 50 that contain elements

associated with the control of ESP activities. The instruction states that the applicant would

apply elements from these criteria or verify that the controls applied to ESP activities reflect

these elements. The applicant did not consider the control of inspection to be a criterion having

elements associated with the control of ESP activities.

The instruction states that the control of inspection does not apply to ESP activities; therefore,

since no safety-related material or product processing is involved in the ESP activities, no

inspection activities (by the applicant) are expected or planned.

The PQP of the primary contractor describes the organizational, programmatic, and procedural

requirements intended to result in a complete and accurate application and states that the

contractor will use, where appropriate, the elements of Appendix B to 10 CFR Part 50. The

POP states that this quality criterion does not apply to ESP activities.

In RAI 17.1.1-3, the staff asked the applicant to explain why inspection does not apply to the

development of the ESP application. Alternatively, if this QA measure were to apply, the staff

asked the applicant to describe the QA measures it and its primary contractor used for the ESP

application. In its response, the applicant stated that the development of the ESP application

does not involve safety-related material or product processing. Thus, the applicant does not

expect or plan to conduct any QA inspections.

17.10.2 Regulatory Evaluation (Inspection)

While the NRC does not require inspection controls to comply with the criteria of Appendix B to

10 CFR Fart 50, Section 17.1.1 of RS-002, Attachment 2, contains guidance for the staff to use

in evaluating an ESP applicant's controls for inspection. In Section 4.2.10 of the instruction, the

applicant stated that inspection did not apply to ESP activities.

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Paragraph 17.1.1.10 in Section 17.1.1 of RS-002, Attachment 2, provides the QA measures

that constitute an acceptable level of inspection control. Acceptable inspection controls should

include (1) provisions for the inspection of activities affecting the quality of ESP activities that

could affect SSCs important to safety, including the items and activities to be covered,

(2) organizational responsibilities and qualifications for individuals or groups performing

inspection of ESP activities that could affect SSCs important to safety, and (3) provisions for

inspection personnel to be independent of the performance of the activity being inspected.

17.10.3 Technical Evaluation (Inspection)

Neither the applicant nor its primary contractor invoked QA measures for inspection. The staff

concluded, based on its review of the applicant's response to RAI 17.1.1-3 and its observations

during the inspection, that the applicant and CH2M HILL did not conduct activities important to

safety that required control of inspection.

17.10.4 Conclusion (Inspection)

As set forth above, the staff reviewed the need for QA measures by the applicant and its

primary contractor and concluded that, based on the scope of work for the ESP project,

inspection by the applicant is not required.

17.11 Test Control

17.11.1 Technical Information in the Application (Test Control)

The EGC application did not initially supply information on test control, but the applicant

subsequently provided this information in response to an RAI. The applicant's instruction

identifies certain criteria of Appendix B to 10 CFR Part 50 that contain elements associated with

the control of ESP activities. The instruction states that the applicant will apply elements from

these criteria or verify that the controls applied to ESP activities reflect these elements. The

applicant considered test control to be a criterion having elements associated with the control of

ESP activities.

The instruction states that the POP will include controls for testing accomplished in connection

with the development of an ESP application.

The PQP of the primary contractor describes the organizational, programmatic, and procedural

requirements intended to result in a complete and accurate application and states that the

contractor will use, where appropriate, the pertinent elements of Appendix B to 10 CFR Part 50.

The POP states that testing will be conducted in accordance with controlled procedures

established after consideration of the applicable industry standards. Test procedures will

include provisions for verifying that the prerequisites for a given test have been met, that

adequate test instrumentation is available and used, and that the test is performed under

suitable environmental conditions. Test results will be documented and evaluated to verify that

the test requirements have been satisfied.

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17.11.2 Regulatory Evaluation (Test Control)

While the NRC does not require test controls to comply with the criteria of Appendix B to

10 CFR Part 50, Section 17.1.1 of RS-002, Attachment 2, contains guidance for the staff to use

in evaluating an ESP applicant's test controls. The applicant's instruction details the test

controls it applied to the ESP activities.

Paragraph 17.1.1.11 in Section 17.1.1 of RS-002, Attachment 2, provides the QA measures

that constitute an acceptable level of test control. Acceptable test controls should include

(1 ) provisions to ensure that tests performed related to ESP activities that could affect SSCs

important to safety are appropriately controlled to provide confidence that these SSCs will

perform adequately once they are in service, and (2) provisions to ensure that prerequisites are

provided in written test procedures and that test results are documented and evaluated for ESP

activities; that could affect SSCs important to safety.

17.11.3 Technical Evaluation (Test Control)

17.11.3.1 Exelon Generation Company

ESP quality project personnel observed activities performed at the proposed ESP site. The

field activities included the following:

* TSC advanced three deep soil borings using mud rotary drilling methods and conducted

sDil sampling. TSC also advanced rock coring up to 30 feet (ft) into the bedrock in the

deep boring.

* TSC installed three ground water piezometers.

* Stratigraphics advanced four cone penetrometer test (CPT) soundings. Two of these

included seismic wave CPTs for the measurement of the shear wave velocity soil profile,

in addition to the normal CPT side and end resistance measurements. The other two

were piezocone CPT soundings, involving end, side, and pore pressure measurements.

* GEOVision conducted one suspension logging test to log the shear wave velocity of the

subsurface profile.

* Chastain surveyed each of the boring and sounding locations for horizontal coordinates.

Elevations of each location were measured by differential leveling.

The "ESP Project Activity Matrix," which EGC provided to the staff, identified the contractors

performing ESP-related activities. Contractors on site during the field activities included

(1) TSC, responsible for site borings, sample collection, and piezometer tests, (2) GRL,

responsible for SPT measurements, (3) GEOVision, responsible for suspension logging tests to

determine shear and compressional wave velocities, and (4) Homer Chastain and Associates,

responsible for collection, review, and preparation of the data for inclusion in the ESP

application.

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The staff considered test control to be adequate based on its field observations and review of

ESP quality project personnel logs.

17.11.3.2 CH2M HILL

The staff reviewed the CH2M HILL purchase orders for each of the contractors. With the

exception of TSC and GRL, the contractors worked in accordance with the CH2M HILL POP.

TSC and GRL conducted activities in accordance with their own internal quality plans. The staff

reviewed all quality plans.

In conjunction with the governing quality plans, a task-specific geotechnical field work plan,

prepared by CH2M HILL, controlled site activities. The CH2M HILL auditor and the CH2M

senior geotechnical engineer assigned to the ESP project reviewed and approved the work

plan. The senior engineer's qualifications, as shown on his resume, include 30 years of

geotechnical design and consulting experience and a Ph.D. in civil engineering.

During the period of field activities, the CH2M HILL auditor was on site full time and observed

activities in progress on a daily basis. The staff reviewed his field log for each of the days on

which the subsurface investigations were conducted. The log documented work by TSC from

the time the drill rig arrived at the site through the time of its departure when the auditor

secured the site.

In addition to the surveillance activities that occurred during the performance of subsurface

investigations, CH2M HILL conducted an audit while boring was in progress. The CH2M HILL

project QA manager conducted the audit, with the CH2M HILL senior geotechnical engineer

providing technical assistance. The scope of the audit included contractor compliance with the

geotechnical field workplan, in addition to applicable quality requirements.

The field notes documented a site visit by Geomatrix during field activities and a visit

subsequent to field activities by a UT representative. This individual was responsible for the

resonant column/cyclic testing performed; the ESP application documents the results of this

testing. The staff documented its observations from this visit in a September 9, 2002,

memorandum from R.N. Gardner, NRC, to J.E. Lyons, NRC (ADAMS Accession

No. ML022530396).

17.11.4 Conclusion (Test Control)

As set forth above, the staff reviewed the QA measures employed by the applicant and its

primary contractor. The staff concluded that these measures implement acceptable test

controls which meet the guidance of Section 17.1.1 of RS-002, Attachment 2, and help provide

reasonable assurance that any information derived from ESP activities that is used in the

design and/or construction of SSCs important to safety will support satisfactory performance of

such SSCs once they are in service.

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17.12 Control of Measuring and Test Eguipment

17.12.1 Technical Information in the Application (Control of M&TE)

The EGC application did not initially supply information about the control of measuring and test

equipment (M&TE), but the applicant subsequently provided this information in response to an

RAI. The applicant's instruction identifies certain criteria of Appendix B to 10 CFR Part 50 that

contain elements associated with the control of ESP activities. The instruction states that the

applicant would apply elements from these criteria or verify that the controls applied to ESP

activities; reflect these elements. The applicant considered control of M&TE to be a criterion

having elements associated with the control of ESP activities.

The instruction states that the PQP will include controls for the accuracy of M&TE used in

connection with the development of an ESP application, as well as guidance that addresses

actions to be taken when said equipment is unacceptable for use.

The PQP of the primary contractor describes the organizational, programmatic, and procedural

requirements intended to result in a complete and accurate application and states that the

contractor will use, where appropriate, the pertinent elements of Appendix B to 10 CFR Part 50.

The PQP states that measures will be established to assure that tools, gauges, instruments,

and other measuring devices used in activities affecting quality are properly controlled,

calibrated, and adjusted at specified periods to maintain accuracy within necessary limits.

17.12.2 Regulatory Evaluation (Control of M&TE)

While the NRC does not require the control of M&TE to comply with the criteria of Appendix B

to 10 CFR Part 50, Section 17.1.1 of RS-002, Attachment 2, contains guidance for the staff to

use in evaluating an ESP applicant's control of M&TE. In its instruction, the applicant detailed

the control of M&TE it applied to ESP activities.

Paragraph 17.1.1.12 in Section 17.1.1 of RS-002, Attachment 2, describes the QA measures

that constitute an acceptable level of control of M&TE. Acceptable control of M&TE should

include provisions to ensure that tools, gauges, instruments, and other measuring and testing

devices are properly identified and controlled and are calibrated and adjusted at specified

intervals.

17.12.3 Technical Evaluation (Control of M&TE)

The instruction states that the applicant is responsible for the establishment and execution of a

project QA plan for the ESP project, but that EGC typically delegates to others, such as

contractors, the work of establishing and executing the QA plan. For control of M&TE, most cf

the subcontractors implemented their own controls. The following sections detail these

controls.

17.12.3.1 GRL Engineers, Inc.

GRL conducted SPT measurement work. The staff reviewed the controls that GRL applied to

M&TE. GRL performed its measurements in accordance with ASTM D4945 for dynamic

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measurements. Measurement gauges and signal processing equipment were in compliance

with the standard for dynamic measurements. The staff found that GRL complied with the

ASTM standard.

17.12.3.2 Testing Services Corporation

CH2M HILL subcontracted to TSC to obtain geological testing support, such as site borings,

sample collection, and piezometer installation. The staff reviewed the adequacy of the TSC

work plan and QA manual for control of M&TE. The manual indicates that reviews of test

results were conducted. Furthermore, the staff noted that the QA manual states that TSC

performs calibration and verification of required equipment at specified intervals. Additionally,

TSC keeps a calibration and verification file for each piece of equipment. The staff found the

TSC control of M&TE to be adequate for the scope of work conducted.

17.12.3.3 University of Texas

The UT team performed soil sample RCTS. The staff reviewed the testing report, which

detailed procedures for the control of M&TE. The procedures were designed to meet ASTM

D3740. The staff considered the procedures adequate for the control of M&TE for the scope of

work conducted by UT.

17.12.4 Conclusion (Control of M&TE)

As set forth above, the staff reviewed the QA measures employed by the applicant and its

contractors. The staff concluded that control of M&TE that meets the guidance of

Section 17.1.1 of RS-002, Attachment 2, and helps provide reasonable assurance that any

information derived from ESP activities that is used in the design and/or construction of SSCs

important to safety will support satisfactory performance of such SSCs once they are in service.

17.13 Handling, Storage, and Shipping

17.13.1 Technical Information in the Application (Handling, Storage, and Shipping)

The EGC application did not initially supply information about handling, storage, and shipping,

but the applicant subsequently provided information in response to an RAI. The applicant's

instruction identifies certain criteria of Appendix B to 10 CFR Part 50 that contain elements

associated with the control of ESP activities. The instruction states that the applicant would

apply elements from these criteria or verify that the controls applied to ESP activities reflect

these elements. The applicant considered handling, storage, and shipping to be a criterion

having elements associated with the control of ESP activities.

The instruction states that the PQP will include controls for the handling, storage, and shipping

of ESP project material and equipment.

The PQP of the primary contractor describes the organizational, programmatic, and procedural

requirements intended to result in a complete and accurate application and states that the

contractor will use, where appropriate, the pertinent elements of Appendix B to 10 CFR Part 50.

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The POP states that measures will be established to control the handling, storage, shipping,

cleaning, and preservation of material and equipment, in accordance with work and inspection

instructions as necessary, to prevent damage or deterioration. When necessary for particular

products, the POP will specify and provide, if appropriate, special protective environments such

as inert gas atmosphere, specific moisture content levels, and temperature levels.

17.13.2 Regulatory Evaluation (Handling, Storage, and Shipping)

While the NRC does not require controls for handling, storage, and shipping to comply with the

criteria of Appendix B to 10 CFR Part 50, Section 17.1.1 of RS-002, Attachment 2, contains

guidance for the staff to use in evaluating an ESP applicant's controls for handling, storage, and

shipping. The applicant's instruction details the handling, storage, and shipping controls it

applied 1o ESP activities.

Paragraph 17.1.1.13 in Section 17.1.1 of RS-002, Attachment 2, provides the QA measures

that constitute an acceptable level of handling, storage, and shipping control. Acceptable

controls for handling, storage, and shipping should include provisions to control handling,

storage, shipping, cleaning, and preservation of items related to ESP activities that could affect

SSCs important to safety, in accordance with work and inspection instructions, to prevent

damage, loss, and deterioration by environmental conditions, such as temperature or humidity.

17.13.3 Technical Evaluation (Handling, Storage, and Shipping)

17.13.3.1 CH2M HILL

With the exception of TSC and GRL, the contractors conducted their work in accordance with

the CH2MA HILL POP. TSC and GRL conducted handling, storage, and shipping activities in

accordance with their own internal quality plans. In conjunction with the governing quality

plans, a task-specific geotechnical field work plan, prepared by CH2M HILL, controlled site

activities. The staff reviewed all quality plans and the work plan and found them to be adequate

for handling, storage, and shipping controls. The staff also reviewed field notes and logs and

noted no deficiencies related to handling, storage, and shipping controls.

17.13.4 Conclusion (Handling, Storage, and Shipping)

As set forth above, the staff reviewed the QA measures the primary contractor and its

subcontractors used. The staff concluded that there were acceptable controls for handling,

storage, and shipping which meet the guidance of Section 17.1.1 of RS-002, Attachment 2, and

help provide reasonable assurance that any information derived from ESP activities that is used

in the design and/or construction of SSCs important to safety will support satisfactory

performance of such SSCs once they are in service.

17.14 Inspection. Test, and Operating Status

17.14.1 Technical Information in the Application (Inspection, Test, and Operating Status)

The EGC application did not initially supply information about the control of inspection, test, and

operating status, but the applicant subsequently provided information in response to an RAI.

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The applicant's instruction identifies certain criteria of Appendix B to 10 CFR Part 50 that

contain elements associated with the control of ESP activities. The instruction states that the

applicant would apply elements from these criteria or verify that the controls applied to ESP

activities reflect these elements. The applicant did not consider the control of inspection, test,

and operating status to be a criterion having elements associated with the control of ESP

activities.

The instruction states that control of inspection, test, and operating status does not apply to

ESP activities. Because ESP activities do not involve inspection, testing, or operation of SSCs

of a nuclear power plant, the instruction does not require measures relating to the inspection,

testing, or operation of such SSCs.

The PQP of the primary contractor describes the organizational, programmatic, and procedural

requirements intended to result in a complete and accurate application and states that the

contractor will use, where appropriate, the pertinent elements of Appendix B to 10 CFR Part 50.

The POP states that this quality criterion does not apply to ESP activities.

In RAI 17.1.1-3, the staff asked the applicant to explain why the control of inspection, test, and

operating status does not apply to the development of the ESP application. Alternatively, if this

QA measure were to apply, the staff asked the applicant to describe the QA measures it and its

primary contractor used for the ESP application. In its response, the applicant stated that the

development of the ESP application does not involve inspection, testing, or operation of SSCs

of a nuclear power plant. Therefore, QA measures relating to the inspection, testing, or

operation of such SSCs are not necessary.

17.14.2 Regulatory Evaluation (Inspection, Test, and Operating Status)

While the NRC does not require controls for inspection, test, and operating status to comply

with the criteria of Appendix B to 10 CFR Part 50, Section 17.1.1 of RS-002, Attachment 2,

contains guidance for the staff to use in evaluating an ESP applicant's controls for inspection,

test, and operating status. In Section 4.2.14 of the instruction, the applicant stated that controls

for inspection, test, and operating status do not apply to ESP activities.

Paragraph 17.1.1.14 in Section 17.1.1 of RS-002, Attachment 2, provides the QA measures

that constitute an acceptable level of controls for inspection, test, and operating status.

Acceptable controls for inspection, test, and operating status should include provisions to

indicate the inspection, test, and operating status of items related to ESP activities that could

affect SSCs important to safety. These provisions will prevent inadvertent use or bypassing of

inspection and tests.

17.14.3 Technical Evaluation (Inspection, Test, and Operating Status)

Neither the applicant nor its primary contractor invoked QA measures for inspection, test, and

operating status. The staff concluded, based on its review of the applicant's response to

RAI 17.1.1-3 and its observations during the inspection, that the applicant and CH2M HILL did

not conduct activities important to safety requiring inspection, test, and operating status.

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17.14.4. Conclusion (Inspection, Test, and Operating Status)

As set forth above, the staff reviewed the need for QA measures by the applicant and its

primary contractor and concluded that, based on the scope of work for the ESP project,

inspection, test, and operating status measures are not required.

17.15 Nonconforming Materials, Parts, or Components

17.15.1 Technical Information in the Application (Nonconforming Materials, Parts, or

Components)

The EGC application did not initially supply information about control of nonconforming

materia's, parts, or components, but the applicant subsequently provided this information in

response to an RAI. The applicant's instruction identifies certain criteria of Appendix B to

10 CFR Part 50 that contain elements associated with the control of ESP activities. The

instruction states that the applicant would apply elements from these criteria or verify that the

controls applied to ESP activities reflect these elements. The applicant did not consider the

control of nonconforming materials, parts, or components to be a criterion having elements

associated with control of ESP activities.

The instruction states that control of nonconforming materials, parts, or components does nct

apply to ESP activities. Since ESP activities do not involve the fabrication, erection, installation,

and use of materials, parts, or components, no measures are necessary to prevent the use or

installation of nonconforming materials, parts, or components.

The PQP of the primary contractor describes the organizational, programmatic, and procedui'al

requirements intended to result in a complete and accurate application and states that the

contractor will use, where appropriate, the pertinent elements of Appendix B to 10 CFR Part 50.

The PQFP states that this criterion does not apply to ESP activities.

In RAI 17.1.1-3, the staff asked the applicant to explain why control of nonconforming materials,

parts, and components does not apply to the development of the ESP application.

Alternatively, if this QA measure were to apply, the staff asked the applicant to describe the C)A

measures it and its primary contractor used for the ESP application. In its response, the

applicant stated that the development of the ESP application does not involve fabrication,

erection, installation, and use of materials, parts, or components. Thus, no QA measures are

necessary to prevent the use or installation of nonconforming materials, parts, or components.

17.15.2 Regulatory Evaluation (Nonconforming Materials, Parts, or Components)

While the NRC does not require control of nonconforming materials, parts, or components to

comply with the criteria of Appendix B to 10 CFR Part 50, Section 17.1.1 of RS-002,

Attachment 2, contains guidance for the staff to use in evaluating an ESP applicant's control of

nonconforming materials, parts, or components. The applicant's instruction states that the

control of nonconforming materials, parts, or components does not apply to ESP activities.

Paragraph 17.1.1.15 in Section 17.1.1 of RS-002, Attachment 2, provides the QA measures

that constitute an acceptable level of control of nonconforming materials, parts, or components;.

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Acceptable controls for nonconforming materials, parts, or components should include

provisions to control the use or disposition of nonconforming materials, parts, or components

related to ESP activities that could affect SSCs important to safety.

17.15.3 Technical Evaluation (Nonconforming Materials, Parts, or Components)

Neither the applicant nor its primary contractor invoked QA measures for the control of

nonconforming materials, parts, or components. The staff concluded, based on its review of

the applicant's response to RAI 17.1.1-3 and its observations during the inspection, that the

applicant and CH2M HILL did not conduct activities important to safety that required control of

nonconforming materials, parts, or components.

17.15.4 Conclusion (Nonconforming Materials, Parts, or Components)

As set forth above, the staff reviewed the need for QA measures by the applicant and its

contractors and concluded that, based on the scope of work for the ESP project, control of

nonconforming materials, parts, or components is not required.

17.16 Corrective Action

17.16.1 Technical Information in the Application (Corrective Action)

The EGC application did not initially supply information about corrective action, but the applicant

subsequently provided this information in response to an RAI. The applicant's instruction

identifies certain criteria of Appendix B to 10 CFR Part 50 that contain elements associated with

the control of ESP activities. The instruction states that the applicant would apply elements

from these criteria or verify that the controls applied to ESP activities reflect these elements.

The applicant considered corrective action to be a criterion having elements associated with

control of ESP activities.

The instruction states that the PQP will include controls for the identification and correction of

ESP project conditions adverse to quality. In addition, any conditions adverse to quality

pertaining to the actions or functions of the EGC-specific segment of the ESP project will be

addressed either in accordance with the corrective action program identified in the PQP, or in

accordance with the applicant's corrective action program. I

The POP of the primary contractor describes the organizational, programmatic, and procedural

requirements intended to result in a complete and accurate application and states that the

contractor will use, where appropriate, the pertinent elements of Appendix B to 10 CFR Part 50.

The POP states that measures will be established to promptly identify and correct conditions

adverse to quality, such as failures, malfunctions, deficiencies, deviations, defective material

and equipment, and nonconformances. In the case of significant conditions adverse to quality,

the measures will determine the cause of the conditions and result in corrective action being

taken to correct the condition and to preclude repetition. The identification of the significant

condition adverse to quality, the cause of the condition, and the corrective action taken will be

documented and reported to the appropriate level of management. The QA manager is

responsible for the corrective action program and its implementing procedures, as well as for

processing corrective actions. Project personnel may address quality issues directly to the QA

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manager or project manager when it is apparent that normal processes are not timely or

capable of resolving the issue.

17.16.2 Regulatory Evaluation (Corrective Action)

While the NRC does not require a corrective action program to comply with Appendix B to

10 CFR Part 50, Section 17.1.1 of RS-002, Attachment 2, contains guidance for the staff to use

in evaluating an ESP applicant's corrective action program. The applicant's instruction states

that corrective action does apply to ESP activities.

Paragraph 17.1.1.16 in Section 17.1.1 of RS-002, Attachment 2, provides the QA measures

that constitute an acceptable level of control of corrective action. An acceptable corrective

action program should include provisions to ensure that conditions adverse to quality are

promptly identified and corrected. For significant conditions adverse to quality, those provisions

should preclude recurrence.

17.16.3 Technical Evaluation (Corrective Action)

17.16.3.1 Exelon Generation Company

The instruction provides controls for the identification and correction of ESP project conditions

adverse to quality. The instruction specifies that any conditions adverse to quality pertaining to

the actions or functions specific to EGC would be addressed either in accordance with the

corrective action program identified in the PQP or in accordance with the applicant's own

corrective action program.

The PQP provides for the identification and correction of conditions adverse to quality. The

PQP states that when a significant condition adverse to quality occurs, the cause of the

condition and the corrective action taken will be documented and reported to the appropriate

level of management. The CH2M HILL QA manager is responsible for the corrective action

program and its implementing procedures and for processing corrective actions. The staff

determined through interviews with the QA manager and review of relevant documentation that

he possesses adequate training and qualification, including knowledge of the corrective action

process and the resolution of condition reports.

17.16.3.2 CH2M HILL

The staff reviewed the CH2M HILL project procedure for the corrective action program, as

detailed in Inspection Report 0520007/2004001. The procedure provides instructions for

establishing and operating a corrective action program and establishes processes and methods

to be used to resolve issues. The procedure requires documentation of the determination of

the root cause of significant issues, the development and implementation of effective corrective

action plans, and the performance of followup activities to determine whether the corrective

action is effective in resolving the issue. The staff determined the guidance in the procedure to

be adequate for the conduct of a corrective action program.

The staff reviewed all of the corrective action reports (CARs) that were generated during the

applicant's ESP activities, including subsequent actions to resolve identified issues. Inspection

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Report 0520007/2004001 provides further information. The staff also discussed some of its

observations with the CH2M HILL QA manager. For the majority of the CARs, the staff found

the proposed corrective action and subsequent resolution-to be adequate in addressing the

identified problem. The staff did note that the auditor performing the audit had generated all of

the CARs. The personnel conducting the ESP activities did not generate any CARs. The staff

also noted an instance in which CH2M HILL did not initially document the root cause of an

adverse condition. The applicant identified this deficiency to CH2M HILL. CH2M HILL

subsequently corrected it. Finally, an EGC audit identified many adverse findings related to

procedural deficiencies revealed during the early stages of ESP activities. The applicant

assured the staff that it had corrected the findings. The staff determined that the findings

identified above do not have a significant impact on ESP activities and had been adequately

resolved.

17.16.4 Conclusion (Corrective Action)

As set forth above, the staff reviewed the QA measures employed by the applicant and its

primary contractor and concluded that they have implemented an acceptable corrective action

program which meets the guidance of Section 17.1.1 of RS-002, Attachment 2, and helps

provide reasonable assurance that any information derived from ESP activities that could be

used in the design and/or construction of SSCs important to safety will support satisfactory

performance of such SSCs once they are in service.

17.17 Quality Assurance Records

17.17.1 Technical Information in the Application (Quality Assurance Records)

The EGC application did not initially supply information about the control of QA records, but the

applicant subsequently provided information in response to an RAI. The applicant's instruction

identifies certain criteria of Appendix B to 10 CFR Part 50 that contain elements associated with

the control of ESP activities. The instruction states that the applicant would apply elements

from these criteria or verify that the controls applied to ESP activities reflect these elements.

The applicant considered QA records to be a criterion having elements associated with the

control of ESP activities.

The instruction states that the PQP will include controls for the identification, retention, and

maintenance of ESP project records. In addition, the applicant will retain records of audits and

reviews in project files until the completion of the project. If the ESP application were to be

used to obtain a COL, the project records would become records associated with the

requirements of 10 CFR Part 52, Subpart C, for a licensed facility. The applicant will, at ESP

project completion, take possession of and retain from the lead contractor all applicable ESP

project documentation in accordance with its records retention and storage processes.

The POP of the primary contractor describes the organizational, programmatic, and procedural

requirements intended to result in a complete and accurate application and states that the

contractor will use, where appropriate, the pertinent elements of Appendix B to 10 CFR Part 50.

The PQP states that records required for the quality program will be controlled. Controls will be

implemented to ensure that the records are legible, readily identifiable, and retrievable.

Consistent with applicable regulatory requirements, specific requirements concerning record

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retention, such as duration, location, and assigned responsibility, will be determined. Records

may be in any format consistent with these storage requirements, including hard copy,

electron ic, or other media. Sufficient records will be maintained to furnish evidence of activities

affecting quality. The records will include, at a minimum, operating logs and the results of

reviews, inspections, tests, audits, monitoring of work performance, and materials analyses.

The records will also include closely related data, such as qualifications of personnel,

procedures, and equipment. Inspection and test records will also identify the inspector or data

recorde, the type of observation, the results, the acceptability, and the action taken in

connection with any deficiencies noted.

17.17.2 Regulatory Evaluation (Quality Assurance Records)

While the NRC does not require control of QA records to comply with the criteria of Appendix B

to 10 CF:R Part 50, Section 17.1.1 of RS-002, Attachment 2, contains guidance for the staff to

use in evaluating an ESP applicant's QA records. In its instruction, the applicant stated that

control of QA records applies to ESP activities.

Paragraph 17.1.1.17 in Section 17.1.1 of RS-002, Attachment 2, provides the QA measures

that constitute an acceptable level of QA records control. Acceptable control of QA records

should include provisions for the identification, retention, retrieval, and maintenance of quality

records.

17.17.3 Technical Evaluation (Quality Assurance Records)

17.17.3.-l Exelon Generation Company

The instruction states that the PQP will include controls for the identification, retention, and

maintenance of ESP project records. The staff reviewed the applicant's procedures associated

with records retention. Inspection Report 0520007/2004001 details this review. An EGC

procedure provides general guidance on retention of records. Records are classified as

'lifetime" or "nonpermanent" according to criteria in the procedure. The procedure requires

review of nonpermanent records to determine an appropriate retention period; a documented

review has not yet occurred for ESP records. The applicant stated that it intends to retain ESPrelated QA records until it decides whether to use the ESP in support of a COL application. If

EGC decides to reference the ESP in a COL application, the COL project will acquire the ESP

records.

The staff reviewed the applicant's requirements imposed on contractors for turning over ESP

quality records. The instruction requires that the applicant, at ESP project completion, take

possession from the lead contractor of all applicable ESP project documentation, in accordance

with EGC record retention and storage processes. The applicant stated that CH2M HILL does

not have an explicit written internal requirement regarding turnover of records to EGC.

However, the applicant, through a service agreement, required CH2M HILL to provide it with all

information and documentation that are within the contractor's scope of services and that are

required for the design, construction, licensing, QA, operation, or maintenance of the services

or of the facility for which the services are intended.

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17.17.3.2 CH2M HILL

The PQP states that-records required for the quality program will be controlled and that

sufficient records will be maintained to furnish evidence of activities affecting quality. The PQP

also lists the types of records requiring control as quality records.

The staff reviewed several of the primary contractor's QA records procedures, which are

discussed in Inspection Report 0520007/2004001. A CH2M HILL project procedure establishes

instructions for identifying, storing, retrieving, protecting, retaining, and disposing of project QA

records. This procedure outlines responsibility for QA records for project managers, the

document control manager, and recordkeepers. It also lists categories of QA records and

requirements for storage and protection, retrieval, and disposition. For example, the procedure

requires that recordkeepers consider security, fire, and environment (heat and humidity) before

storing records.

The staff also reviewed the CH2M HILL record retention requirements. The record retention

procedure states that the retention time of all quality records will be defined. It referred to the

CH2M HILL online records management retention schedule, which contains specific retention

requirements for project files (records documenting substantive project documentation,

including calculations, reference material, preliminary drawings and reports, project contracts,

and documentation of any client requirements). The company maintains these records for the

active length of a project plus 6 years. It retains work products and deliverables for periods of 6

to 15 years after the active period of a project, depending on the type of record. The staff also

reviewed the CH2M HILL quality record log for ESP deliverables. This log showed specific

CH2M HILL retention periods for ESP records that appeared to be consistent with those

specified in the online records management retention schedule. CH2M HILL personnel

interviewed stated that service agreements (contracts) with clients govern retention

requirements for records developed by CH2M HILL that are associated with the clients'

projects. Several line entries in the online retention schedule related to project records

contain language consistent with these statements. As detailed in Inspection

Report 0520007/2004001, the staff also reviewed procedures for document control and

creation, as well as for peer and technical review.

Interviews with cognizant EGC and CH2M HILL staff indicated that responsibility for quality

records had not been turned over to the applicant. At the time of the inspection, the records

resided on a secure computer server in the CH2M HILL offices in Idaho Falls, Idaho. The

CH2M HILL document control manager (DCM) stated that she controlled access to and storage

of the records. She stated that the server containing the documents was housed in a secure

room, which was locked at night, and that the room contained a fire suppression system. She

stated that security, fire, and environmental considerations are factors in the storage of the

records. She also stated that the electronic records were backed up nightly. Inspection

Report 0520007/2004001 discusses these issues.

Finally, the staff reviewed the reports of the final review of the seismic sections of the SSAR,

and supporting documents, as well as the CH2M HILL peer review, and found that the results of

the reviews were documented. Inspection Report 0520007/2004001 provides further detail.

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17.17.4 Conclusion (Quality Assurance Records)

As set iorth above, the staff reviewed the QA measures the applicant and its primary contractor

used arid concluded that they have implemented an acceptable level of control for QA records

which meets the guidance of Section 17.1.1 of RS-002, Attachment 2, and helps provide

reasonable assurance that any information derived from ESP activities that is used in the

design and/or construction of SSCs important to safety will support satisfactory performance of

such SSCs once they are in service.

17.18 Audits

17.18.1 Technical Information in the Application (Audits)

The EGC application did not initially supply information about the control of audits, but the

applicant subsequently provided this information in response to an RAI. The applicant's

instruction identifies certain criteria of Appendix B to 10 CFR Part 50 that contain elements

associated with the control of ESP activities. The instruction states that the applicant would

apply elements from these criteria or verify that the controls applied to ESP activities reflect

these elements. The applicant considered control of audits to be a criterion having elements

associated with the control of ESP activities.

The instruction states that the PQP will include controls for the verification of compliance with its

requirements. In addition, the applicant may, from time to time, perform audits of the primary

contractor's implementation of the PQP.

The POP of the primary contractor describes the organizational, programmatic, and procedural

requirements intended to result in a complete and accurate application and states that the

contractor will use, where appropriate, the pertinent elements of Appendix B to 10 CFR Part 50.

The PQFO states that planned audits will be carried out to verify compliance with the QA

program and to determine the effectiveness of the program. Trained personnel who do not

have direct responsibility for the area being audited will perform the audits in accordance with

written procedures. The task lead with responsibility for the area being audited will review the

audit res'ults. Followup action, including reaudit of deficient areas, will be taken when indicated.

The QA manager will coordinate the conduct of internal audits of project processes and

procedures. Findings of nonconformance will be recorded in the corrective action/preventive

action spreadsheet or other similar tracking mechanism.

17.18.2 Regulatory Evaluation (Audits)

While the NRC does not require the control of audits to comply with the criteria of Appendix B to

10 CFR F'art 50, Section 17.1.1 of RS-002, Attachment 2, contains guidance for the staff to use

in evaluating an ESP applicant's control of audits. In its instruction, the applicant stated that

audits did apply to ESP activities.

Paragraph 17.1.1.18 in Section 17.1.1 of RS-002, Attachment 2, provides the QA measures

that constitute an acceptable level of control of audits. Acceptable audits should include

(1) provisions for audits to verify compliance with all aspects of QA controls and to determine

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the effectiveness of these controls, and (2) responsibilities and procedures for conducting,

documenting, and reviewing the results of audits (including designating management levels to

review and assess audit results).

17.18.3 Technical Evaluation (Audits)

The staff reviewed all audits and the requisite audit reports that covered the applicant's ESP

activities. Inspection Report 0520007/2004001 provides the details of the audit reports. The

staff also addressed the adequacy of the audit process related to ESP activities.

17.18.3.1 Exelon Generation Company

The ESP project team consisted of representatives from EGC, CH2M HILL, Parsons, and

Geomatrix. All of these organizations were audited during preparation of the ESP application.

Tasks performed by organizations not represented on the ESP project team were performed in

conjunction with field investigations at the ESP site. During this period, CH2M HILL and EGC

quality personnel provided full-surveillance coverage of subcontractor activities. Based on the

audit and surveillance coverage identified above, the staff concluded that oversight of contract

activities for the preparation of the ESP application was adequate.

The instruction states that the applicant may perform audits of the lead subcontractor's

implementation of the PQP. The PQP included guidance for subcontractors to conduct audits.

The audit conducted by EGC personnel applied guidance from existing Nuclear Oversight

Department (NOS) procedures. The staff reviewed the qualifications of the EGC personnel

who conducted the audit and found that all audit personnel appeared to have adequate

qualifications.

As discussed in Inspection Report 0520007/2004001, procedures were in place for the conduct

of audits of internal CH2M HILL activities, including those of project subcontractors. The

applicant's corrective action process documented audit deficiencies. Some contractors,

including subcontractors whose portions of the ESP project were of short duration, were not

audited since they were operating under their own previously accepted 10 CFR Part 50,

Appendix B, quality processes (e.g., Parsons).

The staff reviewed the results of the audits and assessments the applicant conducted.

Inspection Report 0520007/2004001 discusses the review of the audits and assessments and

the resultant findings. The audit used the process developed by the Nuclear Utilities

Procurement Issues Committee. The staff found the audit process adequate.

The staff discussed the process used to conduct the assessment with the applicant's lead

corporate assessor for NOS. A unique template was developed to conduct the assessment

based on existing NOS procedures. The staff concluded that the applicant had adequately

implemented an assessment process of the project quality controls which provided reasonable

assurance of ESP application quality.

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17.18.3.1.1 Board of Review

An independent board of review assisted the project staff during the seismic work. This board

evaluated the implementation plan for the seismic hazard work, the interim results of the work,

and the conclusions reached during the work.

The staff reviewed the board of review's product. The review involved checking Sections 2.5

and 3.4 of the SSAR and providing feedback. The staff reviewed the qualifications of the

members of the board of review and found their qualifications to be adequate.

17.18.3.1.2 Independent Review of the SSAR

In addition to the routine audits and performance assessments detailed in Inspection

Report 0520007/2004001, EGC had Sargent & Lundy (S&L) and Idaho National Engineering

and Environmental Laboratory (INEEL) perform an independent review of draft SSAR sections.

The scope of the review included all documents and information, including reference material,

that formed the entire ESP application. S&L conducted an overall review, while the INEEL

review focused on the geotechnical report and supporting information. The staff found these

reviews to be adequate in scope.

17.18.3.2 CH2M HILL

The EGC: application contract identified the CH2M HILL internal audit program as the primary

process for evaluating the level of implementation and effectiveness of processes used in data

collection and report generation. CH2M HILL integrated the audit program with its

documentation program, training program, corrective action program, and management

program for controlling procurement activities. The audit process evaluated project activities by

reviewing procedures against contract requirements for compliance and documenting and

addressing nonconforming steps or outputs through the corrective action program.

The PQP provides that planned audits will be conducted to verify compliance with the QA

program to determine the effectiveness of the program. An audit program procedure outlined

the administration and implementation of the audit program. Procedure guidance covered

personnel responsibility, internal auditor training requirements, development of an audit

schedule, audit documentation, and processing audit findings.

The staff reviewed the qualifications of the CH2M HILL personnel who conducted audits,

concluding that all audit personnel appeared to have adequate qualifications.

Based on its review of the audits and assessments conducted by CH2M HILL, the staff

concluded that CH2M HILL adequately implemented its audit program.

17.18.3.2.1 Peer Review

Before fonvarding the ESP application to EGC, CH2M HILL conducted an internal, independent

technical assessment of the data and reported findings. The assessment evaluated the

collection process, performed verifying calculations, and reviewed the methodologies applied in

developing the information to be submitted in support of the ESP application.

17-39
17.18.4 Conclusion (Audits)

As set forth above, the staff reviewed the QA measures the applicant and its primary contractor

used and concluded that they have implemented acceptable audit controls which meet the

guidance of Section 17.1.1 of RS-002, Attachment 2, and help provide reasonable assurance

that any information derived from ESP activities that is used in the design and/or construction of

SSCs important to safety will support satisfactory performance of such SSCs once they are in

service.

17.19 Conclusions

Based on its review and evaluation of the QA measures contained in the applicant's ESP

program as set forth above, the staff concludes that the applicant's QA measures conform to

the guidance in RS-002, Attachment 2, as well as appropriate industry standards, and that the

applicant and its contractors implemented them for the ESP application activities.

17-40
18. REVIEW BY THE ADVISORY COMMITTEE ON REACTOR

SAFEGUARDS

The Advisory Committee on Reactor Safeguards (ACRS) completed its review of the

application from Exelon Generation Company, LLC (EGC or the applicant) for an early site

permit (ESP) for the Exelon Generation Company (EGC) ESP site and the U.S. Nuclear

Regulatory Commission (NRC) staff's draft safety evaluation report (DSER) and supplemental

DSER for this application. The ACRS ESP subcommittee began its detailed review of the EGC

ESP application and the staff's DSER in February 2005.

The ACAS ESP subcommittee met with representatives from EGC and the staff on

September 7, 2005. The ACRS held its full committee meeting on the EGC ESP DSER on

September 8, 2005. The discussions during these meetings focused on the open items from

the DSER and the supplemental DSER . On the basis of its review, the ACRS issued an

interim letter report, dated September 22, 2005, which addresses the portions of the EGC EUSP

application that concern safety. The staff responded to the interim letter report in its letter

dated October 26, 2005 (ADAMS Accession No. ML052790028). This final safety evaluation

report (FSER) documents the resolution of open items discussed in the DSER and the

supplemental DSER. The FSER also captures the actions that the staff has taken in response

to the ccmments and recommendations identified by the ACRS in its interim report of

September 22, 2005, as described in the staff's response letter of October 26, 2005.

During its meetings with the ACRS on March 8 and March 9, 2006, the staff discussed the

resolutiol of open items and the responses to ACRS comments on the major elements of the

ESP review. At the 530' meeting of the ACRS, the full committee considered the staff's FSER,

as well as EGC's ESP application, and issued its final letter report to the NRC Chairman on

March 24, 2006. That letter report is included as Appendix E to this report.

In its final letter report dated March 24, 2006, the ACRS concurred with the NRC staff's

conclusions concerning EGC's ESP application and concluded that the proposed site, subject

to the permit conditions recommended by the staff, can be used for nuclear power plants or

modules having a total power generation rate of 2400 to 6800 MW thermal without undue risk

to public health and safety.

18-1

19. CONCLUSIONS

In accordance with Subpart A, "Early Site Permits," of Title 10 of the Code of Federal

Regulallons (10 CFR), Part 52, uEarly Site Permits, Standard Design Certifications, and

Combined Licenses for Nuclear Power Plants," the staff of the U.S. Nuclear Regulatory

Commission reviewed the site safety analysis report and emergency planning information

included in the early site permit (ESP) application submitted by Exelon Generation Company,

LLC (EGC or the applicant), for the Exelon Generation Company (EGC) ESP site. On the basis

of its evaluation and independent analyses as discussed in this safety evaluation report (SER),

the staff concludes that the EGC ESP site characteristics comply with the requirements of

10 CFR Part 100, "Reactor Site Criteria," with the limitations and conditions proposed by the

staff in this SER for inclusion in any ESP that might be issued. Further, for the reasons set

forth in this SER, the staff concludes that, taking into consideration the site criteria contained in

10 CFR Part 100, a reactor(s), having characteristics that fall within the parameters for the site,

and which meets the terms and conditions proposed by the staff in this SER, can be

constructed and operated without undue risk to the health and safety of the public. For the

same reasons, the staff also concludes that issuance of the requested ESP will not be inimical

to the common defense and security or to the health and safety of the public. If issued, the

EGC ESP may be referenced in an application to construct or to construct and operate a

nuclear power reactor, or reactors, with a total generating capacity of up to 6800 megawatts

(thermal) at the ESP site, subject to the terms and conditions of the permit.

19-1

Appendix A

Permit Conditions, COL Action Items, Site Characteristics, and

Bounding Parameters

A.1 Permit Conditions Table ..............................

Definition .................................................

Section 2.1 - Introduction ....................................

Section 2.4 - Hydrology ......................................

Section 2.5 - Geology, Seismology, and Geotechnical Engineering ....

..............

..............

..............

..............

..............

.

A.2 CCIL Action Items Table .........................................

Definition ................................................................

Section 2.1 - Introduction ...................................................

Section .2.2 - Nearby Industrial, Transportation, and Military Facilities .................

Section :2.3 - Meteorology ...................................................

Section :2.4 - Hydrology .....................................................

Section :2.5 - Geology, Seismology, and Geotechnical Engineering ...................

Section 11.1 - Radiological Effluent Release Dose Consequences from Normal Operations

Section 13.6 - Industrial Security ..............................................

A-2

A-2

.A-2

A-3

.A-3

A-4

A-4

A-4

A-4

A-5

A-5

A-8

A-9

A-9

A.3 Site Characteristics Table ...........................

Definition ................................................

Section 2.1 - Introduction ...................................

Section' 2.3 - Meteorology ...................................

Section 2.4 - Hydrology .....................................

Section 2.5 - Geology, Seismology, and Geotechnical Engineering ...

.............

..............

..............

..............

..............

..............

A-.1 0

A*.10

.A**10

AA 11

A-*20

.A*-21

A.4 Bounding Parameters Table ....................................... A-22

Definition............................................................... A-22

Section 2.4 - Hydrology ............................................ A-:22

Figure 1 The proposed facility boundary for the ESP site ......... ................. A-23

Figure 2 EGC ESP horizontal and vertical ESP SSE as well as the RG 1.60 DRS anchored at

0.3g ........................................... A-24

A-1
A.1 Permit Conditions

Permit Condition: The Commission's regulation in 10 CFR 52.24 authorizes the inclusion of limitations and conditions in an ESP. A

permit condition is not needed when an existing NRC regulation requires a future regulatory review of a matter to ensure adequate

safety during design, construction, or inspection activities for a new plant. The staff is proposing that the Commission include six

permit conditions, which are set forth below, to control various safety matters.

Permit

Condition SER

No. Section Description

2.1 - Introduction

1 2.1.2 The NRC staff proposes to include a condition in any ESP that might be issued in connection with this

application to govern exclusion area control. This permit condition would require an agreement

granting EGC an exclusive and irrevocable option to purchase, enter a long-term lease, and/or other

legal right in the land required to satisfy the requirements of 10 CFR Part 100 for the ESP facility, be

obtained and executed before submission of an application for a COL seeking authority to construct

and operate a nuclear power plant referencing the ESP.

2 2.1.2 The NRC staff proposes to include a condition in any ESP that might be issued in connection with this

application requiring that the ESP holder obtain the right to implement the site redress plan before

initiating any activities authorized by 10 CFR 52.25.

A-2
Permit

Condition SER l

No. Section noarrintinn

2.4 - Hydrology

3 2.4.12.3 The applicant's description of the effluent-holding facility presumed (see Sections 2.4.13.1 and 2.4.13.3

of this SER) that there will be no scenario where liquid radioactive effluent could be released above the

ambient groundwater table, including the scenario where the effluent-holding facility could be flooded

raising the release point above the ambient groundwater table. The staff agreed that under these

assumptions, release of liquid radioactive effluent to ambient groundwater can be precluded.

Therefore, the staff determined that it is necessary to ensure that the hydraulic gradient will always

point inwards into the radwaste holding and storage facility from ambient groundwater during

construction and operation of the ESP facility, including the time during which recovery of groundwater

occurs to near its pre-dewatering elevation.

4 2.4.13.3 The NRC staff proposes to include a condition in any ESP that might be issued in connection with this

application requiring a radwaste facility design for a future reactor with features to preclude any and all

accidental releases of radio-nuclides into any potential liquid pathway is necessary.

5 2.4.13.3 The staff determined that the preclusion of radioactive effluent discharge into ambient groundwater

system at the ESP site is primarily and crucially dependent on the hydraulic gradient pointing from

ambient subsurface into the effluent holding facility. The staff also determined that it is essential to

institute a groundwater monitoring program at the ESP site to continuously monitor and verify that the

central assumption for preclusion of radioactive release to groundwater is not violated. The staff stated

this requirement as Permit Condition 3 in Section 2.4.12.3 of this SER. The staff will also require that

this monitoring system be kept in place and the monitoring program be kept in operation for the life of

the ESP facility, including its decommissioning.

2.5 - Geology, Seismology, and Geotechnical Engineering

6 2.5.4.3.8 The NRC staff proposes to include a condition in any ESP that might be issued in connection with this

application requiring that the ESP holder either remove or replace or improve the soils above 60 ft

below the ground surface to reduce any liquefaction potential.

A-3
A.2 COL Action Items

COL Action Items: The combined license (COL) action items set forth in the SER and incorporated herein identify certain matters

that shall be addressed in the final safety analysis report (FSAR) by an applicant who submits an application referencing the Clinton

ESP. These items constitute information requirements but do not form the only acceptable set of information in the FSAR. An

applicant may depart from or omit these items, provided that the departure or omission is identified and justified in the FSAR. In

addition, these items do not relieve an applicant from any requirement in 10 CFR Parts 50 and 52 that govern the application. After

issuance of a construction permit (CP) or COL, these items are not controlled by NRC requirements unless such items are restated

in the preliminary safety analysis report or FSAR, respectively.

The staff identified the following COL action items with respect to individual site characteristics in order to ensure that particular'

significant issues are tracked and considered during the review of a later application referencing any ESP that might be issued for

the Clinton ESP site.

Action SER

Item No. Section Subject To Be Addressed Reason for Deferral

2.1- Geography and Demogriphy

2.1-1 2.1.1 A COL or CP applicant should provide latitude, longitude, and Universal Exact unit locations not known at ESP

Transverse Mercator coordinates for new unit(s) on the ESP site. stage.

2.1-2 2.1.2 A COL or CP applicant should make arrangements with the appropriate Such arrangements not required at

local, State, Federal, or other public agencies to provide for control of the ESP stage.

portions of Clinton Lake that lies within the exclusion area.

2.2 - Nearby Industrial, Transportation, and Military Facilities

2.2-1 2.2.1.3- | A COL or CP applicant should assess design-specific interactions 1 New unit design and specific location

2.2.2.3 between the existing and new units and, if necessary, propose measures not known at ESP stage. _ to account for such interactions.

A-4
Action SER

Item No. Section Subject To Be Addressed Reason for Deferral

2.3 - Meteorology

2.3-1 2.3.2 A COL or CP applicant should, as part of detailed engineering, assess the Cooling tower location and design not

potential impact of natural and/or mechanical cooling towers on the design known at ESP stage.

and operation of the new facility.

2.3-2 2.3.4 A COL or CP applicant should assess dispersion of airborne radioactive Control room location and design not

materials to the control room. known at ESP stage.

2.3-3 2.3.5 A COL or CP application should verify specific release point Exact release points and receptor

characteristics and specific locations of potential receptors of interest locations not known at ESP stage.

used to generate the long-term (routine release) atmospheric dispersion

site characteristics.

2.4 - Hydrology

2.4-1 2.4.1.3 The COL applicant to ensure that the ESP facility intake piping is installed The feasibility of the use of the existing

with adequate clearance from the CPS facility piping. discharge tunnel from the abandoned

units is not known at the ESP stage.

2.4-2 2.4.1.3 The COL applicant should provide the detail design of the UHS system, if The design of the UHS system

a UHS is required by the selected reactor type for the ESP facility. depends on the reactor design.

Reactor design not known at ESP

stage.

2.4-3 2.4.2.3 The COL applicant should design the ESP intake structures to withstand The requirement of a UHS and the

the combined effects of PMF, coincident wind wave activity, and wind necessity of protection of its intake

setup, as discussed further in Section 2.4.3 of this SER. structure from flooding is dependent on

reactor design, which has not been

selected at the ESP stage.

2.4-4 2.4.2.3 The COL applicant should demonstrate that the ESP site drainage from Detailed design of the plants, including

local intense precipitation at the ESP site can be discharged to Clinton the site grade are beyond the scope of

Lake without relying on any active drainage systems that may be blocked an ESP review.

during this event.

A-5
Action SER

Item No. Section Subject To Be Addressed Reason for Deferral

2.4-5 2.4.7.3 The COL applicant should demonstrate that the intake structure can The requirement of an ESP facility UHS

withstand the effects of any ice sheet crushing, bending, buckling, intake structure is dependent on

splitting, or a combination of these modes. whether the selected reactor design

requires a UHS. The reactor design

has not been selected at the ESP

stage.

2.4-6 2.4.7.3 The COL applicant should design the ESP facility UHS intake to maintain The requirement of an ESP facility UHS

a minimum water temperature of 40 OF at all times to preclude formation of intake structure is dependent on

frazil and anchor ice on the intake inlet. whether the selected reactor design

requires a UHS. The reactor design

has not been selected at the ESP

stage.

2.4-7 2.4.7.3 The COL applicant should ensure that the ice sheet formed on Clinton The requirement of an ESP facility UHS

Lake would not constrain the intake. This is predicated on the ESP facility intake structure is dependent on

UHS intake being located at an elevation of 668 ft MSL. whether the selected reactor design

requires a UHS. The reactor design

has not been selected at the ESP

stage.

2.4-8 2.4.8.3 The COL or CP applicant should ensure that any water-cooled UHS that The ESP water budget analysis relies

may be required by a selected reactor type for the ESP facility is designed on independent UHS reservoirs only, to a maximum 30-day makeup water requirement not exceeding 87 ac-ft. but need for a UHS is not known at the

ESP stage.

2.4-9 2.4.8.3 The COL or CP applicant should establish that the ESP facility NHS is The requirement of an ESP facility UHS

designed such that there is no over-reliance on the UHS for frequent plant system is dependent on whether the

shutdowns. selected reactor design requires a

UHS. The reactor design has not been

selected at the ESP stage. I

A-6
Action SER

Item No. Section Subject To Be Addressed Reason for Deferral

2.4-'0 The COL or CP applicant should ensure the monitoring and any required The reliance of the ESP facility UHS on

dredging of the submerged UHS pond. water available in the submerged UHS

pond is dependent on the selected

reactor type requiring a UHS. The

reactor design has not been selected at

the ESP stage.

2.4-11 2.4.11.3 The COL Applicant should develop a plant shutdown protocol when the The requirement of an ESP facility UHS

water surface elevation in Clinton Lake falls to 677 ft MSL. intake structure is dependent on

whether the selected reactor design

requires a UHS. The reactor design

has not been selected at the ESP.

stage.

2.4-12 2.4.12.3 The COL applicant should ensure that ground water would not be used for The normal and safety-related

either normal or safety-related plant operations. requirements for the ESP facility

depend on the selected reactor type.

The reactor design has not been

selected at the ESP stage.

2.4-13 2.4.12.3 The COL or CP applicant should establish conservative groundwater flow Exact location and design not known at

velocities and conservative soil properties that are representative of the ESP stage.

hydrogeologic conditions at the ESP site.

2.4-14 2.4.13.3 The COL or CP applicant should conclusively prove that there will be no The maximum elevation at which any

likely scenario that can lead to liquid radioactive release to the ambient radioactive releases can occur within

groundwater, either above the ambient groundwater table, or below it. the ESP facility will depend on the

chosen reactor design. The reactor

design has not been selected at the

ESP stage.

A-7
Action SER

Item No. Section Subject To Be Addressed Reason for Deferral

- 2.5 - Geology, Seismology, and Geotechnical Information

2.5.4-1 2.5.4 A COL or CP applicant should submit the analyses of soil-rock-structure Exact unit locations and design not

interaction for the ESP site. known at ESP stage.

2.5.4-2 2.5.4 A COL or CP applicant should address the guidance recommended in RG Exact unit locations and design not

1.132 regarding drilling and sampling. known at ESP stage.

2.5.4-3 2.5.4 A COL or CP applicant should submit plot plans and the profiles of all Exact unit locations and design not

seismic Category I facilities for comparison with the subsurface profile and known at ESP stage.

material properties.

2.5.4-4 2.5.4 The COL or CP applicant should submit excavation and backfill plans for Exact unit locations and design not

NRC review. known at ESP stage

2.5.4-5 2.5.4 The COL applicant should inform the NRC staff (1) if it encounters Exact unit locations and design not

previously unknown geologic features that could represent a hazard to the known at ESP stage.

plant and (2) when site excavations are open for examination and

evaluation.

2.5.4-6 2.5.4 A COL or CP applicant should assess groundwater conditions as they Exact unit locations and design not

affect foundation stability or detailed dewatering plans. known at ESP stage.

2.5.4-7 2.5.4 The COL or CP applicant should perform a complete static stability Exact unit locations and design not

assessment (including bearing capacities, settlement analyses, and lateral known at ESP stage.

load assessment) and to ensure that the bearing capacities meet the

minimum value of 25 tsf.

2.5.4-8 2.5.4 The COL or CP applicant should describe the design criteria and Exact unit locations and design not

methods, including the FOSs from the design analyses. known at ESP stage.

2.5.5-1 2.5.5 A COL or CP applicant should conduct a more detailed dynamic analysis Locations of safety-related structures

of the stability of the existing slope and any new slopes using the safe- relative to the existing or new slopes

shutdown earthquake (SSE) ground motion. not known at ESP stage.

A-8
Action SER |

Item No. Section Subject To Be Addressed Reason for Deferral

2.6.6-, I * ne COL applicant should perform evaluations (if appropriate) at the COL Exact unit location and design not

stage to assess the performance of the submerged dam forming the UHS known, therefore, need for UHS cannot

under the ESP SSE ground motion. be determined at ESP stage.

11.1 - Radiological Effluents

11.1-1 11.1 A COL or CP applicant should verify that the calculated radiological doses Specific details of how the new facility

to members of the public from radioactive gaseous and liquid effluents for will control, monitor, and maintain

any facility to be built on the Exelon ESP site are bounded by the radioactive gaseous and liquid effluents

radiological doses included in the ESP application and reviewed by the not known at ESP stage.

NRC.

13.6 - Industrial Security

13.6-1 13.6 | A COL or CP applicant should provide specific designs for protected area Exact locations and design of barriers

| barriers. not known at ESP stage.

A-9
A.3 Site Characteristics

Site Characteristics: Based on site investigation, exploration, analysis and testing, the applicant initially proposes a set of site

characteristics. These site characteristics are specific physical attributes of the site, whether natural or man-made. Site

characteristics, if reviewed and approved by the staff, are specified in the ESP. The staff proposes to include the following site

characteristics in any ESP that might be issued for the Exelon ESP site.

Site Characteristic Value Definition

2.1 - Introduction

Exclusion Area Boundary The perimeter of a 3362 ft (0.64 The area surrounding the reactor, in

mile) radius circle from the center which the reactor licensee has the

of the proposed ESP facility authority to determine all activities

footprint. including exclusion or removal of

personnel and property from the area

Low Population Zone 13,182 ft (2.5 mile) radius circle The area immediately surrounding the

from the center of the proposed exclusion area which contains

ESP facility footprint. residents

Population Center Distance 22 miles The minimum allowable distance from

the reactor to the nearest boundary of

a densely populated center containing

more than about 25,000 residents

A-10
Site Characteristic Value Definition

2.3 - Meteorology

Ambient Air Temperature and Humidity

Maximum Dry-Bulb 2% annual exceedance 88 *F with 74 *F concurrent wet- The ambient dry-bulb temperature

Temperature bulb (and coincident wet-bulb temperature)

that will be exceeded 2% of the time

annually

1% annual exceedance 91 F The ambient dry-bulb temperature that

will be exceeded 1% of the time ._ annually

0.4% annual 94 OF with 77 *F concurrent wet- The ambient dry-bulb temperature

exceedance bulb (and coincident wet-bulb temperature)

that will be exceeded 0.4% of the time

annually

100-year return period 117 The ambient dry-bulb temperature that

has a 1% annual probability of being

exceeded (1 00-year mean recurrence

interval)

Minimum Dry-Bulb 99% annual 0 F The ambient dry-bulb temperature

Temperature exceedance below which dry-bulb temperatures will

fall 1% of the time annually

99.6% annual -6 F The ambient dry-bulb temperature

exceedance below which dry-bulb temperatures will

fall 0.4% of the time annually

A-11
Site Characteristic Value Definition

1 00-year return period -36 'F The ambient dry-bulb temperature for

which a 1% annual probability of a

lower dry-bulb temperature exists

._ (1 00-year mean recurrence interval)

Maximum Wet-Bulb 1% annual exceedance 78 *F The ambient wet-bulb temperature that

Temperature will be exceeded 1% of the time

annually

0.4% annual 80 *F The ambient wet-bulb temperature that

exceedance will be exceeded 0.4% of the time

annually

100-year return period 86 F The ambient wet-bulb temperature that

has a 1% annual probability of being

exceeded (1 00-year mean recurrence

interval)

Basic Wind Speed

Fastest Mile 75 mi/hr The fastest-mile wind speed to be

used in determining wind loads,

defined as the fastest-mile wind speed

at 33 feet (10 meters) above the

ground that has a 1% annual

probability of being exceeded (100-

year mean recurrence interval)

A-12
Site Characteristic Value Definition

3-second Gust 96 mi/hr The 3-second gust wind speed to be

used in determining wind loads,

defined as the 3-second gust wind

speed at 33 feet (10 meters) above the

ground that has a 1% annual

probability of being exceeded (100-

year mean recurrence interval)

Design-Basis Tornado

Maximum Wind Speed 300 mi/hr Maximum wind speed resulting from

passage of a tornado having a

probability of occurrence of 10-7 per

year

Translational Speed 60 mi/hr Translation component of the

maximum tornado wind speed

Rotational Speed 240 mi/hr Rotation component of the maximum

tornado wind speed

Radius of Maximum Rotational Speed 150 ft Distance from the center of the

tornado at which the maximum

rotational wind speed occurs

Maximum Pressure Drop 2.0 Ibf/in2 Decrease in ambient pressure from

normal atmospheric pressure resulting

from passage of the tornado

Maximum Rate of Pressure Drop 1.2 Ibf/in2/s Rate of pressure drop resulting from

the passage of the tornado

A-13
Site Characteristic Value Definition

Winter Precipitation

100-year Snowpack 24.4 lbf/ft2 Weight of the 100-year return period

snowpack (to be used in determining

normal winter precipitation loads for

roofs)

48-Hour Probable Maximum Winter Precipitation 16.6 in. of water Probable maximum precipitation during

the winter months (to be used in

conjunction with the 100-year

snowpack in determining extreme.

winter precipitation loads for roofs)

Ultimate Heat Sink Ambient Air Temperature and Humidity

Meteorological Conditions Resulting in the 81 F wet-bulb temperature with Historic worst 1 -day daily average wetMinimum Water Cooling During Any 1 Day coincident 87.6 °F dry-bulb bulb temperature and coincident drytemperature bulb temperature

Meotorological Conditions Resulting in the 79.7 *F wet-bulb temperature with Historic worst 5-day daily average wetMinimum Water Cooling During Any Consecutive 5 coincident 86.2 *F dry-bulb bulb temperature and coincident drydays temperature bulb temperature

Meteorological Conditions Resulting in the 74.7 *F wet-bulb temperature with Historic worst 30-day daily average

Maximum Evaporation and Drift Loss During Any coincident 82 *F dry-bulb wet-bulb temperature and coincident

Consecutive 30 Days temperature dry-bulb temperature

A-14
Site Characteristic I Value Definition

Short-Term (Accident Release) Atmospheric Dispersion

0-2 hr X/Q Value @ EAB 2.52 x 1O0 s/M3 The 0-2 hour atmospheric dispersion (5% value) factor to be used to estimate dose

consequences of design-basis ,_ accidents at the EAB

0-8 hr X/Q Value @ LPZ 3.00 x 105 s/M3 The 0-8 hour atmospheric dispersion

(5% value) factor to be used to estimate dose

consequences of design-basis

accidents at the LPZ

8-24 hr x/Q Value @ LPZ 2.02 x 1O" s/r 3 The 8-24 hour atmospheric dispersion

(5% value) factor to be used to estimate dose

consequences of design-basis

accidents at the LPZ

1-4 day X/Q Value @ LPZ 8.53 x 10-6 s/M3 The 1-4 day atmospheric dispersion

(5% value) factor to be used to estimate dose

consequences of design-basis

accidents at the LPZ

4-30 day XIQ Value @ LPZ 2.48 x 1 0- s/r3 The 4-30 day atmospheric dispersion

(5% value) factor to be used to estimate dose

consequences of design-basis

accidents at the LPZ

Long-Term (Routine Release) Atmospheric Dispersion

Annual Average Undepleted/No Decay XfQ Value 2.04 x 10-6 s/M3 The maximum annual average EAB

@ EAB undepleted/no decay X/Q value for use

in determining gaseous pathway doses

to the maximally exposed individual

A-15
Site Characteristic Value Definition

Annual Average Undepleted/2.26-day Decay X/Q 2.04 x 10-6 s/m3 The maximum annual average EAB

Value @ EAB undepleted/2.26-day decay X/Q value

for use in determining gaseous

pathway doses to the maximally

exposed individual

Annual Average Depleted/8.00-day Decay X/Q 1.84 x 10-6 s/M3 The maximum annual average EAB

Value @ EAB depleted/8.00-day decay X/Q value for

use in determining gaseous pathway

doses to the maximally exposed

individual

Annual Average D/Q Value @ EAB 1.46 x 1 0-8 1/m2 The maximum annual average EAB

D/Q value for use in determining

gaseous pathway doses to the

maximally exposed individual

Annual Average Undepleted/No Decay X/Q Value 1.10 x 10- s/r3 The maximum annual average milk

@ Nearest Milk Cow cow undepleted/no decay X/Q value for

use in determining gaseous pathway

doses to the maximally exposed

individual

Annual Average Undepleted/2.26-day Decay X/Q 1.10 x 1 Q6 s/r3 The maximum annual average milk

Value cow undepleted/2.26-day decay XIQ

@ Nearest Milk Cow value for use in determining gaseous

pathway doses to the maximally

exposed individual

A-16
Site Characteristic Value Definition

Annual Average Depleted/8.00-day Decay X/Q 9.63 x 10-7 s/M3 The maximum nnnla!verane mill, vaiue C Nearest Milk Cow cow depleted/8.00-day decay X1Q

value for use in determining gaseous

pathway doses to the maximally

exposed individual

Annual Average D/Q Value @ Nearest Milk Cow 6.76 x 10-9 1/r2 The maximum annual average milk

cow D/Q value for use in determining

gaseous pathway doses to the

maximally exposed individual

Annual Average Undepleted/No Decay X/Q Value 9.90 x 10-a s/r3 The maximum annual average goat @ Nearest Goat Milk milk undepleted/no decay X/Q value for

use in determining gaseous pathway

doses to the maximally exposed

individual

Annual Average Undepleted/2.26-day Decay X/Q 9.72 x 108 s/nM3 The maximum annual average goat Value C Nearest Goat Milk milk undepleted/2.26-day decay X/Q

value for use in determining gaseous

pathway doses to the maximally

exposed individual

Annual Average Depleted/8.00-day Decay X/Q 7.28 x 1 o-8 s/M3 The maximum annual average goat Value @ Nearest Goat Milk milk depleted/8.00-day decay X/Q

value for use in determining gaseous

pathway doses to the maximally

exposed individual

Annual Average D/Q Value @ Nearest Goat Milk 4.21 x 10.10 1/m2 The maximum annual average meat

animal D/Q value for use in

determining gaseous pathway doses to

the maximally exposed individual

A-17
Site Characteristic Value Definition

Annual Average Undepleted/No Decay X/Q Value 1.10 x 10-' s/m3 The maximum annual average garden

@ Nearest Garden undepleted/no decay X/Q value for use

in determining gaseous pathway doses

to the maximally exposed individual

Annual Average Undepleted/2.26-day Decay X/Q 1.10 x 10-6 s/m3 The maximum annual average garden

Value @ Nearest Garden undepleted/2.26-day decay X/Q value

for use in determining gaseous

pathway doses to the maximally

exposed individual

Annual Average Depleted/8.00-day Decay X/Q 9.63 x 10O' s/m3 The maximum annual average garden

Value @ Nearest Garden depleted/8.00-day decay X/Q value for

use in determining gaseous pathway

doses to the maximally exposed

individual

Annual Average D/Q Value @ Nearest Garden 6.76 x 10-9 1/M2 The maximum annual average garden

D/Q value for use in determining

gaseous pathway doses to the

maximally exposed individual

Annual Average Undepleted/No Decay X/Q Value 1.10 x 10-6 s/r3 The maximum annual average meat

@ Nearest Meat Animal animal undepleted/no decay X/Q value

for use in determining gaseous

pathway doses to the maximally

exposed individual

Annual Average Undepleted/2.26-day Decay X/Q 1.10 x 10-6 s/M3 The maximum annual average meat

Value @ Nearest Meat Animal animal undepleted/2.26-day decay X/Q

value for use in determining gaseous

pathway doses to the maximally

exposed individual

A-18
Site Characteristic Value Definition

Annual Average Depleted/8.00-day Decay X/Q 9.63 x 10-7 s/M3 The maximum annuil viernge meat

value @ NearesI Meat Animal depleted/8.00-day decay X/Q

value for use in determining gaseous

pathway doses to the maximally

exposed individual

Annual Average D/Q Value @ Nearest Meat 6.76 x 10-9 1/M2 The maximum annual average meat

Animal animal D/Q value for use in

determining gaseous pathway doses to

the maximally exposed individual

Annual Average Undepleted/No Decay X/Q Value 1.50 x 10-6 s/M3 The maximum annual average resident

@ Nearest Resident undepleted/no decay X1Q value for use

in determining gaseous pathway doses

to the maximally exposed individual

Annual Average Undepleted/2.26-day Decay X/Q 1.49 x 10-6 s/M3 The maximum annual average resident

Value @ Nearest Resident undepleted/2.26-day decay X/Q value

for use in determining gaseous

pathway doses to the maximally

exposed individual

Annual Average Depleted/8.00-day Decay X/Q 1.34 x 10-6 s/M3 The maximum annual average resident

Value @ Nearest Resident depleted/8.00-day decay X/Q value for

use in determining gaseous pathway

doses to the maximally exposed

individual

Annual Average D/Q Value @ Nearest Resident 6.76 x 1 0-91/m2 The maximum annual average resident

D/Q value for use in determining

gaseous pathway doses to the

maximally exposed individual

A-19
Site Characteristic Value Definition

2.4 - Hydrology

Hydrology

Proposed Facility Boundaries Appendix A, Figure 1 (FSER ESP site boundary map

Figure 2.4.14) shows the proposed

facility boundary

Site Grade 735 ft MSL Finished plant grade at the ESP site

Highest Ground Water Elevation 733.5 ft MSL The maximum elevation of ground

water at the ESP site

Probable Maximum Flood (PMF) elevation 709.8 ft MSL The maximum hydrostatic water

surface elevation at the ESP site

Coincident Wind Wave Activity 6.4 ft Increment of change in water surface

elevation due to wind waves

Storm Surge 0.3 ft Increment of change in water surface

elevation due to storm surge

Combined Effects Maximum Water Surface 716.5 ft MSL Sum of hydrostatic water surface

Elevation elevation, wind wave activity, and

storm surge. Maximum water surface

elevation at the ESP site.

Local Intense Precipitation 18.15 in during 1 hour Maximum potential rainfall at the

immediate ESP site

Lake Surface Icing 27 in Ice sheet thickness at Clinton Lake

(based on maximum cumulative

degree-days below freezing)

A-20
Site Characteristic Value ( Definition

Maximum Cumulative Degree-Days 1141.5 in Fahrenheit A measure of severity of winter

weather conditions conducive to ice

formation

Frazil and Anchor Ice The ESP site has the potential for Accumulated ice formation in a

formation of frazil and anchor ice. turbulent flow condition

2.5 - Geology, Seismology, and Geotechnical Engineering

Basic Geologic and Seismic Information

Capable Tectonic Structures | | No fault displacement potential within

_ __ the investigative area

Vibratory Ground Motion

Design Response Spectra (Safe Shutdown Appendix A, Figure 2 Site Specific response spectra

Earthquake) (FSER Figure 2.5.2-16)

Stability of Subsurface Materials and Foundations

Minimum Bearing Capacity (Static) 50,0000 lbs/ft2 (25 tsf)

Minimum Shear Wave 0 - 50 ft 820 fps

Velocity 50 - 285 ft 1090fps Propagation of shear waves through

50__-_285_ __________foundation materials

285 -310 ft 2580 fps

A-21
A.4 Bounding Parameters

Plant Parameter Envelope: A plant parameter envelope (PPE) sets forth postulated values of design parameters that provide design details to

support the NRC staff's review of an ESP application. A controlling PPE value, or bounding parameter value, is one that necessarily depends on a

site characteristic. As the PPE is intended to bound multiple reactor designs, the actual design selected in a combined license (COL) or

construction permit (CP) application referencing an ESP would be reviewed to ensure that the design fits within the bounding parameter values.

Otherwise, the COL or CP applicant would need to demonstrate that the design, given the site characteristics in the ESP, complies with the

Commission's regulations. Should an applicant reference an ESP for a design that is not certified, the applicant would need to demonstrate that

the design's characteristics fall within the bounding parameter values.

Bounding Parameters Value | Definition

2.4 - Hydrology

Makeup flow rate to mechanical draft cooling towers 555 gpm Average makeup water needed for

mechanical draft cooling towers of the

ultimate heat sink for the proposed facility

Maximum inlet temperature to CCW heat exchanger 95 F Maximum allowable temperature of water

on inlet side of the condenser

Evaporation rate 31,500 gpm (70.2 cfs) Forced evaporation for the ESP facility

under normal operation

A-22
1459100

1401300-M

M4ZOON- `

it

as4

1|

'4uoo o

149300

Figure 1 (SER Figure 2.4.14) The proposed facility boundary for the ESP site

A-23
1.4

1.2-

-cm 1.0-

E 0 .8

0.6 -

I-.

.~0.4

~0.26

0.4

0.1 1 10 100

Frequency (Hz)

Figure 2 (SER Figure 2.5.2-16) EGC ESP horizontal and vertical ESP SSE as well as the

RG 1.60 DRS anchored at 0.3g

A-24
Appendix B

Chronology of Early Site Permit Application for the EGC ESP Site

This appendix lists all correspondence between the Exelon Generation Company, LLC (EGC),

and the U.S. Nuclear Regulatory Commission regarding the EGC early site permit application

through February 16, 2006, with the exception of legal filings related to the hearing. Source:

Agencypvide Document Access and Management System (ADAMS).

Revisions to the EGC Early Stie Permit Application

Revision Date Accession Number

0 September 25, 2003 ML032721596

1 November 23, 2005 ML053420053

2 January 10, 2006 ML060460043

3 March 3, 2006 ML060950511

4 April 14, 2006 ML061100260

B-1
This appendix lists all correspondence between the Exelon Generation Company, LLC, and the U.S. Nuclear Regulatory Commission regarding the Exelon early site permit application through December 31, 2004, with the exception of legal filings related

to the hearing. Source: Agencywide Documents Access and Management Systems (ADAMS).

Document Accession Title/Description Document Author Addressee Docket Date Number Includes Est. Page Count Type Affiliation(s) AffilIation(s) Number

06/27/2002 ML042280019 2002/06/27-E-mail - Exelon ESP Site E-Mail Exelon Corp NRC 05200007

Activities.

2 Page(s)

07/08/2002 ML042280020 2002/07/08-E-mail - RE: Exeron ESP E-Mail Exelon Corp NRC 05200007,

Site Activities. PROJO718

2 Page(s)

07/12/2002 ML042280021 2002/07/12 - E-mail - Exelon ESP E-Mail Exelon Corp NRC 05200bo7,

seismic activities. PROJO718

2 Page(s)

07/25/2002 ML042280022 2002/07/25-E-mail - RE: NRC-Exelon E-Mail Exelon Corp NRC 05200007,

seismic field work telecon at 2 EDT. PROJO718

2 Page(s)

07/31/2002 ML042280023 2002/07/31-E-mail - ESP Schedule of E-Mail Exelon Corp NRC 05200007, Seismic & Geotechnical Activities. PROJO718

3 Page(s)

B-2
Document Accession Title/Description Document Author Addressee |Docket Date Number Includes Est. Page Count Type Affiliation(s) Affiliation(s) Number

05/16/2003 MnAn.300743 2003/0'11 '-E-mail - Clii (301,ol rrrriurniiy E-Maii NC . Exelon 05200007, Advisory Panel. Corp PROJ0718

2 Page(s)

05/29/2003 ML042300745 2003/05/29-E-mail - CD needed for E-Mail NRC Exelon 05200007, Web Posting. Corp PROJO718

4 Page(s)

06/10/2003 ML042280025 2003/06/10-E-mail Re :Question on E-Mail Exelon Corp NRC 05200007, Security Info. PROJO718

2 Page(s)

06/10/2003 ML042300768 2003/06/10-E-mail - Application TOC. E-Mail NRC Exelon 05200007,

Corp PROJO718

1 Page(s)

06/10/2003 ML042300771 2003/06/10-E-mail - Question on E-Mail NRC Exelon 05200007, Security Info. Corp PROJO718

1 Page(s)

06/11/2003 ML042300774 2003/06/11-E-mail - Requirements on E-Mail NRC Exelon 05200007, Number of Copies. Corp PROJO718

2 Page(s)

B-3
Document Accession Title/Description Document Author Addressee Docket

Date Number Includes Est. Page Count Type Affiliation(s) Affillation(s) Number

06/11/2003 ML042300772 2003/06/11-E-mail - RE: Application E-Mail NRC Exelon 05200007, TOC. Corp PROJO718

2 Page(s) .

06/12/2003 ML042300775 2003/06/12-E-mail - Word File. E-Mail NRC Exelon 05200007,

Corp PROJO718

2 Page(s)

06/12/2003 ML042300778 2003/06/12-E-mail - RE: Word File. E-Mail NRC Exelon 05200007,

Corp PROJO718

2 Page(s)

06/13/2003 ML042300779 2003/06/13-E-mail - RE: Word File. E-Mail NRC Exelon 05200007,

Corp PROJO718

3 Page(s)

07/02/2003 ML042300780 2003/07/02-E-mail - RE: Application E-Mail NRC Exelon 05200007, TOC. Corp PROJO718

3 Page(s)

07/07/2003 ML042300827 2003/07/07-E-mail - Information on E-Mail NRC Exelon 05200007,

Clinton Lake. Corp PROJO718

2 Page(s)

07/14/2003 ML042300782 2003/07/14 - E-mail - Call on Seismic E-Mail NRC Exelon 05200007,

Issues. Corp PROJO718

1 Page(s)

B-4
Document Accession Title/Description Document Author Addressee Docket Date Number Includes Est. Page Count Type Affillation(s) Affiliation(s) Number |

07/14/2003 ML049300784 2003/07/14-E-mal0 - : Call or, C-Mail NRC Exelon 05200007, Seismic Issues. Corp PROJ0718

2 Page(s)

08/11/2003 ML042300787 2003/08/11-E-mail - QA Meeting. E-Mail NRC Exelon 05200007,

Corp PROJO718

2 Page(s)

08/26/2003 ML042300788 2003/08/26-E-mail - QA Meeting. E-Mail NRC Exelon 05200007,

Corp .PROJO71 8 1 Page(s)

08/29/2003 ML042300791 2003/08/29-E-mail - Discussion After E-Mail NRC Exelon 05200007, Entergy QA Meeting. Corp PROJO718

1 Page(s)

08/29/2003 ML042280026 2003/08/29-E-mail - RE: Application E-Mail Exelon Corp NRC 05200007, TOC. PROJO71 8

3 Page(s)

08/29/2003 ML042300792 2003/08/29-E-mail - RE: Application E-Mail NRC Exelon 05200007, TOC. Corp PROJO718

3 Page(s)

09/02/2003 ML042300793 2003/09/02-E-mail - RE: Application E-Mail NRC Exelon 05200007, TOC. Corp PROJO718

4 Page(s)

B-5
Document Accession Title/Description Document Author Addressee Docket Date Number Includes Est. Page Count Type Affillation(s) Affillation(s) Number

09/09/2003 ML042300825 2003109/09-E-mail - Re: ESP Letter. E-Mail NRC Exelon 05200007,

Corp PROJO718

2 Page(s)

09/11/2003 ML042300795 2003/09/11 -E-mail - Re: Yesterday's E-Mail NRC Exelon 05200007, Mtg. Corp PROJ0718

2 Page(s)

09/12/2003 ML042300796 2003/09/12-E-mail - QA Inspection E-Mail NRC Exelon 05200007,

Dates. Corp PROJO718

2 Page(s)

09/25/2003 ML032721594 2003/09/25-Submittal of Exelon Letter, Exelon NRC/Docu 05000461, Generation Company (EGC) application License- Generation ment 05200007, for an early site permit (ESP) for Application Co, LLC, Control PROJO718

property co-located with existing Clinton for Exelon Desk

Power Station (CPS) facility in Illinois. Constructio Nuclear

n Permit

3 Page(s) DKT 50

09/30/2003 ML042300799 2003/09/30-E-mail - Hard Copies. E-Mail NRC Exelon 05200007,

Corp PROJO718

2 Page(s)

10/01/2003 ML042300815 2003/10/01-E-mail - Picture. E-Mail, NRC Exelon 05200007

Photograph Corp

2 Page(s)

B-6
Document Accession Title/Description Document Author Addressee Docket Date Number Includes Est. Page Count Type Affiliation(s) Affiliation(s) Number

in/Al IPlnlf1 MI nAAQ'innflfn ',nnomi ninii a .. ; 1 lei AT,-% -* . -. .----- *- . ... JJ LII I - I .IILI .~Jf I~I ~ l Xlf UUUU7, 0103ML4300°031,0-E- --- mail- CiIt LUNBMI IR uEm xelon U'UU7,5 Update. Corp PROJO718

1 Page(s)

10/01/2003 ML042300801 2003/10/01-E-mail - Service List E-Mail NRC Exelon 05200007

Generation

2 Page(s) Co, LLC

10/02/2003 ML042310348 2003/10/02-E-mail - RE: Hard Copies. E-Mail NRC Exelon 05200007,

Corp *PROJO718 3 Page(s)

10/02/2003 ML042310323 2003/10/02-E-mail - RE: Service List. E-Mail, NRC Exelon 05200007

Letter Generation

3 Page(s) Co, LLC

10/03/2003 ML042310342 2003/10/03-E-mail - RE: Hard Copies. E-Mail NRC Exelon 05200007,

Corp PROJO718 3 Page(s)

10/03/2003 ML042310333 2003/10/03-E-mail - Re: Hard Copies. E-Mail NRC Exelon 05200007,

Corp PROJO71 8 3 Page(s)

10/03/2003 ML042310360 2003/10/03-E-mail - RE: Hard Copies. E-Mail NRC Exelon 05200007

Corp 3 Page(s)

10/08/2003 ML042440536 2003/10/08-E-mail - RE: Schedule. E-Mail, NRC Exelon 05200007

Letter Generation

3 Page(s) Co, LLC

B-7
Document Accession Title/Description Document Author Addressee Docket

Date Number Includes Est. Page Count Type Affiliation(s) Affiliation(s) Number

10/16/2003 ML042300811 2003/10/16-E-mail - Answer to E-Mail NRC Exelon 05200007, Question on ESP Record Retention. Generation PROJO71 8

Co, LLC

2 Page(s)

10/27/2003 ML032930051 2003/10/27-Letter to M. Kray re: Letter NRC/NRR/D Exelon 05200007

Acceptance of Application for ESP for RIP Generation

Property Co-Located With The Existing Co, LLC

Clinton Power Station.

6 Page(s)

10/27/2003 ML032930059 2003/10/27-Exelon ESP Review Spreadshee NRC/NRR/D Exelon 05200007

Schedule. t File RIP Generation

Co, LLC

1 Page(s) ,

11/19/2003 ML033250261 2003/11/19-Notice Of Intent To Prepare Federal NRC/NRR/D Exelon 05200007

An Environmental Impact Statement Register RIP Generation

And Conduct Scoping Process For An Notice, Co, LLC

Early Site Permit (ESP) At The Clinton Letter

ESP Site (TAC NO. MC1125).

13 Page(s)

11/21/2003 ML042300813 2003/11/21-E-mail - Request for E-Mail, NRC/NRR/D Exelon 05200007

Additional Information-QA. Letter, RIP/RNRP Corp

Request for

11 Page(s) Additional

Information _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ (R A I) _ _ _ _ _ _ _ _ _ _ _ _ _ _ _

B-8
Document Accession Title/Description Document Author Addressee Docket Date Number Includes Est. Page Count Type Affiliation(s) Affillation(s) Number

/ /2003 MW^OVA 31V1;2V r1t -c-l aii - Atiorneys. t-Mail NRC Exelon 05200007

Corp 2 Page(s) Corp

11/21/2003 ML033210018 2003/11/21 -Request For Additional Letter, NRC/NRR/D Exelon 05000461, Information Letter No. 1 - Exelon ESP Request for RIP Generation 05200007 Application for the Clinton ESP Site on Additional Co, LLC QA Measures (MC1 122). Information

(RAI)

7 Page(s)

12/09/2003 ML033510146 2003/12/09-Service of Notice of Letter Exelon NRC/Docu 05200007 Availability of an Application for an Nuclear ment Early Site Permit. Control

Desk, 3 Page(s) NRC/NRR

12/10/2003 ML042280027 2003/12/10-E-mail, Administrative E-Mail Exelon NRC 05200007 items. Generation

Co, LLC

2 Page(s)

12/10/2003 ML042280028 2003/12/10-E-mail - Administrative E-Mail Exelon Corp NRC 05200007 questions.

2 Page(s)

12/11/2003 ML042440541 2003/12/11 -E-mail - Re: Administrative E-Mail, NRC Exelon 05200007 questions. Letter Generation

Co, LLC

3 Page(s)

B-9
Document Accession Title/Description Document Author Addressee Docket

Date Number Includes Est. Page Count Type Aff llation(s) Affillation(s) Number

12/22/2003 ML033640639 2003/12/22-Response to RAI Letter No. Letter Exelon NRC/Docu 05000461,

1 Regarding Quality Assurance Nuclear ment 05200007

Measures, per Early Site Permit Control

Application for the Clinton Site. Desk

1 Page(s)

01/06/2004 ML042440548 2004/01/06-E-mail - Re: Administrative E-Mail, NRC Exelon 05200007

questions. Letter Corp

2 Page(s)

01/21/2004 ML040430135 2004/01/21 -SUMMARY OF PUBLIC Meeting NRC/NRR/D Exelon 05200007

MEETING TO DISCUSS THE Agenda, RIP/RLEP Generation

ENVIRONMENTAL SCOPING Meeting Co, LLC

PROCESS FOR THE CLINTON Summary,

EARLY SITE PERMIT (ESP) Transcript

APPLICATION

143 Page(s)

01/24/2004 ML050280252 2004/01/24-Response to Request for

Additional Information Letter No. 12 re

Application for Clinton ESP Site.

Letter Exelon

Generation

Co, LLC,

Exelon

Nuclear

NRC/Docu

ment

Control

Desk

05200007

82 Page(s) ________________ .1. __________________________________________ .

B-1 0
Document Accession Title/Description Document Author Addressee Docket Date Number Includes Est. Page Count Type Affiliation(s) Affiliation(s) Number

02/13/2004 AV IO4 130 102 004RO/i 3-Staff E-mail to Exelon E-Mail NRC/NRR/D Exelon 05200007 Forwarding the Proposed Agenda for RIP/RLEP Corp Alternative Site Visits for the EGC ESP

Review.

4 Page(s)

02/18/2004 ML041830095 2004/02/18-Staff E-mail to Exelon E-Mail NRC/NRR/D Exelon 05200007

Forwarding Agenda Items for the EGC RIP/RLEP Corp ESP Site Audit.

13 Page(s)

02/20/2004 ML040540622 2004/02/20-IR 0520007-04-001, on Inspection NRC/RGN- Exelon 05200007

01/12/04 through 01/16/04, for Exelon Report, III/DRS Generation

Generation Company, Kennett Square, Letter Co, LLC

PA; (Clinton) Early Site Permit.

48 Page(s)

02/23/2004 ML042300818 2004/02/23-E-mail - Requests for Letter, NRC Exelon 05200007

Additional Information. Request for Corp

Additional

4 Page(s) Information

(RAI)

02/24/2004 I ML041820385 2004/02/24-Staff E-mail to Exelon

Forwarding an Additional Question for

the EGC ESP Site Audit re Spent Fuel

Storage.

E-Mail NRC/NRR/D

RIP/RLEP

Exelon

Corp

05200007

1 Page(s) - ___________ .1 __________

B-11
Document Accession Title/Description Document Author Addressee Docket

Date Number Includes Est. Page Count Type Affillation(s) Affillation(s) Number

02/25/2004 ML041830104 2004/02/25-Staff E-mail to Exelon E-Mail NRC/NRR/D Exelon 05200007

Forwarding Additional Agenda Items for RIP/RLEP Corp the EGC ESP Site Audit.

3 Page(s)

02/26/2004 ML041830124 2004/02/26-Staff E-mail to Exelon E-Mail NRC/NRR/D Exelon 05200007

Regarding Discussion Items on Worker RIP/RLEP Corp Dose for the EGC ESP Site Audit.

3 Page(s)

03/05/2004 ML042300803 2004/03/05-E-mail - Seismic Call- E-Mail NRC Exelon 05200007, REVISION. Corp PROJO718

1 Page(s)

03/08/2004 ML042440552 2004/03/08-E-mail - RE: Seismic Call- E-Mail, NRC Exelon 05200007

REVISION. Letter Generation

Co, LLC

2 Page(s)

03/11/2004 ML042280029 2004/03/11 -E-mail forwarding Amy E-Mail Exelon NRC/NRR 05200007

Lientz Corrected Address, (Privacy Generation

Info). Co, LLC

3 Page(s)

B-1 2
Document Accession Title/Description Document Author Addressee Docket Date Number Includes Est. Page Count Type Affileation(s) { Affillation(s) f Number

.1u3tiU5,°IO cr-Eilosuiei 2; Exeion i ecnnicai hxelon NRC/NRR/ 05200007 Generation Company, LLC Early Site Paper Generation DRIP/RLEP

Permit Application of Alternative Site Co, LLC

Comparison Process and Attachment

1: Alternative Site Comparison

Process.

22 Page(s)

03/17/2004 ML040790804 2004/03/17-Clinton Power Station Early Letter Exelon NRC/Docu 05000461, Site Permit - Response to Verbal Generation ment 05200007 Request for Documentation. Co, LLC, Control

Exelon Desk

2 Page(s) Nuclear

03/17/2004 ML042280030 2004/03/17-E-mail - Clinton ETE. E-Mail Exelon Corp NRC 05200007

2 Page(s)

03/19/2004 1 ML040900247 2004/03/19-Motion for Leave to File

I Notice of Appearance Out of Time

LegalMotion

3 Page(s)

Exelon

Generation

Co, LLC,

Harmon,

Curran,

Spielberg &

Eisenberg,

LLP

NRC/ASLB

P

05200007

j .1 _____________

B-13
Document Accession Title/Description Document Author Addressee Docket

Date Number Includes Est. Page Count Type Affillation(s) Affiliation(s) Number

03/19/2004 ML040900251 2004/03/19-Notice of Appearance by Legal- Exelon NRC/ASLB 05200007

Diane Curran on behalf of Blue Ridge Notice of Generation P

Environmental Defense League Appearance Co, LLC,

Harmon,

3 Page(s) Curran,

Spielberg &

Eisenberg,

LLP

03/19/2004 ML042300816 2004/03/19-E-mail - Draft Requests for E-Mail, NRC Exelon 05200007

Additional Information-SSAR 2.5.2. Request for Corp

Additional

3 Page(s) Information

(RAI) _

03/30/2004 ML042300805 2004/03/30-E-mail - Seismic Site Visit. E-Mail NRC Exelon 05200007

Corp

1 Page(s)

04/06/2004 ML040920584 2004/04/06-Letter to M Kray Re Letter NRC/NRR/D Exelon 05200007

Revised Date for Transmitting RIP Generation

Environmental RAls for Exelon ESP Co, LLC

Application.

6 Page(s)

04/12/2004 ML042300817 2004/04/12-E-mail - Draft Requests for E-Mail NRC/NRR Exelon 05200007

Additional Information-Emergency Plan. Corp

6 Page(s)

B-14
Document Accession Title/Description Document r Author | Addressee | Docket Date Number Includes Est. Page Count Type Affiliation(s) Affiliation(s) Number

/1 3I2004 ML041110024 204,'04i V 3-Exeion Submission of Calculation, Exelon NRC/Docu 05200007 Requested Information, PBMR Ltd Letter Generation ment

Calculation MF 00-016344-2053 dated Co, LLC Control

March 6, 2003. Desk

4 Page(s)

04/14/2004 ML0424501 11 2004/04/1 4-E-mail-Re: Chicago E-Mail, NRC Exelon 05200007 Seismic Meeting. Letter Generation

Co, LLC

2 Page(s)

04/15/2004 ML040930400 2004/04/15-RAI No. 2- Exelon ESP Letter, NRC/NRR/D Exelon 05200007 Application for the Clinton ESP Site on Request for RIP Generation

Site Safety Analysis Report Section Additional Co, LLC

2.3.3 (TAC No. MC1 122). Information

(RAI)

7 Page(s)

04/29/2004 ML042450110 2004/04/29-E-mail - Re: May 11-12 site E-Mail, NRC Exelon 05200007

visit. Letter, Trip Corp

Report

2 Page(s)

04/29/2004 ML042280032 2004/04/29-E-mail, RE: May 18-19 E-Mail Exelon NRC 05200007

seismic visit. Generation

Co, LLC

3 Page(s) .

B-15
Document Accession Tltle/Description Document Author Addressee Docket Date Number Includes Est. Page Count Type Affiliation(s) Affiliation(s) Number

04/29/2004 ML042280031 2004/04/29-E-mail - May 11-12 site E-Mail Exelon Corp NRC 05200007

visit.

3 Page(s)

04/30/2004 ML0424501 01 2004/04/30-E-mail - Re: May 11-12 site E-Mail NRC Exelon 05200007

visit. Corp

3 Page(s)

04/30/2004 ML042450102 2004/04/30-E-mail - RE: May 18-19 E-Mail NRC Exelon 05200007

seismic visit. Corp

3 Page(s)

04/30/2004 ML042450097 2004/04/30-E-mail - RE: RAI No. 2 re E-Mail NRC Exelon 05200007

Met Data. Corp

2 Page(s)

04/30/2004 ML042450104 2004/04/30-E-mail - Re: May 11-12 site E-Mail NRC Exelon 05200007

visit. Corp

3 Page(s)

05/03/2004 ML042450093 2004/05/03-E-mail - Re: May 11-12 site E-Mail NRC Exelon 05200007

visit. Corp

3 Page(s) I I

B-1 6
Document Accession Title/Description Document Author Addressee Docket Date Number Includes Est. Page Count Type Affiliation(s) Atffillation(s) Number

05./04/004 ML012O45086 2004/05/04-E-maIl - RE: Site visii info - E-Maii NRC Exelon 05200007 May 19. Corp

1 Page(s)

05/05/2004 ML042280033 2004/05/05-E-mail - RE: Emergency E-Mail Exelon Corp NRC 05200007

Plan draft RAls - Applicant questions.

3 Page(s)

05/05/2004 ML042450083 2004/05/05-E-mail - RE: Emergency E-Mail NRC Exelon 05200007 Plan draft RAls. Corp

3 Page(s)

05/05/2004 ML042450081 2004/05/05-E-mail - RE: Emergency E-Mail, NRC Exelon 05200007

Plan draft RAls - Applicant questions. Letter Corp

3 Page(s)

05/06/2004 ML042300807 2004/05/06-E-mail - Hydrology E-Mail NRC Exelon 05200007

Discussion Topics. Generation

Co, LLC

5 Page(s) .

B-17
Document Accession Title/Description Document Author Addressee Docket

Date Number Includes Est. Page Count Type Affillation(s) Affillation(s) Number

05/11/2004 ML041330188 2005/05/11 -Request for Additional Letter, NRC/NRR/D Exelon 05200007

Information (RAI) Regarding the Request for RIP/RLEP Generation

Environmental Portion of the Early Site Additional Co, LLC

Permit Application for the Exelon Information

Generation Company Site (TAC No. (RAI)

MC1 125).

17 Page(s)

05/12/2004 ML042300520 2004/05/12-E-mail - Fwd: Seismic RAI E-Mail NRC/NRR Exelon 05200007

Topics for Mtg discussion. Corp

3 Page(s) _

05/14/2004 ML042450079 2004/05/14-E-mail - RE: NRC Seismic E-Mail NRC Exelon 05200007

visit info - May 17-19. Corp

3 Page(s)

05/18/2004 ML041830135 2004/05/18-Staff E-mail to Exelon E-Mail NRC/NRR/D Exelon 05200007

Regarding Clarification Items to Site RIP/RLEP Corp

Audit Summary for the EGC ESP

Review.

2 Page(s)

05/28/2004 ML041560144 2004/05/28-Exelon Generation Legal- Exelon NRC/ASLB 05200007

Company's Answer to Proposed Intervention Generation P

Contentions Petition, Co, LLC,

Responses Morgan,

42 Page(s) and Lewis &

Contentions Bockius, LLP

B-18
Document Accession Title/Description Document Author j Addressee Docket Date Number Includes Est. Page Count Type Affillation(s) Affiliation(s) Number

06/02/2004 M n41620nq0 onn^l06,2oExelon GenerationLegai- Exelon NRC/ASLB 05200007 Company's Answer in Opposition to Motion Generation P

Petitioners' Motion for Extension of Co, LLC, Time to Reply to Response to Morgan, Contentions Lewis &

Bockius, LLP

7 Page(s)

06/08/2004 ML042300808 2004/06/08-E-mail - Figure 1.2-3. E-Mail NRC Exelon 05200007

Corp 1 Page(s)

06/08/2004 ML042450076 2004/06/08-E-mail Re: SSAR Site E-Mail NRC Exelon 05200007

Hazards Visit. Generation

Co, LLC

3 Page(s)

06/10/2004 ML042450074 2004/06/10-E-mail - RE: Figure 1.2-3. E-Mail NRC Exelon 05200007

Generation 2 Page(s) Co, LLC

06/11/2004 ML042300819 2004/06/11-E-mail - RE: Emergency

Plan draft RAIs - Applicant questions.

E-Mail,

Letter

I NRC Exelon

Corp

05200007

4 Page(s)

a. i

06/11/2004 ML042300820 2004/06/11-E-mail - Draft Requests for

Additional Information.

E-Mail,

Request for

Additional

Information

(RAI)

NRC/NRR Exelon

Corp

05200007

12 Page(s)

I a -

B-1 9
Document Accession Title/Description Document Author Addressee Docket Date Number Includes Est. Page Count Type Affiliation(s) Affiliation(s) Number

06/11/2004 ML042450072 2004/06/11 -E-mail - RE: SSAR Site E-Mail NRC Exelon 05200007

Hazards Visit. Generation

Co, LLC

4 Page(s) _

06/18/2004 ML041830154 2004/06/18-Exelon E-mail Forwarding E-Mail Exelon Corp Battelle 05200007

Files for Lake Modeling PT 1 for the Memorial

EGC ESP Review. Institute,

Pacific

25 Page(s) Northwest

National

Lab, NRC,

NRC/NRR/

DRIP/RLEP

06/20/2004 ML041830159 2004/06/20-Staff E-mail to Exelon E-Mail Battelle Battelle 0520007

Regarding Files for Lake Modeling PT 2 Memorial Memorial

for the EGC ESP Review. Institute, Institute,

Pacific Pacific

2 Page(s) Northwest Northwest

National Lab National

Lab, Exelon

Corp, NRC,

NRC/NRR/

DRIP/RLEP

06/22/2004 ML041400206 2004/06/22-Letter to M. Kray, Exelon Letter NRC/NRR/D Exelon 05200007

re: ESP Template RIP/RNRP Generation

Co, LLC 6 Page(s)

B-20
Document Accession Title/Description Document | Author Addressee Docket Date Number Includes Est. Page Count Type Affiliation(s) Affillation(s) Number

m j , u4JuO,23-E-rnaii - Question on Draft NRC Exeion 05200007 Met RAls. Generation

Co, LLC

2 Page(s)

06/23/2004 ML042300810 2004/06/23-E-mail - Response to E-Mail NRC Exelon 05200007 Question on Met RAI. Corp

2 Page(s)

06/23/2004 I ML042280003 2004/06/23-E-mail- RE: Response to

Question on Met RAI.

2 Page(s)

E-Mail Exelon

Generation

Co, LLC

NRC 05200007

4. 4. 4. 1

I 07/02/2004 1 ML042180098 2004/07/02-NRC RAI E5.2-3 - Att El,

Clinton Lake Volume - 24 YR Period of

Record Analysis with Single Uprated

Existing Plant (Forced Loss estimated

based on Forced Loss due to two 992

MW Plants).

11 Page(s)

Graphics

incl Charts

and Tables,

Spreadshee

t File

Exelon

Generation

Co, LLC,

Exelon

Nuclear

NRC/Docu

ment

Control

Desk

05200007

_

B-21

_
Document Accession Title/Description Document Author Addressee Docket Date Number Includes Est. Page Count Type Affillation(s) Afflilation(s) Number

07/07/2004 ML042180099 2004/07/07-NRC RAI E5.2-3 - Att E2, Graphics Exelon NRC/Docu 05200007

Clinton Lake Volume - 24 YR Period of incl Charts Generation ment

Record Analysis with Single Uprated and Tables, Co, LLC, Control

Existing Plant (Forced Loss estimated Spreadshee Exelon Desk

based on Forced Loss due to two 992 t File Nuclear

MW Plants) & New Plant with Wet-Dry

Cooling Process.

15 Page(s)

07/07/2004 ML042180102 2004/07/07-NRC RAI E5.2-3 - Att E3, Graphics Exelon NRC/Docu 05200007

Clinton Lake Volume - 24 YR Period of incl Charts Generation ment

Record Analysis with Single Uprated and Tables, Co, LLC, Control

Existing Plant (Forced Loss estimated Spreadshee Exelon Desk

based on Forced Loss due to two 992 t File Nuclear

MW Plants) and New Plant with Wet

Cooling Process.

11 Page(s)

07/08/2004 ML042300821 2004/08/08-E-mail - Draft Request for E-Mail, NRC/NRR Exelon 05200007

Additional Information. Request for Corp

Additional

10 Page(s) Information

(RAI)

B-22
Document Accession Title/Description | Document | Author 1 Addressee Docket Date Number Includes Est. Page Count Type Affillatlon(s) Affillation(s) Number

37/09/2304 ML041 9022u7 20u4iu709-Environmental u Impact Environmen NRC/NRR/D Exelon 05200007

Statement Scoping Process Summary tal Impact RIP/RLEP Generation

Report - Exelon Generation Company, Statement Co, LLC

LLC Early Site Permit, July 2004, U.S.

Nuclear Regulatory Commission,

Rockville, Maryland.

57 Page(s)

07/09/2004 ML041950214 2004/07/09-Issuance of Environmental Letter NRC/NRR/D Exelon 05200007

Scoping Summary Report Associated RIP/RLEP Generation

with Staff's Review of Application by Co, LLC

Exelon Generation Company, LLC. For

an Early Site Permit for Exelon ESP

Site.

10 Page(s)

07/14/2004 ML042300822 2004/07/14-E-mail - Draft Request for E-Mail, NRC/NRR Exelon 05200007

Additional Information. Request for Corp Additional

9 Page(s) Information

(RAI)

07/15/2004 ML042280013 2004/07/15-E-mail-Draft Requests for E-Mail NRC Exelon 05200007

Additional Information. Generation

Co, LLC

9 Page(s)

B-23
Document Accession Title/Description Document Author Addressee Docket Date Number Includes Est. Page Count Type Affiliation(s) Affiliation(s) Number

07/20/2004 ML042440182 2004/07/20-E-mail - Draft Request for E-Mail NRC/NRR Exelon 05200007

Additional Information. Corp

4 Page(s)

07/21/2004 ML042310775 2004/07/21-E-mail, Public EP Info. E-Mail Exelon NRC 05200007

Generation

2 Page(s) Co, LLC

07/22/2004 ML042440477 2004/07/22-E-mail - Draft Request for E-Mail, NRC/NRR Exelon 05200007

Additional Information. Letter Generation

Co, LLC

4 Page(s)

07/22/2004 ML041890497 2004/07/22-Request for Additional Letter, NRC/NRR/D Exelon 05200007

Information Letter No. 3 - Exelon Early Request for RIP/RNRP Generation

Site Permit (ESP) Application for the Additional Co, LLC

Clinton ESP Site. Information

(RAI)

10 Page(s)__ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _

07/23/2004 ML042180090 2004/07/23-NRC RAI E5.2-1 &-2 - Att A,

Lake Drought Model Description.

Report,

Technical

Exelon

Generation

Co, LLC,

Exelon

Nuclear

NRC/Docu

ment

Control

Desk

05200007

6 Page(s)

IL L_ _ _ _ _ _ _ _

B-24
Document Accession Title/Description Document Author Addressee Docket Date Number Includes Est. Page Count Type Affililation(s ffilations) Number

07/23/2004 ML0I2180079 2O04!07/23Exeor- Generation Legal- Exelon NRC/Docu 05200007 Company, LLC (EGC) Application for Affidavit, Generation ment

an Early Site Permit (ESP) Letter Co, LLC, Control Environmental Requests for Additional Exelon Desk Information.. Nuclear

97 Page(s)

07/23/2004 ML042440486 2004/07/23-E-mail - Draft Request for E-Mail NRC/NRR Exelon 05200007 Additional Information. Generation

Co, LLC . 3 Page(s)

07/23/2004 ML042180095 2004/07/23-NRC RAI E5.2-1 &-2 - Att C, Graphics Exelon NRC/Docu 05200007 Lake Drought Analysis Model, Clinton incl Charts Generation ment Lake Volume - 100 YR RI Dry Period. and Tables, Co, LLC, Control

Spreadshee Exelon Desk

4 Page(s) t File Nuclear

07/23/2004 ML042180088 2004/07/23-NRC RAI E4.4-1 - Att B, - No Exelon NRC/Docu 05200007 Capacity Waste Water Supply - Rev. Document Generation ment

Type Co, LLC, Control

2 Page(s) Applies Exelon Desk

Nuclear

07/23/2004 I ML042180093 2004/07/23-NRC RAI E5.2-1 &-2 - Att B,

Lake Drought Analysis Description.

Report,

Technical

Exelon

Generation

Co, LLC,

Exelon

Nuclear

NRC/Docu

ment

Control

Desk

05200007

4 Page(s)

___________ I __________ -

B-25
Document Accession Title/Description Document Author Addressee Docket

Date Number Includes Est. Page Count Type Affillation(s) Affillation(s) Number

07/23/2004 ML042180106 2004/07/23-NRC RAI E7.1-3 - Att A, Graphics Exelon NRC/Docu 05200007

Revised Table 7.1-2. incl Charts Generation ment

and Tables Co, LLC, Control

3 Page(s) Exelon Desk

Nuclear

07/23/2004 ML042180096 2004/07/23-NRC RAI E5.2-3 - Att D, Report, Exelon NRC/Docu 05200007

Clinton Lake Period of Record Analysis Technical Generation ment - Spreadsheet Column by Column Co, LLC, Control

Explanation. Exelon Desk

Nuclear

11 Page(s)

07/23/2004 ML042180105 2004/07/23-NRC RAI E5.2-3 - Att E4, Graphics Exelon NRC/Docu 05200007

Table 2.3-2, Attachment to July 22, incl Charts Generation ment

2002 Memo from Blonn, Keiser and Toll and Tables, Co, LLC, Control - Revised January 29, 2003. Spreadshee Exelon Desk

t File Nuclear

14 Page(s)

07/26/2004 ML042010267 2004/07/26-Clinton ESP Site Request Letter, NRC/NRR/D Exelon 05200007

For Additional Information Letter No. 4 - Request for RIP/RNRP Generation

Exelon ESP Application. Additional Co, LLC

Information

14 Page(s) (RAI)

07/26/2004 ML04244051 0 2004/07/26-E-mail - RAI Letters. E-Mail, NRC Exelon 05200007

Letter Generation

49 Page(s) I _I _Co, LLC

B-26
Document Accession Title/Description | Document | Author | Addressee Docket Date Number Includes Est. Page Count Type Affiliation(s) | Affiliation(s) Number

07/26/20n0 4 AI 042020n1n 20107I2n-CIntor, ESP Sie Request Letter, NRC/NRR/D Exelon 05200007 For Additional Information Letter No. 7 - Request for RIP/RNRP Generation Exelon ESP Application. Additional Go, LLC

Information

13 Page(s) (RAI)

07/26/2004 ML042020371 2004/07/26-Request For Additional Letter, NRC/N RR/D Exelon 05200007 Information Letter No. 9 - Exelon ESP Request for RIP/RNRP Generation

Application for the Clinton ESP Site. Additional Co, LLC

Information

9 Page(s) (RAI)

07/26/2004 ML042020002 2004/07/26-Clinton ESP Site Request Letter, NRC/NRR/D Exelon 05200007 For Additional Information Letter No. 6 - Request for RIP/RNRP Generation

Exelon ESP Application. Additional Co, LLC

Information

11 Page(s) (RAI)

07/27/2004 ML042280018 2004/07/27-E-mail - RE: RAI Letters. E-Mail Exelon Corp Exelon 05200007

Corp, NRC

2 Page(s)

07/27/2004 ML042020408 2004/07/27-Request For Additional Letter, NRC/NRR/D Exelon 05200007 Information Letter No. 10 - Exelon ESP Request for RIP/RNRP Generation

Application for the Clinton ESP Site. Additional Co, LLC

Information

9 Page(s) (RAI)

07/27/2004 ML042440530 2004/07/27-E-mail - RAI Letters. E-Mail, NRC Exelon 05200007

Letter Generation

47 Page(s) Co, LLC

B-27
Document Accession Title/Description Document Author Addressee Docket

Date Number Includes Est. Page Count Type Affiliation(s) Affiliation(s) Number

07/27/2004 ML042020021 2004/07/27-Request For Additional Letter, NRC/NRR/D Exelon 05200007

Information Letter No. 8 - Exelon ESP Request for RIP/RNRP Generation

Application for the Clinton ESP Site. Additional Co, LLC

Information

10 Page(s) (RAI)

07/27/2004 ML042440523 2004/07/27-E-mail - RAI Letters. E-Mail, NRC Exelon 05200007

Letter Generation

49 Page(s) Co, LLC

07/27/2004 ML042050408 2004/07/27-Exelon ESP Application for Letter, NRC/NRR/D Exelon 05200007

the Clinton ESP Site (TAC No. Request for RIP/RNRP Generation

MC1 122). Additional Co, LLC

Information

13 Page(s) (RAI)

07/27/2004 ML042280017 2004/07/27-E-mail- RE: RAI Letters. E-Mail Exelon Corp Exelon 05200007

Corp, NRC

2 Page(s)

07/27/2004 ML042010334 2004/07/27-Request For Additional Letter, NRC/NRR/D Exelon 05200007

Information Letter No. 5 - Exelon ESP. Request for RIP/RNRP Generation

Application for the Clinton ESP Site. Additional Co, LLC

Information

7 Page(s) (RAI)

07/30/2004 ML042440473 2004/07/30-E-mail - RAI Letter No. 3. E-Mail NRC Exelon 05200007

Corp

11 Page(s)

B-28
Document Accession Title/Description Document Author Addressee Docket Date Number Includes Est. Page Count Type Affiliation(s) Affillation(s) Number

08_2_/2on4 IuL0423705u51 I ofU6 L lor Additiouial Letter, NRUNHR/D Exelon 05200007 Information (RAI) Regarding the Request for RIP/RLEP Generation

Environmental Portion of the Early Site Additional Co, LLC

Permit Application for the Exelon Information

Generation Company Site (TAC NO. (RAI) MC1 125).

9 Page(s)

08/24/2004 ML042230041 2004/08/24-Exelon, Revision to RAI No. Letter, NRC/NRR/D Exelon 05200007

11 - ESP Application for Clinton ESP Request for RIP/RNRP Generation Site. Additional Co, LLC

Information

12 Page(s) (RAI)

08/31/2004 ML042530527 2004/08/31-Exelon Generation Legal-Brief Exelon NRC/OCM 05200007 Company's Answer in Opposition to Generation

Petition for Interlocutory Review Co, LLC,

Morgan, 40 Page(s) Lewis &

Bockius, LLP _

09/07/2004 ML042660165 2004/09/07-Submittal of Early Site Letter Exelon NRC/Docu 05200007

Permit Quality Plans. Nuclear ment

Control

7 Page(s) Desk

B-29
Document Accession Title/Description Document Author Addressee Docket Date Number Includes Est. Page Count Type Affillation(s) Affillation(s) Number

09/07/2004 ML042600182 2004/09/07-Letter from Paul M. Legal- Exelon Environme 05200007

Bessette to Shannon Fisk and Tyson R. Interrogatori Generation ntal Law &

Smith attaching disclosures with es and Co, LLC, Policy Ctr, respect to Contention 3.1 as admitted Response Morgan, NRC/OGC

by the Licensing Board Lewis &

Bockius, LLP

5 Page(s)

09/07/2004 ML042750231 2004/09/07-E-mail w/o att-EGC ESP E-Mail Exelon NRC 05200007

Quality Plan. Generation

Co, LLC

2 Page(s)

09/17/2004 ML042590004 2004/09/17 - Summary of Meeting with Meeting NRC/NRR/D Dominion 05200007, Dominion, SERI and Exelon Regarding Summary RIP/RNRP Nuclear 05200008,

Reviews of EP Aspects of Their North 05200009

Respective ESP Applications. Anna, LLC,

Exelon

10 Page(s) Generation

Co, LLC,

Exelon

Nuclear,

System

Energy

Resources,

._ _ _ _ Inc

B-30
Document Accession Title/Description Document Author Addressee Docket Date Number Includes Est. Page Count Type Affillation(s) Affillation(s) Number

09/17124 L0427305 20041091117-Exeion Generation Letter Exelon NRC/Docu 05200007 Company, LLC (EGC), Delay in Nuclear ment

Responding to Requests for Additional Control

Information (RAI) regarding the Desk

Environmental Portion of the

Application for an Early Site Permit

(ESP).

2 Page(s)

09/17/2004 ML042680065 2004/09/17-Joint Response of Exelon Legal- Exelon NRC/ASLB 05200007

Generation Company and the NRC Report Generation P

Staff to Licensing Board Request Co, LLC, Regarding Mandatory Hearing Morgan, Procedures for the Clinton Early Site Lewis &

Permit Bockius, LLP

14 Page(s)

09/21/2004 ML042730214 2004/09/21 -Letter from Steven P. Legal- Exelon NRC/ASLB 05200007

Frantz to Administrative Judges Correspond Generation P

informing of the agreement of Exelon ence Co, LLC, Generation Company, Intervenors, and Morgan, the NRC staff regarding updates to Lewis &

discovery disclosures under 10 CFR § Bockius, LLP

2.336(d)

4 Page(s)

B-31
Document Accession Title/Description Document Author Addressee Docket Date Number Includes Est. Page Count Type Affillation(s) Affiliatlon(s) Number

09/23/2004 ML042730012 2004/09/23-Exelon Generation . Legal- Exelon NRC/Docu 05200007

Company, LLC (EGC), Response to Affidavit, Nuclear ment

Requests for Additional Information Letter Control

(RAI) regarding the Environmental Desk

Portion of the Application for an Early

Site Permit (ESP).

51 Page(s) _

09/24/2004 ML042730467 2004/09/24-Letter from Steven P. Legal- Exelon NRC/ASLB 05200007

Frantz to Administrative Judges Correspond Generation P

enclosing a copy of a letter dated ence Co, LLC,

09/23/04 from Exelon Generation Morgan, Company to the NRC staff responding Lewis &

to several Requests for Additional Bockius, LLP

Information

54 Page(s)

09/28/2004 ML042790495 2004/09/28-Response to Request for Letter Exelon NRC/Docu 05200007

Additional Information (RAI) Letter No. Nuclear ment

5 - Exelon Early Site Permit (ESP) Control

Application for the Clinton ESP Site Desk

(TAC No. MCI 122.).

10 Page(s)

09/28/2004 ML042780333 2004/09/28-E-mail-Response to RAI E-Mail Exelon NRC 05200007

Letter No. 5. Generation

Co, LLC

12 Page(s)

B-32
Document Accession Title/Description Document Author | Addressee Docket Date Number Includes Est. Page Count Type Affillation(s) | Affillation(s) [ Number 1 0/01/2004 MI-04P7QfAonq 9nnAI1~-1nn.C ..- Ia*...:-rr~ MAIe .. . K1 

10/0 1/200 Ml- I - L I .1 IIIAII_$ :v Etx<alon ErS E-ivaii, Exeion NRC 05200007 Quality Plan. Letter Generation

Co, LLC

2 Page(s)

10/01/2004 ML042790139 2004/10/01-E-mail-Re: FW: Exelon E-Mail, NRC Exelon 05200007 ESP Quality Plan. Letter Generation

Co, LLC

2 Page(s)

10/05/2004 ML04289041 8 Response to Request for Additional Letter Exelon NRC/Docu 05200007

Information (RAI) Letter No. 3 - Exelon Nuclear ment

Early Site Permit (ESP) Application for Control

the Clinton ESP Site (TAC No. Desk

MCI 122).

43 Page(s)

10/06/2004 ML042860252 2004/10/06-E-mail - Typographical E-Mail NRC Exelon 05200007

Error in RAI Letter No. 7. Generation

Co, LLC

2 Page(s)

10/06/2004 ML042800504 2004/10/06-Telecon Summary to Note NRC/NRR/D Exelon 05200007

Clarify Responses to NRC RIP/RLEP Generation

Environmental Requests for Additional Co, LLC

Information on the Exelon Early Site

Permit Application.

9 Page(s)

B-33
Document Accession Title/Description Document Author Addressee Docket Date Number Includes Est. Page Count Type Affiliation(s) Affiliation(s) Number

10/06/2004 ML042860248 2004/10/06-E-mail-First EP RAI E-Mail, Exelon NRC 05200007

response submittal. Letter Generation

Go, LLC _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ 4 4 P a g e (s) _ _ _ _ _ _ _ _ _ _ _ __ _ _ _ _

10/07/2004 I ML042890357 2004/10/07-Response to Request for

Additional Information (RAI) Letter No.

8 - Exelon Early Site Permit (ESP)

Application for the Clinton ESP Site.

Letter Exelon

Nuclear

NRC/Docu

ment

Control

Desk

105200007

33 Page(s)

I 10/07/2004 I ML042890390 Response to Revision to Request for Emergency Exelon NRC/Docu 05200007

Additional Information (RAI) Letter- No. Preparedne Nuclear ment

11 - Exelon Early Site Permit (ESP) ss- Control

Application for the Clinton ESP Site Emergency Desk

(TAC No. MC1 122.) Plan, Letter

67 Page(s)

ML042870496 2004/10/07-Letter from Paul M. Legal- Exelon Environme 05200007

Bessette to Shannon Fisk and Mauri T. Affidavit, Generation ntal Law &

Lemoncelli attaching updates to Legal- Co, LLC, Policy Ctr,

disclosures with respect to Contention Correspond Morgan, NRC/OGC

3.1 ence Lewis &

Bockius, LLP

5 Page(s)

I 10/07/2004

B-34
Document Accession TitlelDescription Document Author Addressee Docket Date Number Includes Est. Page Count Type Affiliation(s) Affiliatlon(s) Number

10n/0/2004 I ML04288A60 2004/1 0/08-fl espo nse to Requesi for Letter Exelon NRC/Docu 05200007 Additional Information (RAI) Letter No. Nuclear ment

10 - Exelon Early Site Permit (ESP) Control

Application for the Clinton ESP Site Desk

(TAC No. MC1 122.)

15 Page(s)

10/08/2004 ML042990572 2004/10/08-Email- Response to RAI E-Mail Exelon NRC 05200007 Letter No. 11. Generation

Co, LLC

2 Page(s)

10/08/2004 ML042920203 10/08/04-E-mail- Response to RAI E-Mail, Exelon NRC 05200007

Letter No. 11. Legal- Generation

Affidavit, Co, LLC

68 Page(s) Letter,

Report,

Miscellaneo

us

10/08/2004 ML042890051 2004/10/08-Response to Request for Letter Exelon NRC/Docu 05200007 Additional Information (RAI) Letter No. Nuclear ment

4 - Exelon Early Site Permit (ESP) Control Application for the Clinton ESP Site. Desk

145 Page(s)

10/08/2004 ML042860254 2004/10/08-E-mail - Response to RAI E-Mail, Exelon NRC 05200007 Letter No. 8. Letter Generation

Co, LLC

35 Page(s)

B-35
Document Accession Title/Description Document Author Addressee Docket Date Number Includes Est. Page Count Type Affiliation(s) Afflilation(s) Number

10/08/2004 ML042880466 2004/10/08-Response to NRC Letter Exelon NRC/Docu 05200007

Inspection of Applicant and Contractor Nuclear ment

Quality Assurance Activities Involved Control

with Preparation of the Application for Desk

an Early Site Permit, Report

0520007/2004001.

12 Page(s)

10/11/2004 ML042920225 2004/10/11-E-mail-RE: Response to E-Mail, Exelon NRC 05200007

QA IR. Letter Generation

Co, LLC

14 Page(s)

10/11/2004 ML042920222 2004/10/11-E-mail- RE: Response to E-Mail, Exelon NRC 05200007

RAI Letter No. 4 Legal- Generation

Affidavit, Co, LLC

147 Page(s) Letter,

Report,

Miscellaneo

us

10/11/2004 ML042920213 2004/10/11-E-mail- Response to RAI E-Mail, Exelon NRC 05200007

Letter No. 10. Legal- Generation

Affidavit, Co, LLC

17 Page(s) Letter

B-36
Document Accession Title/Description Document Author Addressee | Docket Date Number Includes Est. Page Count Type Affillatlon(s) | Affiliation(s) | Number

10/11/2004 ML0429601 06 2004/10/11 s- -Rcsponsv to II- * ,0f Leter xelon NRC/Docu 05200007 Additional Information (RAI) Letter No. Generation ment

7 - Exelon Early Site Permit (ESP) Co, LLC, Control

Application for the Clinton ESP Site. Exelon Desk

Nuclear

91 Page(s)

10/11/2004 ML042960057 2004/10/11-Response to Request for Letter Exelon NRC/Docu 05200007 Additional Information (RAI) Letter No. Nuclear ment 9 - Exelon Early Site Permit (ESP) Control

Application for the Clinton ESP Site. Desk

8 Page(s)_ _

10/11/2004 ML042960105 Response to Request for Additional Legal- Exelon NRC/Docu 05200007 Information (RAI) Letter No. 6 - Exelon Affidavit, Nuclear ment

Early Site Permit (ESP) Application for Letter Control

the Clinton ESP Site. Desk

56 Page(s)

10/12/2004 ML043030610 2004/10/12-E-mail-FW: 3r set of E-Mail Exelon NRC 05200007 seismic attachments #2. Generation

Co, LLC

3 Page(s)

10/12/2004 ML043030613 2004/10/12-E-mail-RAI 2.5.2-6 Figure E-Mail Exelon NRC 05200007

1A. Generation

Co, LLC

3 Page(s) . -

B-37
Document Accession Title/Description Document Author Addressee Docket Date Number Includes Est. Page Count Type Affiliation(s) Affiliation(s) Number

10/12/2004 ML043030672 2004/10/12-E-mail-RE: 3rd set of E-Mail Exelon NRC 05200007

seismic attachments (8 of 11). Generation

Co, LLC

2 Page(s)

10/12/2004 ML042920229 2004/10/12-E-mail- Response to RAI E-Mail Exelon NRC 05200007

Letter No. 6. Generation

Co, LLC

383 Page(s) _

10/12/2004 ML043030667 2004/10/12-E-mail-RE: 3 rd set of E-Mail Exelon NRC 05200007

seismic attachments (7 of 11). Generation

Co, LLC

2 Page(s)

10/12/2004 ML042920234 2004/10/12-E-mail- Response to RAI E-Mail, Exelon NRC 05200007

Letter No. 9. Letter Generation

Co, LLC

10 Page(s)

10/12/2004 ML043030600 2004/10/12-E-mail-FW: 3 rd set of E-Mail Exelon NRC 05200007

seismic attachments. Generation

Co, LLC

3 Page(s)

10/12/2004 ML043030592 2004/10/12-E-mail-2nd set of seismic E-Mail Exelon NRC 05200007

attachments. Generation

Co, LLC

2 Page(s)

B-38
Document Accession Title/Description Document Author Addressee Docket Date Number Includes Est. Page Count Type Affiliation(s) Affiliation(s) Number

10/12/2004 MLI03O~ R8 200'/10/12-E-moain-l se' st of sEivsrnaii Exeion NRC 05200007

attachments Generation

Co, LLC

2 Page(s)

10/12/2004 ML043030700 2004/10/12-E-mail-RE: 3rd set of E-Mail Exelon NRC 05200007

seismic attachments (12 of 12). Generation

Co, LLC

2 Page(s)

10/12/2004 ML043030664 2004/10/12-E-mail-RE: 3rd set of E-Mail Exelon NRC 05200007

seismic attachments (6 of 11). Generation

Co, LLC

2 Page(s)

10/12/2004 ML043030660 2004/10/12-E-mail- RE: 3rd set of E-Mail Exelon NRC 05200007

seismic attachments (5 of 11). Generation

Co. LLC

2 Page(s) _ _

10/12/2004 ML043030651 2004/10/12-E-mail-FW: 3rd set of E-Mail Exelon NRC 05200007

seismic attachments (2 of 11). Generation

Co, LLC

2 Page(s)

10/12/2004 ML043030631 2004/10/12-E-mail-RE: 3rd set of E-Mail Exelon NRC 05200007

seismic attachments (4 of 11). Generation

Go,sLLC ___________ ~~2 P ag e(s)__ _ _ _ _ _ _ _ _ _ _ _ __ _ _ _ _ _ _ _ _ _ _

B-39
Document Accession Title/Description Document Author Addressee Docket Date Number Includes Est. Page Count Type Affiliation(s) Affillation(s) Number

10/12/2004 ML043030697 2004/10/12-E-mail-RE: 3rd set of E-Mail Exelon NRC 05200007

seismic attachments (9 of 1 1). Generation

Co, LLC

2 Page(s)

10/12/2004 ML043030696 2004/10/12-E-mail- RE: 3rd set of E-Mail Exelon NRC 05200007

seismic attachments (11 of 11). Generation

Go, LLC

2 Page(s) _

10/12/2004 ML043030617 2004/10/12-E-mail- 3rd set of seismic E-Mail Exelon NRC 05200007

attachments (1 of 11). Generation

Co, LLC

3 Page(s)

10/12/2004 ML043030626 2004/10/12-E-mail-RE: 3rd set of E-Mail Exelon NRC 05200007

seismic attachments (3 of 11). Generation

Co, LLC

2 Page(s)

10/12/2004 ML043030577 2004/10/12-E-mail-Response to RAI E-Mail, Exelon NRC 05200007

Letter No. 7. Letter Generation

Go, LLC

2 Page(s)

10/12/2004 ML043030675 2004/10/12-E-mail-RE: 3rd set of E-Mail Exelon NRC 05200007

seismic attachments (10 of 11). Generation

Go,sLLC __ _ _ _ _ _ _ _ _ _ _ _ 2 P a g e (s) _ _ _ L__ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _

B-40
Document Accession TitlelDescriptlon Document Author Addressee Docket Date Number Includes Est. Page Count Type Affillation(s) Affiliation(s) Number

10/19/2004 ML0430305-3 200a/1 f! 9-E-mai! - Sc i scc-Man Exe ion NNC 05200007 Consultant. Generation

Co, LLC

1 Page(s) Co____

10/20/2004 ML043030557 2004/10/20-E-mail-Re: Seismic E-Mail, NRC Exelon 05200007 Consultant. Letter Generation

Co, LLC 2 Page(s) _ Co,__ _ _

10/22/2004 ML043060232 2004/10/22-Letter from Paul M. Legal- Exelon Environme 05200007 Bessette to Shannon Fisk and Mauri T. Correspond Generation ntal Law & Lemoncelli attaching an update to ence Co, LLC, Policy Ctr, disclosures with respect to Contention Morgan, NRC/OGC 3.1 as admitted by the Licensing Board Lewis &

Bockius, LLP

5 Page(s)

10/28/2004 ML042820082 2004/10/28-Clinton, Withholding From Letter, NRC/NRR/D Exelon 05200007 Public Disclosure, Exelon ESP Project Proprietary RIP/RNRP Generation Quality Assurance Plan. Information Co, LLC

Review

6 Page(s)

11/05/2004 ML043140401 11/05/04-E-mail-Conference Call E-Mail NRC Exelon 05200007

Information, Generation

Co, LLC

1 Page(s)

B-41
Document Accession Title/Description Document Author Addressee Docket

Date Number Includes Est. Page Count Type Affiliation(s) Afflilation(s) Number

11/12/2004 ML043200576 2004/11/12-E-mail-Draft Requests for E-Mail, NRC/NRR Exelon 05200007

Additional Information - Emergency Letter, Generation

Planning. Request for Co, LLC

Additional

5 Page(s) Information

(RAI)

11/12/2004 ML043240474 2004/11/12-Exelon Generation Legal- Exelon NRC/ASLB 05200007

Company's Answer in Opposition to Motion Generation P

Intervenors' Motion to Suspend Co, LLC,

Proceeding Pending Reinstatement of Morgan,

Agencywide Document Access and Lewis &

Management System Bockius, LLP

8 Page(s)

11/15/2004 ML043210579 2004/11/15-Request for Additional Request for NRC/NRR/D Exelon 05200007

Information (RAI) Regarding the Additional RIP/RLEP Generation

Environmental Portion of the Early Site Information Co, LLC

Permit Application for The Exelon (RAI)

Generation Company Site (TAC No.

MC1 125).

7 Page(s)

11/15/2004 ML043090029 2004/11/15-Revised Dates For Letter NRC/NRR/D Exelon 05200007

Conducting the Environmental Review RIP/RNRP Generation

of the Exelon ESP Application. Co, LLC

7 Page(s)

B-42
Document Accession Title/Description Document Author Addressee | Docket Date Number Includes Est. Page Count Type Affillation(s) Affiliatlon(s) Number

11/16/2004 ML04.qOnnnrl 2004/11 ! "-Corr.ctions I Clari,,catks Environmen Exelon NRC/Docu 05200007 to the Exelon Early Site Permit (ESP) tal Report, Nuclear ment Application Environmental Report for Letter Control

the Clinton ESP Site. Desk

67 Page(s)

11/18/2004 ML043410062 2004/11/18-E-mail correspondence E-Mail Exelon Corp NRC, 05200007 regarding ER corrections relating to the NRC/NRR/ EGC ESP environmental review. DRIP/RLEP

Pacific

1 Page(s) National

Lab

11/19/2004 ML043270432 2004/11/19-E-mail- Seismic Primer. E-Mail Exelon NRC 05200007

Generation

33 Page(s) Co, LLC

11/19/2004 ML043350394 2004/11/19-Seismic Risk (Performance Letter Exelon NRC/Docu 05200007

Goal) Based Approach Primer - Exelon Nuclear ment Early Site Permit (ESP) Application for Control the Clinton ESP Site. Desk

31 Page(s)

11/30/2004 ML043360250 2004/11/30-E-mail- Final 2004 NRC E-Mail Exelon Corp NRC 05200007

Invoice.

__ 2 Page(s)

B-43
Document Accession Tltle/Descriptlon Document Author Addressee Docket

Date Number Includes Est. Page Count Type Affiliation(s) Affillation(s) Number

12/07/2004 ML043510176 2004/12/07-Letter from Paul M. Legal- Exelon Environme 05200007

Bessette to Shannon Fisk and Mauri T. Affidavit, Generation ntal Law &

Lemoncelli attaching an update to Legal- Co, LLC, Policy Ctr,

disclosures with respect to Contention Correspond Morgan, NRC/OGC

3.1 as admitted by the Licensing Board ence Lewis &

Bockius, LLP

4 Page(s)

12/07/2004 ML043510382 2004/12107-Corrections/Clarifications to Emergency Exelon NRC/Docu 05200007

the Exelon Generation company, LLC Preparedne Nuclear ment

(EGC) Early Site Permit (ESP) ss- Control

Application Site Safety Analysis Report Emergency Desk

and Emergency Plan for the Clinton Plan, Final

ESP Site. Safety

Analysis

56 Page(s) Report

(FSAR),

Letter

12/08/2004 ML043480194 2004/12/08-E-mail-Self identified E-Mail, Exelon Corp NRC 05200007

changes. Letter

58 Page(s)

12/09/2004 ML043380008 2004/12109-Request for Additional Letter, NRC/NRR/D Exelon 05200007

Information Letter No. 12 - Exelon ESP Request for RIP/RNRP Generation

Application for the Clinton ESP Site. Additional Co, LLC,

Information Exelon

9 Page(s) (RAI) Nuclear

B-44
Document Accession Title/Description Document | Author Addressee | Docket Date Number Includes Est. Page Count Type Affiliation(s) Affiliation(s) Number

/1q/2fO4 Ml oAnL0n330A25 onA 0/1/ / -Response to Raequest I o Luai- Exeion Corp, N(;L/ocu 05200007

Additional Information (RAI) - Exelon Affidavit, Exelon ment

Early Site Permit (ESP) Application for Letter Nuclear Control

the Clinton ESP Site. Desk

7 Page(s)

12/13/2004 ML043570096 2004/12/13-E-mail correspondence E-Mail, Exelon Corp Battelle 05200007

regarding S-3 request for additional Environmen Memorial

information response pertaining to the tal Impact Institute, Exelon ESP project. Statement Pacific

Northwest

9 Page(s) National

Lab, NRC

12/14/2004 ML050030024 2004/12/14-Revised Response to - No Exelon Corp, NRC/Docu 05200007

Request for Additional Information Document Exelon ment

(RAI) Letter No. 3 re: Early Site Permit Type Nuclear Control

(ESP) Application for the Clinton ESP Applies Desk

Site.

13 Page(s)

12/15/2004 ML050030022 2004/12/15-Transmittal of Revised Legal- Exelon Corp, NRC/Docu 05200007

Response to Request for Additional Affidavit, Exelon ment

Information (RAI) Letter No. 3 re: Early Letter Nuclear Control

Site Permit (ESP) Application for the Desk

Clinton ESP Site.

3 Page(s)

B-45
Document Accession Title/Descriptlon Document Author Addressee Docket Date Number Includes Est. Page Count Type AffiliatIon(s) Affiliation(s) Number

12/15/2004 ML043520443 2004/12/15-E-mail-Docket 52-007 re: E-Mail Exelon NRC 05200007

EGC Revised RAI 13.3-2 Response. Generation

Co, LLC

16 Page(s)

12/15/2004 ML043520433 2004/12/15-E-mail-Docket 52-007 re: E-Mail Exelon NRC 05200007

Seismic High Frequency Effects. Generation

Co, LLC

6 Page(s)

12/15/2004 ML043630437 2004/12/15-Early Site Permit Letter Exelon NRC/Docu 05200007

Application for Clinton ESP Site, Nuclear ment

Seismic High Frequency Control

Considerations (TAC No. MCI122). Desk

4 Page(s)

12/16/2004 ML043520441 2004/12/16-E-mail-Re: Projection of E-Mail Exelon NRC 05200007

NRC Year End Invoices. Generation

Co, LLC

2 Page(s)

12/16/2004 ML043520438 2004/12/16-E-mail-Projection of NRC E-Mail Exelon NRC 05200007

Year End Invoices. Generation

Co, LLC

3 Page(s)

12/16/2004 ML043520439 2004/12/16-E-mail-Re: Projection of E-Mail NRC Exelon 05200007

NRC Year End Invoices. Generation

Co, LLC

2 Page(s)

B-46
Document Accession Title/Description Document Author Addressee Docket Date Number Includes Est. Page Count Type Afflilation(s) Affiliation(s) Number

01/14/2005 ML-05501117 q 114-Early Site (S)raphics Gemit Exelon NRC/Docu 05200007

Application for the Clinton ESP Site incl Charts Nuclear ment

Seismic Risk (Performance Goal) and Tables, Control

Based Approach Primer Revision. Legal- Desk

Affidavit,

32 Page(s) Letter

01/14/2005 ML050140051 2005/01/14-Exelon Early Site Permit Letter NRC/NRR/D Exelon 05200007 Project Manager Reassignment. RIP/RNRP Generation

Co, LLC

5 Page(s)

01/24/2005 ML050250305 2005/01/24-E-mail EP ETE RAI E-Mail, Exelon NRC/NRR/ 05200007

Responses to Letter No. 12. Graphics Generation DRIP/RNR

incl Charts Co, LLC P

88 Page(s) and Tables,

LegalAffidavit

02/01/2005 ML043570375 2005/02/01-Clinton, Withholding From

Public Disclosure, Exelon ESP

Application - State and Local

Emergency Plans.

Letter,

Proprietary

Information

Review

NRC/NRR/D

RIP/RNRP

Exelon

Generation

Co, LLC

05200007

5 Page(s)

I 02/04/2005 I ML050320230 2005/02/04-Potential Open Items for Letter NRC/NRR/D Exelon 05200007

the Draft Safety Evaluation Report for RIP Generation

the Exelon Early Site Permit Co, LLC

Application.

12 Page(s)

B-47
Document Accession Title/Description Document Author Addressee Docket

Date Number Includes Est. Page Count Type Afflilatlon(s) Affillation(s) Number

02/07/2005 ML050390092 2005/02/07-E-mail-Potential Exelon E-Mail, NRC/NRR Exelon 05200007

ESP DSER Open Items. Letter Generation

Co, LLC

10 Page(s)

02/10/2005 ML050400350 2005/02/10-Draft Safety Evaluation Letter, NRC/NRR/D Exelon 05200007

Report for the Exelon Early Site Permit Safety RIP/RNRP Generation

Application. Evaluation Co, LLC

Report, 9 Page(s) Draft

02/11/2005 ML050480478 2005/02/11-E-mail-Re: Copy of Exelon Draft Safety NRC Exelon 05200007

ESP DSER, Appendices A & B. Evaluation Generation

Report Co, LLC,

54 Page(s) (DSER), E- NRC

Mail,

Graphics

incl Charts

and Tables

02/11/2005 ML050480447 2005/02/11-E-mail-Re: Copy of Exelon Draft Safety NRC Exelon 05200007

ESP DSER-#1. Evaluation Generation

Report Co, LLC,

169 Page(s) (DSER), E- NRC

Mail, Letter

02/11/2005 ML050670436 2005/02/11-E-mail- Re: Copy of Exelon E-Mail NRC Exelon 05200007

ESP DSER. Generation

Co, LLC,

2 Page(s) NRC

B-48
Document Accession Title/Description Date | Document 1 Author | Addressee Docket Number Includes Est. Page Count Type Affillation(s) Affiliation(s) Number

02/1 512005i M1.0505503-56 I2005!0-11 5-Lcttr rom Paul IvM. Legai- Exeion Environme 05200007 Bessette to Shannon Fisk and Mauri T. Affidavit, Generation ntal Law & Lemoncelli providing an update to Legal- Co, LLC, Policy Ctr, disclosures with respect to Contention Correspond Morgan, NRC/OGC 3.1 as admitted by the Licensing Board ence Lewis &

Bockius, LLP

4 Page(s)

02/23/2005 ML050630552 2005/02/03-Review of Draft Safety Letter Exelon NRC/Docu 05200007 Evaluation Report for the Early Site Nuclear ment Permit (ESP) Application for the Clinton Control ESP Site. Desk

2 Page(s)

B-49
Document Accession Title/Description Document Author Addressee Docket Date Number Includes Est. Page Count Type Affiliation(s) Affillation(s) Number

02/24/2005 ML050600414 2005/02/24-E-Mail - Fwd: Draft Safety

Evaluation Report for the Exelon Early

Site Permit Application.

10 Page(s)

E-Mail NRC/NRR/D

RIP/RNRP

Advanced

Technologi

es & Labs

Internationa

I, Inc, AECL

Technologi

es, Inc.

Dominion,

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Entergy

Nuclear

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Inc, Exelon

Corp,

Framatome

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General

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General

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Greenpeac

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Nuclear

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B-50
Document Accession Title/Description Document Author Addressee Docket Date Number Includes Est. Page Count Type Affillation(s) Affillation(s) Number

02/28/2005 ML050400378 20n5;/02q/-r!qnton, Early Site Dnrmf SKfafy NRC/NRRID Exe;n- 0-200007 Draft Safety Evaluation Report, Chapter Evaluation RIP/RNRP Generation

1 with Table of Contents and Report, Co, LLC

Abbreviations. Draft

29 Page(s) l

02/28/2005 ML050400411 2005/02/28-Clinton, Early Site Permit Safety NRC/NRR/D Exelon 05200007

Draft Safety Evaluation Report, Chapter Evaluation RIP/RNRP Generation

18, Review by the Advisory Committee Report, Co, LLC

on Reactor Safeguards. Draft

1 Page(s)

02/28/2005 ML050400404 2005/02/28-Clinton, Early Site Permit Safety NRC/NRR/D Exelon 05200007 Draft Safety Evaluation Report, Chapter Evaluation RIP/RNRP Generation

17, Quality Assurance. Report, Co, LLC

Draft

39 Page(s)__ _ _ _ _ __ _ _ _ _ __ _ _ _ _

02/28/2005 1 ML050400436 2005/02/28-Clinton, Early Site Permit

Draft Safety Evaluation Report,

Appendix A, Chronology of Early Site

Permit application for the EGC ESP

Site.

Safety

Evaluation

Report,

Draft

NRC/NRR/D

RIP/RNRP

Exelon

Generation

Co, LLC

05200007

43 Page(s)

B-51
Document Accession Title/Description Document Author Addressee Docket

Date Number Includes Est. Page Count Type Affiliation(s) Affiliation(s) Number

02/28/2005 ML050400394 2005/02/28-Clinton, Early Site Permit Safety NRC/NRR/D Exelon 05200007

Draft Safety Evaluation Report, Chapter Evaluation RIP/RNRP Generation

3, Site Safety Assessment. Report, Co, LLC

Draft

26 Page(s)

02/28/2005 ML050400423 2005/02/28-Clinton, Early Site. Permit Safety NRC/NRR/D Exelon 05200007

Draft Safety Evaluation Report, Chapter Evaluation RIP/RNRP Generation

19, Conclusions. Report, Co, LLC

Draft

1 Page(s)

02/28/2005 ML050400386 2005/02/28-Clinton, Early Site Permit Safety NRC/NRR/D Exelon 05200007

Draft Safety Evaluation Report, Chapter Evaluation RIP/RNRP Generation

2, Site Characteristics. Report, Co, LLC

Draft

139 Page(s) _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _

02/28/2005 I ML050400450 2005/02/28-Clinton, Early Site Permit

Draft Safety Evaluation Report,

Appendix B, References.

Safety

Evaluation

Report,

Draft

NRC/NRR/D

RIP/RNRP

Exelon

Generation

Co, LLC

05200007

9 Page(s)

I 03/02/2005 ML050620302 2005/03/02-Notice of Availability of the Federal NRC/NRR/D Exelon 05200007

Draft Environmental Impact Statement Register RIP Generation

(DEIS) for An Early Site Permit (ESP) Notice, Co, LLC

at the Exelon ESP Site (TAC NO. Letter

MC1 125).

10 Page(s) _

B-52
Document Accession Title/Description Document Author Addressee [ Docket

Date Number Includes Est. Page Count Type Affiliation(s) Affiliation(s) j Number

3-0-200-5 -. L5.0C7027n On A,'3,A' 3- -I 'allGi SLOP r-e: E-Mviaii Exelon NHR/iNH/ 05200007

NRC Invoice for 4 th Qtr 2004. Generation DRIP/RNR

Co, LLC P . 2 Page(s) lI

B-53
Document Accession Title/Description Document Author Addressee Docket

Date Number Includes Est. Page Count Type Affillatlon(s) Affillation(s) Number

03/04/2005 ML050540039 2005/03/04-Draft Safety Evaluation

Report for the Exelon Early Site Permit

Application.

7 Page(s)

Letter NRC/NRR/D

RIP/RNRP

- No Known

Affiliation,

Advanced

Technologi

es & Labs

Internationa

1, Inc,

CH2M Hill,

Dominion

Generation,

Enercon

Services,

Inc,

Entergy

Nuclear,

Inc, Exelon

Generation

Co, LLC,

Exelon

Nuclear,

Framatome

ANP

Richland,

Inc,

Greenpeac

e, Morgan,

Lewis &

Bockius,

LLP,

Nuclear

05200007

B-54
Document Accession Title/Description Document Author Addressee Docket

Date Number Includes Est. Page Count Type Affillation(s) Affiliation(s) Number

03/04/2005 ML050670302 200,'/03;04-E-maii-Exeion ESP re: E-Mail NRC/NRR/D Exelon 05200007

NRC Invoice for 4 th Qtr 2004. RIP/RNRP Generation

Co, LLC

2 Page(s)

03/08/2005 ML050670580 2005/03/08-E-mail-Conference line for E-Mail Exelon Corp NRC/NRR/ 05200007

Thursday Hydrology call. DRIP/RNR

P

2 Page(s) I

B-55

. . . _

_
Document Accession Title/Description Document Author Addressee Docket

Date Number Includes Est. Page Count Type Affiliation(s) Affiliation(s) Number

1 03/08/2005 ML050670322 2005/03/08-E-mail-Fwd: Draft Safety

Evaluation Report for the Exelon Early

Site Permit Application.

13 Page(s)

E-Mail NRC/NRR/D

RIP/RNRP

Advanced

Technologi

es & Labs

Internationa

I, Inc, AECL

Technologi

es, Inc,

Dominion,

Eckert,

Seamans,

Cherin &

Mellott,

LLC,

EmergiLite,

Entergy

Nuclear

Operations,

Inc, Exelon

Corp,

Framatome

ANP, Inc,

General

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General

Electric Co,

Greenpeac

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Nuclear

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B-56
Document Accession Title/Descriptlon Document Author Addressee Docket Date Number Includes Est. Page Count Type Affillation(s) Affiliation(s) Number ____L00 kLIAO5080AAA7 onnA,/n'2/1 -I- o"Grro rla...a aa U5200007V.

M -_-_ I%.'I JII L.te. fr imi auIlv M. LUzyai- Exeion tnvironme U5200007

Bessette to Shannon Fisk and Mauri T. Interrogatori Generation ntal Law &

Lemoncelli attaching an update to es and Co, LLC, Policy Ctr, disclosures with respect to Contention Response Morgan, NRC/OGC

3.1 as admitted by the Licensing Board Lewis &

Bockius, LLP

4 Page(s)

03/16/2005 ML050810517 2005/03/16-Seismic Risk (Performance Letter Exelon NRC/Docu 05200007 Goal) Based Approach Calculation re: Nuclear ment

Early Site Permit Application for Clinton Control

Site. Desk

11 Page(s)

03/17/2005 ML050870594 2005/03/17-Exelon's Motion for Legal- Exelon NRC/ASLB 05200007 Summary Disposition of Contention 3.1 Motion Generation P

Co, LLC, 180 Page(s) Morgan,

Lewis &

Bockius, LLP

03/18/2005 ML050800214 2005/03/18-E-mail from Eddie R. Grant E-Mail Exelon NRC/NRR/ 05200007

to John Segal regarding March 16 Generation DRIP/RNR

submittal. Co, LLC P

13 Page(s)

B-57
Document Accession Title/Description Document Author Addressee Docket

Date Number Includes Est. Page Count Type Affiliation(s) Affiliation(s) Number

03/21/2005 ML050890143 2005/03/21-Letter from Steven P. Legal- Exelon NRC/ASLB 05200007

Frantz to Members of the Licensing Correspond Generation P

Board regarding Certification for Motion ence Co, LLC,

for Summary Disposition Morgan,

Lewis &

4 Page(s) Bockius, LLP

03/29/2005 ML051010274 2005/03/29-Two E-Mails to Bill Maher E-Mail, NRC/NRR Exelon 05200007

for the public hearing record for the Environmen Corp

Exelon ESP site. tal Impact

Statement

4 Page(s)

03/31/2005 ML050920004 2005/03/3-Notice of Change of Federal NRC/NRR/D Exelon 05200007

Location for Public Meeting on the Draft Register RIP/RLEP Generation

Environmental Impact Statement Notice, Co, LLC

(DEIS) for an Early Site Permit (ESP) at Letter,

the Exelon ESP Site (TAC No. Meeting

MC1 125). Notice

11 Page(s)

04/04/2005 ML051020249 2005/04/04-Partial Response to Draft Letter Exelon NRC/Docu 05200007

Safety Evaluation Report (DSER) Nuclear ment

Items. Control

Desk

63 Page(s)

B-58
Document Accession Title/Description Document Author Addressee | Docket Date Number Includes Est. Page Count Type Affiliation(s) Affillation(s) Number

04!OE/°9005 MILA51010A25 g -- i; f5- from cuEuie R. Grant E-Mail, Exelon NRC/NRR/ 05200007

to John Segala regarding April 4 Letter Generation DRIP/RNR

submittal. Co, LLC P

. 65 Page(s) I I

04/07/2005 1 ML051080047 2005/04/07-Letter from Paul M.

Bessette to Shannon Fisk and Mauri T.

Lemoncelli providing an update to

disclosures with respect to Contention

3.1 as admitted by the Licensing Board

LegalInterrogatori

es and

Response

Exelon

Generation

Co, LLC,

Morgan,

Lewis &

Bockius, LLP

Environme

ntal Law &

Policy Ctr,

NRC/OGC

05200007

4 Page(s)

04/08/2005 ML050980379 2004/04/08-Notice of Change of Federal NRC/NRR/D Exelon 05200007

Location for Public Meeting on the Draft Register RIP Generation

Environmental Impact Statement Notice, Co, LLC

(DEIS) for an Early Site Permit (ESP) at Letter

the Exelon ESP Site (TAC No.

MC1125).

10 Page(s)

ML051150509 2005/04/19-E-mail from Eddie R. Grant E-Mail Exelon NRC/NRR/ 05200007

to John Segala Regarding Exelon ESP Generation DRIP/RNR

DSER Hydrology Discussion Items. Co, LLC P

._ 5 Page(s)

04/19/2005 I

B-59
Document Accession Title/Description Document Author Addressee Docket Date Number Includes Est. Page Count Type Affiliation(s) Affiliation(s) Number

04/22/2005 ML051190409 2005/06/22-Intervenors' Motion to Legal- Blue Ridge NRC/ASLB 05200007

Amend Contention 3.1 Motion Environment P

al Defense

78 Page(s) League,

Environment

al Law &

Policy Ctr,

Exelon

Generation

Co, LLC,

Harmon,

Curran,

Spielberg &

Eisenberg,

LLP, Nuclear

Energy

Information

Service,

Nuclear

Information

& Resource

Service

(NIRS),

Public

Citizen, Inc

B-60
Document Accession Title/Description Document Author | Addressee | Docket Date Number Includes Est. Page Count Type Affillation(s) Affiliation(s) Number

04/25/2005 ML05124031A 20051041U25i-Lettei irum Paui M. Legal- Exelon Environme 05200007

Bessette to Shannon Fisk and Mauri T. Interrogatori Generation ntal Law & Lemoncelli providing an update to es and Co, LLC, Policy Ctr, disclosures with respect to Contention Response Morgan, NRC/OGC

3.1 as admitted by the Licensing Board Lewis &

Bockius, LLP

4 Page(s) _

04/26/2005 ML051170014 2005/04/26-E-mail from Eddie R. Grant E-Mail Exelon NRC/NRR/ 05200007

to John Segala Regarding Exelon ESP Generation DRIP/RNR

DSER 01 Response. Co, LLC P

82 Page(s)

04/26/2005 1 ML051230326 2005/04/25-Response to Draft Safety

Evaluation Report (DSER) Regarding

the Early Site Permit (ESP) Application

for the Clinton ESP Site.

Letter Exelon

Nuclear

NRC/Docu

ment

Control

Desk

05200007

79 Page(s) I - I I I _____________

B-61
Document Accession Title/Descriptlon Document Author Addressee Docket

Date Number Includes Est. Page Count Type Affiliation(s) Affiliatlon(s) Number

05/05/2005 ML051320313 2005/05/05-Sixth Additional Disclosures Legal- Environment NRC/ASLB 05200007

of Intervenors Environmental Law and Intervention al Law & P

Policy Center, Blue Ridge Petition, Policy Ctr,

Environmental Defense League, Responses Exelon

Nuclear Information and Resource and Generation

Service, Nuclear Energy Information Contentions Co, LLC,

Service, and Public Citizen Harmon,

Curran,

7 Page(s) Spielberg &

Eisenberg,

LLP, Nuclear

Energy

Information

Service,

Nuclear

Information

& Resource

Service

(NIRS),

Public

._ . Citizen, Inc

05/06/2005 1 ML051320285 2005/05/06-Exelon's Answer to

Intervenors' Motion to Amend

Contention 3.1

LegalMotionExelon

Generation

Co, LLC,

Morgan,

Lewis &

Bockius, LLP

NRC/ASLB

P

05200007

52 Page(s)

I I _________ A. A. I

B-62
Document Accession Title/Description Document Author Addressee Docket Date Number Includes Est. Page Count Type Affiliation(s) Affiliation(s) Number

05/06/2005 ML-0M1ilponn In05/n5 ! !0r-na from EddiC R. rant----- Exen-NRC 052 07

to John Segala Regarding May 6 Letter Letter Generation

on NRC Fee Payment. Co, LLC

4 Page(s)

05/11/2005 ML051390202 2005/05/1 1-Letter from Paul M. Legal- Exelon Environme 05200007

Bessette to Shannon Fisk and Mauri T. Interrogatori Generation ntal Law &

Lemoncelli providing an update to es and Co, LLC, Policy Ctr, disclosures pursuant to 10 CFR § Response Morgan, NRC/OGC

2.336(d) (Supplement 8) Lewis &

Bockius, LLP

4 Page(s)

05/17/2005 ML051430338 2005/05/17-Exelon Brief in Response to Legal-Brief Exelon NRC/OCM 05200007

Commission Memorandum and Order Generation

(CLI-05-09) CoLLC,

Morgan, 28 Page(s) Lewis &

Bockius, LLP

05/24/2005 ML051540317 2005/05/24-Comment (32) of Marilyn C. General FR Exelon NRC/ADM/ 05200007

Kray on behalf of Exelon Nuclear on Notice Nuclear DAS/RDB

Review of Draft Environmental Impact Comment

Statement for Clinton ESP Site. Letter

46 Page(s)

B-63
Document Accession Title/Description Document Author Addressee Docket

Date Number Includes Est. Page Count Type Affiliation(s) Affiliation(s) Number

06/03/2005 ML051640439 2005/06/03-Early Site Permit (ESP) Environmen Exelon NRC/Docu 05200007

Application for the Clinton ESP Site, tal Report Nuclear ment

Submittal of Revision 1 to Exelon Control

Generation Company's Early Site Desk

Permit, Environmental Report, Figure

2.3-14 - Figure 2.3-25..

12 Page(s)

06/03/2005 ML051640440 2005/06/03-Early Site Permit (ESP) Environmen Exelon NRC/Docu 05200007

Application for the Clinton ESP Site, tal Report Nuclear ment . Submittal of Revision 1 to Exelon Control

Generation Company's Early Site Desk

Permit, Environmental Report, Figure

2.4-1 - Figure 2.5-9.

12 Page(s)

06/03/2005 ML051640436 2005/06/03-Early Site Permit (ESP) Environmen Exelon NRC/Docu 05200007

Application for the Clinton ESP Site, tal Report Nuclear ment

Submittal of Revision 1 to Exelon Control

Generation Company's Early Site Desk

Permit, Environmental Report, Figure

2.3-7 - Figure 2.3-12.

6 Page(s)

B-64
Document Accession Title/Description Document | Author | Addressee | Docket Date Number Includes Est. Page Count Type Affillation(s) Affiliatlon(s) Number

06/03/2005n MlO -51640428 2005/06,C3-TransrnIttai of Eafiy Suie Legal- Exelon NRC/Docu 05200007 Permit (ESP) Application for the Clinton Affidavit, Nuclear ment ESP Site, Submittal of Revision 1 to Letter Control Exelon Generation Company's Early Desk Site Permit, Environmental Report, Cover Letter.

3 Page(s)

06/03/2005 ML051640438 2005/06/03-Early Site Permit (ESP) Environmen Exelon NRC/Docu 05200007 Application for the Clinton ESP Site, tai Report Nuclear ment Submittal of Revision 1 to Exelon Control Generation Company's Early Site Desk

Permit, Environmental Report, Figure 2.3-13.

1 Page(s) -

06/03/2005 ML051640441 2005/06/03-Early Site Permit (ESP) Application for the Clinton ESP Site,

Submittal of Revision 1 to Exelon

Generation Company's Early Site

Permit, Environmental Report, Figure

2.7-1 - Figure 2.7-18.

Environmen

tal Report

Exelon

Nuclear

NRC/Docu

ment

Control

Desk

05200007

18 Page(s) - .. .L ______________ .1.

B-65
Document Accession Title/Description Document Author Addressee Docket

Date Number Includes Est. Page Count Type Affiliation(s) Affiliation(s) Number

06/03/2005 ML051640448 2005/06/03-Early Site Permit (ESP) Environmen Exelon NRC/Docu 05200007

Application for the Clinton ESP Site, tal Report Nuclear ment

Submittal of Revision 1 to Exelon Control

Generation Company's Early Site Desk

Permit, Environmental Report,

Environmental Consequences of the

Proposed Action - Table B-1.

60 Page(s)

06/03/2005 ML051640446 2005/06/03-Early Site Permit (ESP) Environmen Exelon NRC/Docu 05200007

Application for the Clinton ESP Site, tal Report Nuclear ment

Submittal of Revision 1 to Exelon Control

Generation Company's Early Site Desk

Permit, Environmental Report,

Environmental Measurement and

Monitoring Programs - Figure 9.2-4.

212 Page(s)

06/03/2005 ML051640444 2005/06/03-Early Site Permit (ESP) Environmen Exelon NRC/Docu 05200007

Application for the Clinton ESP Site, tal Report Nuclear ment

Submittal of Revision 1 to Exelon Control

Generation Company's Early Site Desk

Permit, Environmental Report,

Environmental Impacts of Station

Operation - Figure 5.3-2.

._ 127 Page(s)

B-66
Document Accession Title/Description Document Author Addressee Docket Date Number Includes Est. Page Count Type Affiliation(s) Affillation(s) Number

06/03/2005 ML051640434 20!/06/023-nar!!y Site P.rmit l. /P. .. Exe_^n II mlvi.^nrnen I

Application for the Clinton ESP Site, tal Report Nuclear ment

Submittal of Revision 1 to Exelon Control

Generation Company's Early Site Desk

Permit, Environmental Report, Figure

2.2-6 - Figure 2.3-6.

9 Page(s)

06/03/2005 ML051640431 2005/06/03-Early Site Permit (ESP) Environmen Exelon NRC/Docu 05200007

Application for the Clinton ESP Site, tal Report Nuclear ment Submittal of Revision 1 to Exelon Control . Generation Company's Early Site Desk

Permit, Environmental Report,

Contents - Figure 2.2-5.

245 Page(s)

06/03/2005 ML051640442 2005/06/03-Early Site Permit (ESP) Environmen Exelon NRC/Docu 05200007

Application for the Clinton ESP Site, tal Report Nuclear ment

Submittal of Revision 1 to Exelon Control

Generation Company's Early Site Desk

Permit, Environmental Report, Plant

Description - Figure 4.5-1.

120 Page(s)

B-67
Document Accession Title/Description Document Author Addressee Docket Date Number Includes Est. Page Count Type Affillation(s) Afflilatlon(s) Number

06/30/2005 ML051920121 2005/06/30-Submission of Reviewers Legal- Exelon NRC/Docu 05200007

Aid for Revision 1 to Exelon Generation Affidavit, Nuclear ment

Company's Early Site Permit, Letter Control

Environmental Report. Desk

3 Page(s)

06/30/2005 ML051920127 2005/06/30-Reviewers Aid for Revision Environmen Exelon NRC/Docu 05200007

1 to Exelon Generation Company's tal Report Nuclear ment

Early Site Permit, Environmental Control

Report. Desk

95 Page(s)

07/14/2005 ML051960277 2005/07/14-E-Mail re: Revised DSER E-Mail, Exelon Corp NRC/NRR/ 05200007

Response. Legal- DRIP/RNR

Affidavit, P

64 Page(s) Letter

07/14/2005 ML052150136 Revised Response to Draft Safety Letter Exelon NRC/Docu 05200007

Evaluation Report (DSER) Items re: Nuclear ment

Letter, U.S. NRC (W. D. Beckner) to Control

Exelon Generation Company, LLC, (M. Desk

Kray), dated February 10, 2005, Draft

Safety Evaluation Report for the Exelon

ESP Application.

. _ 62 Page(s)

B-68
Document Accession Title/Description Document Author Addressee Docket

Date Number Includes Est. Page Count Type Affiliation(s) Affiliation(s) Number

07/18/2005 ML0519301.5r Clinton nQulitiy4 ESP Ae-..ur.ace LeiierRCiNR-iD Exelon 05200007

Assessment and Resolution of RIP/RNRP Generation

Confirmatory Item (CI) and Open Item Co, LLC

(01) 17.1-1.

8 Page(s)

08/03/2005 ML052210410 2005/08/03-Letter from Paul M.

Bessette to Shannon Fisk and Mauri T.

Lemoncelli enclosing updates to

disclosures with respect to Contention

3.1 (Supplement 9)

LegalInterrogatori

es and

Response

Exelon

Generation

Co, LLC,

Morgan,

Lewis &

Bockius, LLP

Environme

ntal Law &

Policy Ctr,

NRC/OGC

05200007

35 Page(s) . _

B-69
Document Accession Title/Description Document Author Addressee Docket

Date Number Includes Est. Page Count Type Affiliation(s) Afflilation(s) Number

08/12/2005 ML052360416 2005/08/12-Intervenors' Petition for

Review of the Atomic Safety and

Licensing Board's Dismissal of

Contention 3.1 and Rejection of

Intervenors' Proposed Amended

Contention 3.1

23 Page(s)

Legal-Brief Blue Ridge

Environment

al Defense

League,

Exelon

Generation

Co, LLC,

Harmon,

Curran,

Spielberg &

Eisenberg,

LLP, Nuclear

Energy

Information

Service,

Nuclear

Information

& Resource

Service

(NIRS)

NRC/OCM 05200007

4. 4

08/16/2005 ML051540054 Revised Schedule for Review of the

Exelon Early Site Permit Application for

the Exelon ESP Site.

10 Page(s)

NRC/NRR/D Exelon 05200007

RIP/RNRP Generation

Co, LLC

B-70
Document Accession Title/Description Document Author | Addressee 1 Docket Date Number Includes Est. Page Count Type Affiliation(s) Affiliation(s) Number

08/19/2005 Ml n509qnnia t,, ms Op-n fur I. e /NR HR/D Exelon 05200007 Supplemental Draft Safety Evaluation RIP/RNRP Generation

Report for the Exelon ESP Application. Co, LLC

14 Page(s)

08/22/2005 ML052410437 2005/08/22-Exelon Generation Legal-Brief Exelon NRC/OCM 05200007 Company's Answer in Opposition to Generation

Intervenors' Petition for Review Co, LLC,

Morgan, 30 Page(s) Lewis &

Bockius, LLP

08/26/2005 ML052310469 Cover Letter to M. Kray re: Draft Safety NRC/NRR/D Exelon 05200007 Supplemental Draft Safety Evaluation Evaluation RIP/RNRP Generation

Report for the Exelon Early Site Permit Report Co, LLC

Application. (DSER),

Letter

4 Page(s)

08/31/2005 ML052310478 Supplemental Draft Safety Evaluation Draft Safety NRC/NRR/D Exelon 05200007 Report for the Exelon Early Site Permit Evaluation RIP/RNRP Generation

Application. Report Co, LLC

(DSER)

125 Page(s)

B-71
Document Accession Title/Description Document Author Addressee Docket Date Number Includes Est. Page Count Type Affillation(s) Affiliation(s) Number

09/07/2005 ML052590007 2005/09/07-Letter from Paul M. Legal- Exelon Environme 05200007 Bessette to Shannon Fisk and Mauri T. Interrogatori Generation ntal Law &

Lemoncelli providing updates to es and Co, LLC, Policy Ctr, disclosures with respect to Contention Response Morgan, NRC/OGC

3.1 (Supplement 10) Lewis &

Bockius, LLP

4 Page(s)

09/30/2005 ML052860134 Early Site Permit (ESP) Application for Letter Exelon NRC/Docu 05200007

the Clinton ESP Site - Revised Nuclear ment

Response to Draft Safety Evaluation Control

Report (DSER) Items. Desk

6 Page(s)

l10/11/2005 1 ML052860325 10/11/05 - Request for Additional

Information (RAI) Regarding the

Environmental Portion of the Early Site

Permit Application for the Exelon

Generation Company Site (TAC No.

MC1 125).

Letter,

Request for

Additional

Information

(RAI)

NRC/NRR/D

RIP/RLEP

Exelon.

Generation

Co, LLC

05200007

8 Page(s) _____________ j J ___________ I ____________ I

B-72
Document Accession Title/Description Document Author Addressee Docket Date Number Includes Est. Page Count Type Affillation(s) Affiliation(s) Number

W1/11/2005 ML05286027A 101t1/05 - Summ-ary oi Telephone Meeting NRC/NRR/D Exelon 05200007 Conference Call Held on September Summary, RIP/RLEP Generation

19, 2005 Between the U.S. Nuclear Note to File Co, LLC Regulatory Commission (NRC) and the incl Telcon

Illinois Department of Natural Record,

Resources (IDNR) Regarding the Verbal

Review of the Exelon Early Site Permit Comm

(ESP).

6 Page(s)

10/11/2005 ML052860253 10/11/05 - Summary of Telephone Note NRC/NRR/D Exelon 05200007 Conference Call Held on September RIP/RLEP Generation

13, 2005 Between the U.S. Nuclear Co, LLC Regulatory Commission (NRC) and the

Illinois Environmental Protection

Agency (EPA) Regarding the Review of

the Exelon Early Site Permit (ESP).

6 Page(s)

10/12/2005 1 ML052930270 Early Site Permit Application for the

Clinton ESP Site, ESP Site Soil Hazard

Data.

Letter Exelon

Nuclear

NRC/Docu

ment

Control

Desk

05200007

6 Page(s) J. - .1 1 _________ J

.

B-73
Document Accession Title/Description Document Author Addressee Docket Date Number Includes Est. Page Count Type Affiliation(s) Affliation(s) Number

10/27/2005 ML053070508 Early Site Permit (ESP) Application for Letter Exelon NRC/Docu 05200007

the Clinton ESP Site, Revised Nuclear ment

Response to Request for Additional Control

Information Letter No. 12. Desk

10 Page(s)

10/31/2005 ML053120131 Clinton ESP Site, Responses to Graphics Exelon NRC/Docu 05200007

Supplemental Draft Safety Evaluation incl Charts Nuclear ment

Report (DSER) Items. and Tables, Control

Letter, Map Desk

285 Page(s)

11/23/2005 ML053420057 Submittal of Revision 1 to Exelon Letter Exelon NRC/Docu 05200007

Generation Company's Early Site Generation ment

Permit Application. Co, LLC Control

Desk

4 Page(s)

12/13/2005 ML053540218 Response to Request for Additional Legal- Exelon NRC/Docu 05200007

Information (RAI) - Exelon Early Site Affidavit, Nuclear ment

Permit (ESP) Application for the Clinton Letter Control

ESP Site. Desk

4 Page(s)

12/21/2005 ML060030484 Early Site Permit Application for the Letter Exelon NRC/Docu 05200007

Clinton ESP Site, Revised Response to Nuclear ment

Draft Safety Evaluation Report Open Control

Items. Desk

13 Page(s)

B-74
Document Accession Title/Description Document Author | Addressee | Docket Date Number Includes Est. Page Count Type 1 Affiliation(s) Affiliation(s) Number

06/27/2002 M[OL-2--lO-- I'0I'°7-E-m.il -I - cor E bn Site E-Mai_ Exelon Corp NRC 05200007 Activities.

2 Page(s) l

07/08/2002 ML042280020 2002/07/08-E-mail - RE: Exelon ESP E-Mail Exelon Corp NRC 05200007, Site Activities. PROJO71 8

2 Page(s) ___ _

07/12/2002 ML042280021 2002/07/12- E-mail - Exelon ESP E-Mail Exelon Corp NRC 05200007, seismic activities. PROJO718

2 Page(s)

07/25/2002 ML042280022 2002/07/25-E-mail - RE: NRC-Exelon E-Mail Exelon Corp NRC 05200007, seismic field work telecon at 2 EDT. PROJO718

2 Page(s)

07/31/2002 ML042280023 2002/07/31-E-mail - ESP Schedule of E-Mail Exelon Corp NRC 05200007, Seismic & Geotechnical Activities. PROJO71 8

3 Page(s)

05/16/2003 ML042300743 2003/05/16-E-mail - Clinton Community E-Mail NRC Exelon 05200007, Advisory Panel. Corp PROJO718

__ 2 Page(s)

B-75
Document Accession Title/Description Document Author Addressee Docket

Date Number Includes Est. Page Count Type Affiliation(s) Affiliation(s) Number

05/29/2003 ML042300745 2003/05/29-E-mail - CD needed for E-Mail NRC Exelon 05200007,

Web Posting. Corp PROJO718

4 Page(s)

06/10/2003 ML042280025 2003/06/10-E-mail Re :Question on E-Mail Exelon Corp NRC 05200007,

Security Info. PROJ0718

2 Page(s)

06/10/2003 ML042300768 2003/06/10-E-mail - Application TOC. E-Mail NRC Exelon 05200007,

Corp PROJO718

1 Page(s)

06/10/2003 ML042300771 2003/06/10-E-mail - Question on E-Mail NRC Exelon 05200007,

Security Info. Corp PROJO71 8

1 Page(s) .

06/11/2003 ML042300774 2003/06/11-E-mail - Requirements on E-Mail NRC Exelon 05200007,

Number of Copies. Corp PROJO718

2 Page(s)

06/11/2003 ML042300772 2003/06/11 -E-mail - RE: Application E-Mail NRC Exelon 05200007,

TOC. Corp PROJO718

2 Page(s)

06/12/2003 ML042300775 2003/06/12-E-mail - Word File. E-Mail NRC Exelon 05200007,

Corp PROJO718

2 Page(s)

B-76
Document Accession Title/Description Document Author Addressee Docket

06/ 

Date Number Includes Est. Page Count Type Affillation(s) Affillation(s) Number / I0 MlnAq. _7 'Al~~tIc- .-. a -1 r.*IA.---' -s OB/1v2vl20n3 91°nE,., Mn778 u rIt:. -faii NRC Exelon 05200007,

Corp PROJO718

2 Page(s)

06/13/2003 ML042300779 2003/06/13-E-mail - RE: Word File. E-Mail NRC Exelon 05200007,

Corp PROJ071 8 3 Page(s)

07/02/2003 ML042300780 2003/07/02-E-mail - RE: Application E-Mail NRC Exelon 05200007, TOC. Corp PROJO718

3 Page(s)

07/07/2003 ML042300827 2003/07/07-E-mail - Information on E-Mail NRC Exelon 05200007, Clinton Lake. Corp PROJO718

2 Page(s)

07/14/2003 ML042300782 2003/07/14 - E-mail - Call on Seismic E-Mail NRC Exelon 05200007, Issues. Corp PROJO71 8

1 Page(s)

07/14/2003 ML042300784 2003/07/14-E-mail - RE: Call on E-Mail NRC Exelon 05200007, Seismic Issues. Corp PROJO718

2 Page(s)

08/11/2003 ML042300787 2003/08/11-E-mail - QA Meeting. E-Mail NRC Exelon 05200007,

Corp PROJO718

_2 Page(s)

B-77
Document Accession Title/Description Document Author Addressee Docket

Date Number Includes Est. Page Count Type Affillation(s) Affillation(s) Number

08/26/2003 ML042300788 2003/08/26-E-mail - QA Meeting. E-Mail NRC Exelon 05200007,

Corp PROJ0718

1 Page(s)

08/29/2003 ML042300791 2003/08/29-E-mail - Discussion After E-Mail NRC Exelon 05200007,

Entergy QA Meeting. Corp PRO0j718

1 Page(s)

08/29/2003 ML042280026 2003/08/29-E-mail - RE: Application E-Mail Exelon Corp NRC 05200007,

TOC. PROJ0718

3 Page(s)

08/29/2003 ML042300792 2003/08/29-E-mail - RE: Application E-Mail NRC Exelon 05200007,

TOC. Corp PROJO71 8

3 Page(s) :

09/02/2003 ML042300793 2003/09/02-E-mail - RE: Application E-Mail NRC Exelon 05200007,

TOC. Corp PROJO718

4 Page(s)

09/09/2003 ML042300825 2003/09/09-E-mail - Re: ESP Letter. E-Mail NRC Exelon 05200007,

Corp PROJO718

2 Page(s)

09/11/2003 ML042300795 2003/09/11-E-mail - Re: Yesterday's E-Mail NRC Exelon 05200007,

Mtg. Corp PROJO718

2 Page(s)

B-78
Document Accession Title/Description | Document Author Addressee | Docket Date Number Includes Est. Page Count Type Affillation(s) Affiliation(s) Number

09/12/200,13 Ml nMI 430n796 qnn3,iAO2E maiI - QA In-peo:-n -nRC E-,v', Exeion U52bvU0, Dates. Corp PROJO718

2 Page(s)

09/25/2003 ML032721594 2003/09/25-Submittal of Exelon Letter, Exelon NRC/Docu 05000461, Generation Company (EGC) application License- Generation ment 05200007, for an early site permit (ESP) for Application Co, LLC, Control PROJO718 property co-located with existing Clinton for Exelon Desk Power Station (CPS) facility in Illinois. Constructio Nuclear

n Permit

3 Page(s) DKT 50 .

09/30/2003 ML042300799 2003/09/30-E-mail - Hard Copies. E-Mail NRC Exelon 05200007,

Corp PROJO718 2 Page(s)

10/01/2003 ML042300815 2003/10/01 -E-mail - Picture. E-Mail, NRC Exelon 05200007

Photograph Corp 2 Page(s)

10/01/2003 ML042300800 2003/10/01 -E-mail - Clinton USAR E-Mail NRC Exelon 05200007, Update. Corp PROJO718

1 Page(s) _

10/01/2003 ML042300801 2003/10/01-E-mail - Service List E-Mail NRC Exelon 05200007

Generation _ 2 Page(s) Co, LLC

B-79
Document Accession Title/Description Document Author Addressee Docket

Date Number Includes Est. Page Count Type Affillation(s) Affiliation(s) Number

10/02/2003 ML042310348 2003/10/02-E-mail - RE: Hard Copies. E-Mail NRC Exelon 05200007,

Corp PROJ0718

3 Page(s)

10/02/2003 ML042310323 2003/10/02-E-mail - RE: Service List. E-Mail, NRC Exelon 05200007

Letter Generation

3 Page(s) Co, LLC

10/03/2003 ML042310342 2003/10/03-E-mail - RE: Hard Copies. E-Mail NRC Exelon 05200007,

Corp PROJO718

3 Page(s)

10/03/2003 ML042310333 2003/10/03-E-mail - Re: Hard Copies. E-Mail NRC Exelon 05200007,

Corp PROJO718

3 Page(s)

10/03/2003 ML042310360 2003/10/03-E-mail - RE: Hard Copies. E-Mail NRC Exelon 05200007

Corp

3 Page(s)

10/08/2003 ML042440536 2003/10/08-E-mail - RE: Schedule. E-Mail, NRC Exelon 05200007

Letter Generation

3 Page(s) Co, LLC

10/16/2003 ML042300811 2003/10/16-E-mail - Answer to E-Mail NRC Exelon 05200007, Question on ESP Record Retention. Generation PROJO71 8

Co, LLC

_2 Page(s)

B-80
Document Accession Title/Description Document Author Addressee Docket Date -- Number Includes Est. Page Count Type Affiliation(s) Affiliation(s) Number

10/27/2003 ML032930051 2nnq/1 Ol /7-L.tt.r t MK. A tera i'jI 'NRRID txeion 0520uuu7

Acceptance of Application for ESP for RIP Generation

Property Co-Located With The Existing Co, LLC

Clinton Power Station.

6 Page(s)

10/27/2003 ML032930059 2003/10/27-Exelon ESP Review Spreadshee NRC/NRR/D Exelon 05200007 Schedule. t File RIP Generation

Co, LLC

1 Page(s)

11/19/2003 ML033250261 2003/11/19-Notice Of Intent To Prepare Federal NRC/NRR/D Exelon 05200007

An Environmental Impact Statement Register RIP Generation

And Conduct Scoping Process For An Notice, Co, LLC

Early Site Permit (ESP) At The Clinton Letter

ESP Site (TAC NO. MC1 125).

13 Page(s)

11/21/2003 ML042300813 2003/11/21 -E-mail - Request for E-Mail, NRC/NRR/D Exelon 05200007

Additional Information-QA. Letter, RIP/RNRP Corp

Request for

11 Page(s) Additional

Information

(RAI)

11/21/2003 ML042300824 2003/11/21-E-mail - Attorneys. E-Mail NRC Exelon 05200007

Corp __ 2 Page(s)

B-81
Document Accession Title/Description Document Author Addressee Docket

Date Number Includes Est. Page Count Type Affillation(s) Affillation(s) Number

11/21/2003 ML033210018 2003/11/21 -Request For Additional Letter, NRC/NRR/D Exelon 05000461, Information Letter No. 1 - Exelon ESP Request for RIP Generation 05200007

Application for the Clinton ESP Site on Additional Co, LLC

QA Measures (MC1 122). Information

(RAI)

7 Page(s)

12/09/2003 ML033510146 2003/12/09-Service of Notice of Letter Exelon NRC/Docu 05200007

Availability of an Application for an Nuclear ment

Early Site Permit. Control

Desk,

3 Page(s) NRC/NRR

12/10/2003 ML042280027 2003/12/10-E-mail, Administrative E-Mail Exelon NRC 05200007

items. Generation

Co, LLC

2 Page(s)

12/10/2003 ML042280028 2003/12/10-E-mail - Administrative E-Mail Exelon Corp NRC 05200007

questions.

2 Page(s)

12/11/2003 ML042440541 2003/12/11 -E-mail - Re: Administrative E-Mail, NRC Exelon 05200007

questions. Letter Generation

Co, LLC

3 Page(s)

B-82
Document Accession Title/Description Document | Author Addressee Docket Date Number Includes Est. Page Count Type Affiliation(s) Affiliation(s) Number 12/22/200.3 ML 033RA0639 r003nn/122-flpun i RAi -o Lejier No. Lener Exelon NRC/Docu 05000461,

1 Regarding Quality Assurance Nuclear ment 05200007

Measures, per Early Site Permit Control

Application for the Clinton Site. Desk

1 Page(s) 204/1/6E-ai R: dmnstatv

01/06/2004 1 ML042440548 2004101/06-E-mail - Re: Administrative

questions.

2 Page(s)

E-Mail,

Letter

NRC Exelon

Corp

05200007

J. £. A. I

I 01/21/2004 1 ML040430135 2004/01/21-SUMMARY OF PUBLIC

MEETING TO DISCUSS THE

ENVIRONMENTAL SCOPING

PROCESS FOR THE CLINTON

EARLY SITE PERMIT (ESP)

APPLICATION

Meeting

Agenda,

Meeting

Summary,

Transcript

NRC/NRR/D

RIP/RLEP

Exelon

Generation

Co, LLC

05200007

143 Page(s)

01/24/2004 ML050280252 2004/01/24-Response to Request for Letter Exelon NRC/Docu 05200007

Additional Information Letter No. 12 re Generation ment

Application for Clinton ESP Site. Co, LLC, Control

Exelon Desk

82 Page(s) _ Nuclear

B-83
Document Accession Title/Description Document Author Addressee Docket

Date Number Includes Est. Page Count Type Affiliation(s) Affillation(s) Number

02/13/2004 ML041830102 2004/02/13-Staff E-mail to Exelon E-Mail NRC/NRR/D Exelon 05200007

Forwarding the Proposed Agenda for RIP/RLEP Corp Alternative Site Visits for the EGC ESP

Review.

4 Page(s)__ _ _ _ _ __ _ _ _ _

02/18/2004 ML041830095 2004/02/18-Staff E-mail to Exelon E-Mail NRC/NRR/D Exelon 05200007

Forwarding Agenda Items for the EGC RIP/RLEP Corp ESP Site Audit.

13 Page(s)

02/20/2004 ML040540622 2004/02/20-IR 0520007-04-001, on Inspection NRC/RGN- Exelon 05200007

01/12/04 through 01/16/04, for Exelon Report, III/DRS Generation

Generation Company, Kennett Square, Letter Co, LLC

PA; (Clinton) Early Site Permit.

48 Page(s)

02/23/2004 ML042300818 2004/02/23-E-mail - Requests for Letter, NRC Exelon 05200007

Additional Information. Request for Corp

Additional

4 Page(s) Information

(RAI)

02/24/2004 I ML041820385 2004/02/24-Staff E-mail to Exelon

Forwarding an Additional Question for

the EGC ESP Site Audit re Spent Fuel

Storage.

E-Mail NRC/NRR/D

RIP/RLEP

Exelon

Corp

05200007

1 Page(s) I - - I .5. .5.

B-84
Document Accession Title/Description Document Author Addressee Docket Date Number Includes Est. Page Count Type Affillation(s) Affiliation(s) Number

02/2.5/2004 ML041 830104 2004/0o"25-Staff E-mai tO CExelor, E-Maii NRCiNRR/D Exelon 05200007

Forwarding Additional Agenda Items for RIP/RLEP Corp the EGC ESP Site Audit.

3 Page(s)

02/26/2004 ML041830124 2004/02/26-Staff E-mail to Exelon E-Mail NRC/NRR/D Exelon 05200007

Regarding Discussion Items on Worker RIP/RLEP Corp Dose for the EGC ESP Site Audit.

3 Page(s)

03/05/2004 ML042300803 2004/03/05-E-mail - Seismic Call- E-Mail NRC Exelon 05200007, REVISION. Corp PROJO718

1 Page(s)

03/08/2004 ML042440552 2004/03/08-E-mail - RE: Seismic Call- E-Mail, NRC Exelon 05200007

REVISION. Letter Generation

Co, LLC

2 Page(s)

03/11/2004 1 ML042280029 2004/03/11-E-mail forwarding Amy Lientz Corrected Address, (Privacy

Info).

E-Mail Exelon

Generation

Co, LLC

NRC/NRR 05200007

3 Page(s) I - J _____________ I ______________ I I

B-85
Document Accession Title/Description Document Author Addressee Docket

Date Number Includes Est. Page Count Type Affiliation(s) Affillation(s) Number

03/15/2004 ML040820570 2004/03/15-Enclosure 2: Exelon Technical Exelon NRC/NRR/ 05200007

Generation Company, LLC Early Site Paper Generation DRIP/RLEP

Permit Application of Alternative Site Co, LLC

Comparison Process and Attachment

1: Alternative Site Comparison

Process.

22 Page(s)

03/17/2004 ML040790804 2004/03/17-Clinton Power Station Early Letter Exelon NRC/Docu 05000461,

Site Permit - Response to Verbal Generation ment 05200007

Request for Documentation. Co, LLC, Control

Exelon Desk

2 Page(s) Nuclear

03/17/2004 ML042280030 2004/03/17-E-mail - Clinton ETE. E-Mail Exelon Corp NRC 05200007

2 Page(s) I I I

03/19/2004 ML040900247 2004/03/19-Motion for Leave to File

Notice of Appearance Out of Time

LegalMotion

3 Page(s)

Exelon

Generation

Co, LLC,

Harmon,

Curran,

Spielberg &

Eisenberg,

LLP

NRC/ASLB

P

05200007

J J. J I

B-86
Document Accession Title/Description Document Author [Addressee | Docket Date Number Includes Est. Page Count Type Affiliation(s) Affillation(s) Number

03/19/2004 ML040900251 200413/19 .Mntce of AppCarance by Legal- Exeion NRC/ASLB 05200007 Diane Curran on behalf of Blue Ridge Notice of Generation P

Environmental Defense League Appearance Co, LLC,

Harmon, 3 Page(s) Curran,

Spielberg &

Eisenberg,

LLP

03/19/2004 ML042300816 2004/03/19-E-mail - Draft Requests for E-Mail, NRC Exelon 05200007 Additional Information-SSAR 2.5.2. Request for Corp

Additional

3 Page(s) Information

(RAI)

03/30/2004 ML042300805 2004/03/30-E-mail - Seismic Site Visit. E-Mail NRC Exelon 05200007

Corp 1 Page(s) __

04/06/2004 ML040920584 2004/04/06-Letter to M Kray Re Letter NRC/NRR/D Exelon 05200007

Revised Date for Transmitting RIP Generation Environmental RAls for Exelon ESP Co, LLC

Application.

6 Page(s)

04/12/2004 ML042300817 2004/04/12-E-mail - Draft Requests for E-Mail NRC/NRR Exelon 05200007

Additional Information-Emergency Plan. Corp

6 Page(s)

B-87
Document Accession Title/Description Document Author Addressee Docket Date Number Includes Est. Page Count Type Affillation(s) Affillation(s) Number

04/13/2004 ML041110024 2004/04/13-Exelon Submission of Calculation, Exelon NRC/Docu 05200007

Requested Information, PBMR Ltd Letter Generation ment

Calculation MF 00-016344-2053 dated Co, LLC Control

March 6, 2003. Desk

4 Page(s) _

04/14/2004 ML042450111 2004/04/14-E-mail-Re: Chicago E-Mail, NRC Exelon 05200007

Seismic Meeting. Letter Generation

Co, LLC

2 Page(s)

04/15/2004 ML040930400 2004/04/15-RAI No. 2 - Exelon ESP Letter, NRC/NRR/D Exelon 05200007

Application for the Clinton ESP Site on Request for RIP Generation

Site Safety Analysis Report Section Additional Co, LLC

2.3.3 (TAC No. MC1 122). Information

(RAI)

7 Page(s)

04/29/2004 ML0424501 10 2004/04/29-E-mail - Re: May 11-12 site E-Mail, NRC Exelon 05200007

visit. Letter, Trip Corp

Report

2 Page(s)

04/29/2004 ML042280032 2004/04/29-E-mail, RE: May 18-19 E-Mail Exelon NRC 05200007

seismic visit. Generation

Co, LLC

3 Page(s)

B-88
Document Accession Title/Description | Document Author |Addressee Docket Date Number Includes Est. Page Count Type Affillation(s) I AffIllation(s) Number 04/29/2004 _nfAP28qnni IorAflrA 1lA2OEn a R A-1 *.

-May 1-1A ite I-Ma Exelon Corp NRC 05200007

visit.

3 Page(s)

04/30/2004 ML042450101 2004/04/30-E-mail - Re: May 11-12 site E-Mail NRC Exelon 05200007

visit. Corp

3 Page(s)

04/30/2004 ML042450102 2004/04/30-E-mail - RE: May 18-19 E-Mail NRC Exelon 05200007

seismic visit. Corp

3 Page(s)

04/30/2004 ML042450097 2004/04/30-E-mail - RE: RAI No. 2 re E-Mail NRC Exelon 05200007

Met Data. Corp

2 Page(s)

04/30/2004 ML042450104 2004/04/30-E-mail - Re: May 11-12 site E-Mail NRC Exelon 05200007

visit. Corp

3 Page(s)

05/03/2004 ML042450093 2004/05/03-E-mail - Re: May 11-12 site E-Mail NRC Exelon 05200007

visit. Corp

3 Page(s)

B-89
Document Accession Title/Description Document Author Addressee Docket Date Number Includes Est. Page Count Type Affillation(s) Affiliation(s) Number

05/04/2004 ML042450086 2004/05/04-E-mail - RE: Site visit info - E-Mail NRC Exelon 05200007

May 19. Corp

1 Page(s)

05/05/2004 ML042280033 2004/05/05-E-mail - RE: Emergency E-Mail Exelon Corp NRC 05200007

Plan draft RAls - Applicant questions.

3 Page(s) _

05/05/2004 ML042450083 2004/05/05-E-mail - RE: Emergency E-Mail NRC Exelon 05200007

Plan draft RAls. Corp

3 Page(s)

05/05/2004 ML042450081 2004/05/05-E-mail - RE: Emergency E-Mail, NRC Exelon 05200007

Plan draft RAls - Applicant questions. Letter Corp

3 Page(s)

05/06/2004 ML042300807 2004/05/06-E-mail - Hydrology E-Mail NRC Exelon 05200007

Discussion Topics. Generation

Co, LLC _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ 5 P a g e (s) _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _

B-90
Document Accession Title/Description Document Author Addressee Docket Date Number Includes Est. Page Count Type Affiliation(s) Affiliation(s) Number

05/11/2004 MLn041330n8R qnAfliI1 Rq for05/05 ! 1 -------- - . . -,i I%~ r_%AUL%%-% 14ria11%hrV Ex ionUb2UUUUJ/ Information (RAI) Regarding the Request for RIP/RLEP Generation

Environmental Portion of the Early Site Additional Co, LLC

Permit Application for the Exelon Information

Generation Company Site (TAC No. (RAI)

MC1 125).

17 Page(s)

05/12/2004 ML042300520 2004/05/12-E-mail - Fwd: Seismic RAI E-Mail NRC/NRR Exelon 05200007

Topics for Mtg discussion. Corp

3 Page(s)__ _ _ _ _ _ _ _ _ _ _ _

05/14/2004 I ML042450079 2004/05/14-E-mail - RE: NRC Seismic

visit info - May 17-19.

3 Page(s)

E-Mail NRC Exelon

Corp

05200007

I 05/18/2004 1 ML041830135 2004/05/18-Staff E-mail to Exelon

Regarding Clarification Items to Site

Audit Summary for the EGC ESP

Review.

E-Mail NRC/NRR/D

RIP/RLEP

Exelon

Corp

05200007

2 Page(s)

I 05/28/2004 I ML041560144 2004/05/28-Exelon Generation Legal- Exelon NRC/ASLB 05200007

Company's Answer to Proposed Intervention Generation P

Contentions Petition, Co, LLC,

Responses Morgan, 42 Page(s) and Lewis &*

Contentions Bockius, LLP

B-91

. . = . . _ .
Document Accession Title/Description Document Author Addressee Docket

Date Number Includes Est. Page Count Type Affiliation(s) Affillation(s) Number

06/02/2004 ML041620360 2004/06102-Exelon Generation Legal- Exelon NRC/ASLB 05200007

Company's Answer in Opposition to Motion Generation P

Petitioners' Motion for Extension of Co, LLC,

Time to Reply to Response to Morgan,

Contentions Lewis &

Bockius, LLP

7 Page(s)

06/08/2004 ML042300808 2004/06/08-E-mail - Figure 1.2-3. E-Mail NRC Exelon 05200007

Corp

1 Page(s)

06/08/2004 ML042450076 2004/06/08-E-mail Re: SSAR Site E-Mail NRC Exelon 05200007

Hazards Visit. Generation

Co, LLC

3 Page(s)

06/10/2004 ML042450074 2004/06/10-E-mail - RE: Figure 1.2-3. E-Mail NRC Exelon 05200007

Generation

2 Page(s) Co, LLC

06/11/2004 ML042300819 2004/06/11-E-mail - RE: Emergency E-Mail, NRC Exelon 05200007

Plan draft RAls - Applicant questions. Letter Corp

4 Page(s)

06/11/2004 ML042300820 2004/06/11-E-mail - Draft Requests for E-Mail, NRC/NRR Exelon 05200007

Additional Information. Request for Corp

Additional

12 Page(s) Information

(RAI)

B-92
Document Accession Title/Description Document Author Addressee Docket Date Number Includes Est. Page Count Type Affiliation(s) Affiliation(s) Number

06/11/2004 ML0424.rnn72 20040!/ 1-E-mail = RE: SSAR Site c-ivia NRC Exelon 05200007

Hazards Visit. Generation

Co, LLC

4 Page(s)

06/18/2004 ML041830154 2004/06/18-Exelon E-mail Forwarding E-Mail Exelon Corp Battelle 05200007

Files for Lake Modeling PT 1 for the Memorial

EGC ESP Review. Institute,

Pacific

25 Page(s) Northwest

National

Lab, NRC,

NRC/NRR/

DRIP/RLEP

06/20/2004 ML041830159 2004/06/20-Staff E-mail to Exelon E-Mail Battelle Battelle 05200007

Regarding Files for Lake Modeling PT 2 Memorial Memorial

for the EGC ESP Review. Institute, Institute,

Pacific Pacific

2 Page(s) Northwest Northwest

National Lab National

Lab, Exelon

Corp, NRC,

NRC/NRR/

DRIP/RLEP

06/22/2004 ML041400206 2004/06/22-Letter to M. Kray, Exelon Letter NRC/NRR/D Exelon 05200007

re: ESP Template RIP/RNRP Generation

Co, LLC __ 6 Page(s)

B-93
Document Accession Title/Description Document Author Addressee Docket

Date Number Includes Est. Page Count Type Affiliation(s) Affiliation(s) Number

06/23/2004 ML042300809 2004/06/23-E-mail - Question on Draft E-Mail NRC Exelon 05200007

Met RAls. Generation

Co, LLC

2 Page(s)

06/23/2004 ML04230081 0 2004/06/23-E-mail - Response to E-Mail NRC Exelon 05200007

Question on Met RAI. Corp

2 Page(s) _ _

06/23/2004 ML042280003 2004/06/23-E-mail- RE: Response to E-Mail Exelon NRC 05200007

Question on Met RAI. Generation

Co, LLC

2 P a g e tse_ _ _ _ _ __ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _

07/02/2004 ML042180098 2004/07/02-NRC RAI E5.2-3 - Att El,

Clinton Lake Volume - 24 YR Period of

Record Analysis with Single Uprated

Existing Plant (Forced Loss estimated

based on Forced Loss due to two 992

MW Plants).

Graphics

incl Charts

and Tables,

Spreadshee

t File

Exelon

Generation

Co, LLC,

Exelon

Nuclear

NRC/Docu

ment

Control

Desk

05200007

11 Page(s) ___________ ___________________________ _________ J. _________ A

B-94
Document Accession Title/Description Document Author Addressee Docket Date Number Includes Est. Page Count Type Affiliation(s) Affiliation(s) Number

07/07/2004 ML0421i 80099 20Q!7!07-in7 R.h C ! E5.A-3 - Att E2, Graphics-xelon NRC/Docu 05200007

Clinton Lake Volume - 24 YR Period of incl Charts Generation ment

Record Analysis with Single Uprated and Tables, Co, LLC, Control

Existing Plant (Forced Loss estimated Spreadshee Exelon Desk

based on Forced Loss due to two 992 t File Nuclear

MW Plants) & New Plant with Wet-Dry

Cooling Process.

15 Page(s)

07/07/2004 ML042180102 2004/07/07-NRC RAI E5.2-3 - Att E3, Graphics Exelon NRC/Docu 05200007

Clinton Lake Volume - 24 YR Period of incl Charts Generation ment

Record Analysis with Single Uprated and Tables, Co, LLC, Control

Existing Plant (Forced Loss estimated Spreadshee Exelon Desk

based on Forced Loss due to two 992 t File Nuclear

MW Plants) and New Plant with Wet

Cooling Process.

11 Page(s)

07/08/2004 ML042300821 2004/08/08-E-mail - Draft Request for

Additional Information.

E-Mail,

Request for

Additional

Information

(RAI)

NRC/NRR Exelon

Corp

05200007

10 Page(s)

_ .

B-95
Document Accession Title/Description Document Author Addressee Docket

Date Number Includes Est. Page Count Type Affiliation(s) Affiliation(s) Number

07/09/2004 ML041950227 2004/07/09-Environmental Impact Environmen NRC/NRR/D Exelon 05200007

Statement Scoping Process Summary tal Impact RIP/RLEP Generation

Report - Exelon Generation Company, Statement Co, LLC

LLC Early Site Permit, July 2004, U.S.

Nuclear Regulatory Commission,

Rockville, Maryland.

57 Page(s)

07/09/2004 ML041950214 2004/07/09-Issuance of Environmental Letter NRC/NRR/D Exelon 05200007

Scoping Summary Report Associated RIP/RLEP Generation

with Staff's Review of Application by Co, LLC

Exelon Generation Company, LLC. For

an Early Site Permit for Exelon ESP

Site.

10 Page(s)

07/14/2004 ML042300822 2004/07/14-E-mail - Draft Request for E-Mail, NRC/NRR Exelon 05200007

Additional Information. Request for Corp

Additional

9 Page(s) Information

(RAI)

07/15/2004 ML042280013 2004/07/15-E-mail-Draft Requests for E-Mail NRC Exelon 05200007

Additional Information. Generation

Co, LLC 9 Page(s)

B-96
Document Accession Title/Description Document Author Addressee Docket Date Number. Includes Est. Page Count Type Affiliation(s) Affiliation(s) Number

07/20/2004 Ml A94940182 onAAIA7InI, -. a-' - "'a r E-Mail NRuiNRRi Exelon 05200007

Additional Information. Corp

4 Page(s)

07/21/2004 ML042310775 2004/07/21-E-mail, Public EP Info. E-Mail Exelon NRC 05200007

Generation

2 Page(s) Co, LLC

07/22/2004 ML042440477 2004/07/22-E-mail - Draft Request for E-Mail, NRC/NRR Exelon 05200007

Additional Information. Letter Generation

Co, LLC

4 Page(s)

07/22/2004 I ML041890497 2004/07/22-Request for Additional

Information Letter No. 3 - Exelon Early

Site Permit (ESP) Application for the

Clinton ESP Site.

Letter,

Request for

Additional

Information

(RAI)

NRC/NRR/D

RIP/RNRP

Exelon

Generation

Co, LLC

05200007

10 Page(s)

I 07/23/2004 I ML042180090 2004/07/23-NRC RAI E5.2-1&-2 - Aft A, Report, Exelon NRC/Docu 05200007 Lake Drought Model Description. Technical Generation ment

Co, LLC, Control

6 Page(s) Exelon Desk

Nuclear _

B-97
Document Accession Title/Description Document Author Addressee Docket

Date Number Includes Est. Page Count Type Affillation(s) Affiliation(s) Number

07/23/2004 ML042180079 2004/07/23-Exelon Generation Legal- Exelon NRC/Docu 05200007

Company, LLC (EGC) Application for Affidavit, Generation ment

an Early Site Permit (ESP) Letter Co, LLC, Control

Environmental Requests for Additional Exelon Desk

Information.. Nuclear

97 Page(s)

07/23/2004 ML042440486 2004/07/23-E-mail - Draft Request for E-Mail NRC/NRR Exelon 05200007

Additional Information. Generation

Co, LLC

3 Page(s)

07/23/2004 ML042180095 2004/07/23-NRC RAI E5.2-1&-2 - Att C, Graphics Exelon NRC/Docu 05200007

Lake Drought Analysis Model, Clinton incl Charts Generation ment

Lake Volume - 100 YR RI Dry Period. and Tables, Co, LLC, Control

Spreadshee Exelon Desk

4 Page(s) t File Nuclear

07/23/2004 ML042180088 2004/07/23-NRC RAI E4.4-1 - Att B, - No Exelon NRC/Docu 05200007

Capacity Waste Water Supply - Rev. Document Generation ment

Type Co, LLC, Control

2 Page(s) Applies Exelon Desk

Nuclear

07/23/2004 ML042180093 2004/07/23-NRC RAI E5.2-1 &-2 - Att B, Report, Exelon NRC/Docu 05200007

Lake Drought Analysis Description. Technical Generation ment

Co, LLC, Control

4 Page(s) Exelon Desk

Nuclear

B-98
Document Accession Title/Descriptlon Document Author Addressee Docket Date Number Includes Est. Page Count Type Affillation(s) Affiliation(s) Number

07/23/2004 ML0421 sn1 n 9004!07I23-N!PRC I AI '.1 1-3 . - mot Graphics , Exelon NRC/Docu 05200007 Revised Table 7.1-2. incl Charts Generation ment

and Tables Co, LLC, Control

3 Page(s) Exelon Desk

Nuclear

07/23/2004 ML042180096 2004/07/23-NRC RAI E5.2-3 - Att D, Report, Exelon NRC/Docu 05200007 Clinton Lake Period of Record Analysis Technical Generation ment - Spreadsheet Column by Column Co, LLC, Control Explanation. Exelon Desk

Nuclear 11 Page(s)

07/23/2004 ML042180105 2004/07/23-NRC RAI E5.2-3 - Att E4, Graphics Exelon NRC/Docu 05200007 Table 2.3-2, Attachment to July 22, incl Charts Generation ment

2002 Memo from Blonn, Keiser and Toll and Tables, Co, LLC, Control - Revised January 29, 2003. Spreadshee Exelon Desk

t File Nuclear

14 Page(s)

07/26/2004 ML042010267 2004/07/26-Clinton ESP Site Request Letter, NRC/NRR/D Exelon 05200007 For Additional Information Letter No. 4 - Request for RIP/RNRP Generation

Exelon ESP Application. Additional Co, LLC

Information

14 Page(s) (RAI)

07/26/2004 ML042440510 2004/07/26-E-mail - RAI Letters. E-Mail, NRC Exelon 05200007

Letter Generation _ 49 Page(s) Co, LLC

B-99

----
Document Accession Title/Description Document Author Addressee Docket

Date Number Includes Est. Page Count Type Affiliation(s) Affillation(s) Number

07/26/2004 ML042020018 2004/07/26-Clinton ESP Site Request Letter, NRC/NRR/D Exelon 05200007

For Additional Information Letter No. 7 - Request for RIP/RNRP Generation

Exelon ESP Application. Additional Co, LLC

Information

13 Page(s) (RAI)

07/26/2004 ML042020371 2004/07/26-Request For Additional Letter, NRC/NRR/D Exelon 05200007

Information Letter No. 9 - Exelon ESP Request for RIP/RNRP Generation

Application for the Clinton ESP Site. Additional Co, LLC

Information

9 Page(s) (RAI)

07/26/2004 ML042020002 2004/07/26-Clinton ESP Site Request Letter, NRC/NRR/D Exelon 05200007

For Additional Information Letter No. 6 - Request for RIP/RNRP Generation

Exelon ESP Application. Additional Co, LLC

Information

11 Page(s) (RAI)

07/27/2004 ML042280018 2004/07/27-E-mail - RE: RAI Letters. E-Mail Exelon Corp Exelon 05200007

Corp, NRC

2 Page(s)

07/27/2004 ML042020408 2004/07/27-Request For Additional Letter, NRC/NRR/D Exelon 05200007

Information Letter No. 10 - Exelon ESP Request for RIP/RNRP Generation

Application for the Clinton ESP Site. Additional Co, LLC

Information

9 Page(s) (RAI)

07/27/2004 ML042440530 2004/07/27-E-mail - RAI Letters. E-Mail, NRC Exelon 05200007

Letter Generation

47 Page(s) Co, LLC

B-100
Document Accession TitlelDescription | Document Author Addressee Docket Date Number Includes Est. Page Count Type Affillation(s) Affillation(s) Number

OT12T!2004 IM^L0420021 ' Addiiionai Letter, NRC/NRR/D Exelon 05200007 Information Letter No. 8 - Exelon ESP Request for RIP/RNRP Generation Application for the Clinton ESP Site. Additional Co, LLC

Information

10 Page(s) (RAI) _

07/27/2004 ML042440523 2004/07/27-E-mail - RAI Letters. E-Mail, NRC Exelon 05200007

Letter Generation

49 Page(s) Co, LLC

07/27/2004 ML042050408 2004/07/27-Exelon ESP Application for Letter, NRC/NRR/D Exelon 05200007 the Clinton ESP Site (TAC No. Request for RIP/RNRP Generation MC1 122). Additional Co, LLC

Information

13 Page(s) (RAI)

07/27/2004 ML042280017 2004/07/27-E-mail- RE: RAI Letters. E-Mail Exelon Corp Exelon 05200007

Corp, NRC

2 Page(s)

07/27/2004 ML042010334 2004/07/27-Request For Additional Letter, NRC/NRR/D Exelon 05200007 Information Letter No. 5 - Exelon ESP Request for RIP/RNRP Generation Application for the Clinton ESP Site. Additional Co, LLC

Information

7 Page(s) (RAI)

07/30/2004 ML042440473 2004/07/30-E-mail - RAI Letter No. 3. E-Mail NRC Exelon 05200007

Corp

11 Page(s)

B-101
Document Accession Title/Description Document Author Addressee Docket

Date Number Includes Est. Page Count Type Affiliation(s) Affiliation(s) Number

08/23/2004 ML042370551 2004/08/23-Request for Additional Letter, NRC/NRR/D Exelon 05200007

Information (RAI) Regarding the Request for RIP/RLEP Generation

Environmental Portion of the Early Site Additional Co, LLC

Permit Application for the Exelon Information

Generation Company Site (TAC NO. (RAI)

MCI 125).

9 Page(s)

08/24/2004 ML042230041 2004/08/24-Exelon, Revision to RAI No. Letter, NRC/NRR/D Exelon 05200007

11 - ESP Application for Clinton ESP Request for RIP/RNRP Generation

Site. Additional Co, LLC

Information

12 Page(s) (RAI)

08/31/2004 ML042530527 2004/08/31-Exelon Generation Legal-Brief Exelon NRC/OCM 05200007

Company's Answer in Opposition to Generation

Petition for Interlocutory Review Co, LLC,

Morgan,

40 Page(s) Lewis & ._ Bockius, LLP

09/07/2004 ML042660165 2004/09/07-Submittal of Early Site Letter Exelon NRC/Docu 05200007

Permit Quality Plans. Nuclear ment

Control

7 Page(s) Desk

B-102
Document Accession | Title/Description Document Author Addressee Docket Date Number Includes Est. Page Count Type Affillation(s) Afflilation(s) Number

0"-/07/204 A, 60V01°2,u I . I-Let;tt rum Paui M. Legai- Exelon Environme 05200007 Bessette to Shannon Fisk and Tyson R. Interrogatori Generation ntal Law & Smith attaching disclosures with es and Co, LLC, Policy Ctr, respect to Contention 3.1 as admitted Response Morgan, NRC/OGC

by the Licensing Board Lewis &

Bockius, LLP

5 Page(s)

09/07/2004 ML042750231 2004/09/07-E-mail w/o att-EGC ESP E-Mail Exelon NRC 05200007 Quality Plan. Generation

Co, LLC

2 Page(s)

09/17/2004 ML042590004 2004/09/17 - Summary of Meeting with Meeting NRC/NRR/D Dominion 05200007, Dominion, SERI and Exelon Regarding Summary RIP/RNRP Nuclear 05200008, Reviews of EP Aspects of Their North 05200009

Respective ESP Applications. Anna, LLC,

Exelon

10 Page(s) Generation

Co, LLC,

Exelon

Nuclear,

System

Energy

Resources,

Inc

B-103

-
Document Accession Title/Description Document Author Addressee Docket

Date Number Includes Est. Page Count Type Affiliation(s) Afflilation(s) Number

09/17/2004 ML042730435 2004/09/17-Exelon Generation Letter Exelon NRC/Docu 05200007

Company, LLC (EGC), Delay in Nuclear ment

Responding to Requests for Additional Control

Information (RAI) regarding the Desk

Environmental Portion of the

Application for an Early Site Permit

(ESP).

2 Page(s)

09/17/2004 ML042680065 2004/09/17-Joint Response of Exelon Legal- Exelon NRC/ASLB 05200007

Generation Company and the NRC Report Generation P

Staff to Licensing Board Request Co, LLC,

Regarding Mandatory Hearing Morgan,

Procedures for the Clinton Early Site Lewis &

Permit Bockius, LLP

14 Page(s)

09/21/2004 ML042730214 2004/09/21 -Letter from Steven P. Legal- Exelon NRC/ASLB 05200007

Frantz to Administrative Judges Correspond Generation P

informing of the agreement of Exelon ence Co, LLC,

Generation Company, Intervenors, and Morgan,

the NRC staff regarding updates to Lewis &

discovery disclosures under 10 CFR § Bockius, LLP

2.336(d)

4 Page(s)

B-104
Document Accession Title/Description Document Author Addressee Docket Date Number Includes Est. Page Count Type Affiliation(s) Affiliation(s) Number

09/23/2004 ML042730012 2004/09/23-Exelon G1np-rti nLga-- n x e l o , NRiiuuocu 05200007 Company, LLC (EGC), Response to Affidavit, Nuclear ment

Requests for Additional Information Letter Control (RAI) regarding the Environmental Desk

Portion of the Application for an Early

Site Permit (ESP).

51 Page(s)

09/24/2004 ML042730467 2004/09/24-Letter from Steven P. Legal- Exelon NRC/ASLB 05200007 Frantz to Administrative Judges Correspond Generation P

enclosing a copy of a letter dated ence Co, LLC, 09/23/04 from Exelon Generation Morgan, Company to the NRC staff responding Lewis &

to several Requests for Additional Bockius, LLP

Information

54 Page(s)

09/28/2004 ML042790495 2004/09/28-Response to Request for Letter Exelon NRC/Docu 05200007

Additional Information (RAI) Letter No. Nuclear ment

5 - Exelon Early Site Permit (ESP) Control

Application for the Clinton ESP Site Desk

(TAC No. MC1 122.).

10 Page(s)

09/28/2004 ML042780333 2004/09/28-E-mail-Response to RAI E-Mail Exelon NRC 05200007

Letter No. 5. Generation

Co, LLC

12 Page(s)

B-1U5
Document Accession Title/Description Document Author Addressee Docket Date Number Includes Est. Page Count Type Affiliation(s) Affiliation(s) Number

10/01/2004 ML042790056 2004/10/01-E-mail-FW: Exelon ESP E-Mail, Exelon NRC 05200007

Quality Plan. Letter Generation

Co, LLC

2 Page(s)

10/01/2004 ML042790139 2004/10/01-E-mail-Re: FW: Exelon E-Mail, NRC Exelon 05200007

ESP Quality Plan. Letter Generation

Co, LLC

2 Page(s)

10/05/2004 ML042890418 Response to Request for Additional Letter Exelon NRC/Docu 05200007

Information (RAI) Letter No. 3 - Exelon Nuclear ment

Early Site Permit (ESP) Application for Control

the Clinton ESP Site (TAC No. Desk

MC1 122).

43 Page(s)

10/06/2004 ML042860252 2004/10/06-E-mail - Typographical E-Mail NRC Exelon 05200007

Error in RAI Letter No. 7. Generation

Co, LLC

2 Page(s)

10/06/2004 ML042800504 2004/10/06-Telecon Summary to Note NRC/NRR/D Exelon 05200007

Clarify Responses to NRC RIP/RLEP Generation

Environmental Requests for Additional Co, LLC

Information on the Exelon Early Site

Permit Application.

9 Page(s)

B-1 06
Document Accession Title/Description Document Author Addressee Docket Date Number Includes Est. Page Count Type Affiliation(s) Affiliation(s) Number

10/06/2004 ML042860248 9nnd/10n!06-E-mnil-First EP RA! E-Mail, Exei. NRC 05200007

response submittal. Letter Generation

Co, LLC

44 Page(s)

10/07/2004 ML042890357 2004/10/07-Response to Request for Letter Exelon NRC/Docu 05200007 Additional Information (RAI) Letter No. Nuclear ment

8 - Exelon Early Site Permit (ESP) Control

Application for the Clinton ESP Site. Desk

33 Page(s)

10/07/2004 ML042890390 Response to Revision to Request for Emergency Exelon NRC/Docu 05200007 Additional Information (RAI) Letter- No. Preparedne Nuclear ment

11 - Exelon Early Site Permit (ESP) ss- Control Application for the Clinton ESP Site Emergency Desk (TAC No. MC1 122.) Plan, Letter

67 Page(s)

10/07/2004 I ML042870496 2004/10/07-Letter from Paul M.

Bessette to Shannon Fisk and Mauri T.

Lemoncelli attaching updates to

disclosures with respect to Contention

3.1

LegalAffidavit,

LegalCorrespond

ence

Exelon

Generation

Co, LLC,

Morgan,

Lewis &

Bockius, LLP

Environme

ntal Law &

Policy Ctr,

NRC/OGC

05200007

5 Page(s)

B-i07
Document Accession Title/Description Document Author Addressee Docket Date Number Includes Est. Page Count Type Affiliation(s) Affiliation(s) Number

10/08/2004 ML042880460 2004/10/08-Response to Request for Letter Exelon NRC/Docu 05200007

Additional Information (RAI) Letter No. Nuclear ment

10 - Exelon Early Site Permit (ESP) Control

Application for the Clinton ESP Site Desk

(TAC No. MC1 122.)

15 Page(s)

10/08/2004 ML042990572 2004/10/08-Email- Response to RAI E-Mail Exelon NRC 05200007

Letter No. 11. Generation

Co, LLC

2 Page(s)

10/08/2004 ML042920203 10/08/04-E-mail- Response to RAI E-Mail, Exelon NRC 05200007

Letter No. 11. Legal- Generation

Affidavit, Co, LLC

68 Page(s) Letter,

Report,

Miscellaneo

us

10/08/2004 ML042890051 2004/10/08-Response to Request for Letter Exelon NRC/Docu 05200007

Additional Information (RAI) Letter No. Nuclear ment

4 - Exelon Early Site Permit (ESP) Control

Application for the Clinton ESP Site. Desk

145 Page(s)

10/08/2004 ML042860254 2004/10/08-E-mail - Response to RAI E-Mail, Exelon NRC 05200007

Letter No. 8. Letter Generation

Co, LLC

35 Page(s)

B-108
Document Accession Title/Description 1 Document 1 Author | Addressee Docket Date Number Includes Est. Page Count Type Affiliation(s) Affillation(s) Number

10/08/200)4 MIOd'880466 2004/10/0W-IWIsponsI LO NRC Letter Exelon NRC/Docu 05200007 Inspection of Applicant and Contractor Nuclear ment Quality Assurance Activities Involved Control

with Preparation of the Application for Desk

an Early Site Permit, Report

0520007/2004001.

12 Page(s)

10/11/2004 ML042920225 2004/10/11 -E-mail-RE: Response to E-Mail, Exelon NRC 05200007 QA IR. Letter Generation

Co, LLC

14 Page(s)

10/11/2004 ML042920222 2004/10/11 -E-mail- RE: Response to E-Mail, Exelon NRC 05200007 RAI Letter No. 4 Legal- Generation

Affidavit, Co, LLC

147 Page(s) Letter,

Report,

Miscellaneo

us

10/11/2004 ML042920213 2004/10/11-E-mail- Response to RAI E-Mail, Exelon NRC 05200007

Letter No. 10. Legal- Generation

Affidavit, Co, LLC

17 Page(s) Letter

B-109
Document Accession Title/Description Document Author Addressee Docket Date Number Includes Est. Page Count Type Affiliation(s) Affiliation(s) Number

10/1 1/2004 ML042960106 2004/10/11 -Response to Request for Letter Exelon NRC/Docu 05200007

Additional Information (RAI) Letter No. Generation ment

7 - Exelon Early Site Permit (ESP) Co, LLC, Control

Application for the Clinton ESP Site. Exelon Desk

Nuclear

91 Page(s)

10/11/2004 ML042960057 2004/10/11 -Response to Request for Letter Exelon NRC/Docu 05200007 Additional Information (RAI) Letter No. Nuclear ment

9 - Exelon Early Site Permit (ESP) Control

Application for the Clinton ESP Site. Desk

8 Page(s)

10/11/2004 ML042960105 Response to Request for Additional Legal- Exelon NRC/Docu 05200007 Information (RAI) Letter No. 6 - Exelon Affidavit, Nuclear ment

Early Site Permit (ESP) Application for Letter Control

the Clinton ESP Site. Desk

56 Page(s)

10/12/2004 ML043030610 2004/10/12-E-mail-FW: 3rd set of E-Mail Exelon NRC 05200007

seismic attachments #2. Generation

Co, LLC

3 Page(s)

10/12/2004 ML043030613 2004/10/12-E-mail-RAI 2.5.2-6 Figure E-Mail Exelon NRC 05200007

1 A. Generation

Co, LLC

3 Page(s)

B-110
Document Accession Title/Description | Document | Author 1 Addressee Docket Date Number Includes Est. Page Count Type j Afflilation(s) Affiliation(s) Number

ML0433 10/12/2004 672 20a1012 -E-mai.-RE: 3r seI o' c-iviaii Exelon NRC 05200007 seismic attachments (8 of 11). Generation

Co, LLC

2 Page(s)

10/12/2004 ML042920229 2004/10/12-E-mail- Response to RAI E-Mail Exelon NRC 05200007 Letter No. 6. Generation

Co, LLC

383 Page(s)

10/12/2004 ML043030667 2004/10/12-E-mail-RE: 3rd set of E-Mail Exelon NRC 05200007

seismic attachments (7 of 11). Generation

Co, LLC

2 Page(s)

10/12/2004 ML042920234 2004/10/12-E-mail- Response to RAI E-Mail, Exelon NRC 05200007 Letter No. 9. Letter Generation

Co, LLC

10 Page(s) _ _

10/12/2004 ML043030600 2004/10/12-E-mail-FW: 3rd set of E-Mail Exelon NRC 05200007

seismic attachments. Generation

Co, LLC

3 Page(s)

10/12/2004 ML043030592 2004/10/12-E-mail-2nd set of seismic E-Mail Exelon NRC 05200007

attachments. Generation

Co, LLC ___________ ~~2 P age(s)__ _ _ _ _ _ _ _ _ _ _ __ _ _ _ _ _

B-111
Document Accession Title/Description Document Author Addressee Docket

Date Number Includes Est. Page Count Type Affillation(s) Affiliation(s) Number

10/12/2004 ML043030583 2004/10/12-E-maiy * st set of seismic E-Mail Exelon NRC 05200007

attachments Generation

Go, LLC

2 Page(s) _

10/12/2004 ML043030700 2004/10/12-E-mail-RE: 3rd set of E-Mail Exelon NRC 05200007

seismic attachments (12 of 12). Generation

Go, LLC

2 Page(s)

10/12/2004 ML043030664 2004/10/12-E-mail-RE: 3rd set of E-Mail Exelon NRC 05200007

seismic attachments (6 of 11). Generation

Go, LLC

2 Page(s)

10/12/2004 ML043030660 2004/10/12-E-mail- RE: 3 rd set of E-Mail Exelon NRC 05200007

seismic attachments (5 of 11). Generation

Co, LLC

2 Page(s)

10/12/2004 ML043030651 2004/10/12-E-mail-FW: 3r set of E-Mail Exelon NRC 05200007

seismic attachments (2 of 11). Generation

Go, LLC

2 Page(s)

10/12/2004 ML043030631 2004/10/12-E-mail-RE: 3rd set of E-Mail Exelon NRC 05200007

seismic attachments (4 of 11). Generation

_o, LLC _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ 2 P a g e (s) _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _

B-112
Document Accession Title/Description Document Author Addressee | Docket Date Number Includes Est. Page Count Type Affillation(s) Affiliation(s) Number 10/12/2004 ML043030697 200411012-E-mail-RE: yrd set of -- .Exeon NC I .- wJU IEeinNU05200007

seismic attachments (9 of 11). Generation

Go, LLC

2 Page(s)

10/12/2004 ML043030696 2004/10/12-E-mail- RE: 3' set of E-Mail Exelon NRC 05200007 seismic attachments (11 of 11). Generation

Co, LLC

2 Page(s) ._.

10/12/2004 ML043030617 2004/10/12-E-mail- 3rd set of seismic E-Mail Exelon NRC 05200007 attachments (1 of 11). Generation

Go, LLC

3 Page(s)

10/12/2004 ML043030626 2004/10/12-E-mail-RE: 3rd set of E-Mail Exelon NRC 05200007 seismic attachments (3 of 11). Generation

Co, LLC

2 Page(s)

10/12/2004 ML043030577 2004/10/12-E-mail-Response to RAI E-Mail, Exelon NRC 05200007 Letter No. 7. Letter Generation

Go, LLC - 2 Page(s)

10/12/2004 ML043030675 2004/10/12-E-mail-RE: 3rd set of E-Mail Exelon NRC 05200007

seismic attachments (10 of 11). Generation

GosLLC _ _ _ _2 __ P ag e(s) I _ __ _ I_ __ _ __ _ _ _ _ _ I__ _ _ _ I__ 

B-1 13
Document Accession Title/Description Document Author Addressee Docket

Date Number Includes Est. Page Count Type Affillation(s) Affllation(s) Number

10/19/2004 ML043030553 2004/10/19-E-mail - Seismic E-Mail Exelon NRC 05200007

Consultant. Generation

Co, LLC.

1 Page(s)

10/20/2004 ML043030557 2004/10/20-E-mail-Re: Seismic E-Mail, NRC Exelon 05200007

Consultant. Letter Generation

Co, LLC

2 Page(s) .

10/22/2004 ML043060232 2004/10/22-Letter from Paul M. Legal- Exelon Environme 05200007

Bessette to Shannon Fisk and Mauri T. Correspond Generation ntal Law &

Lemoncelli attaching an update to ence Co, LLC, Policy Ctr,

disclosures with respect to Contention Morgan, NRC/OGC

3.1 as admitted by the Licensing Board Lewis &

Bockius, LLP

5 Page(s)

10/28/2004 ML042820082 2004/10/28-Clinton, Withholding From Letter, NRC/NRR/D Exelon 05200007

Public Disclosure, Exelon ESP Project Proprietary RIP/RNRP Generation

Quality Assurance Plan. Information Co, LLC

Review

6 Page(s)

11/05/2004 ML043140401 11/05/04-E-mail-Conference Call E-Mail NRC Exelon 05200007

Information, Generation

Co, LLC

1 Page(s)

B-114
Document Accession Title/Description Document Author Addressee f Docket Date Number Includes Est. Page Count Type Affillation(s) Affiliation(s) Number

11/12/2004 ML043200576 2004/1 V1/2-E-mail-Draft Rs f E-oai ,NRCUNRR Exelon 05200007

Additional Information - Emergency Letter, Generation

Planning. Request for Co, LLC

Additional

5 Page(s) Information

(RAI) .

11/12/2004 ML043240474 2004/11/12-Exelon Generation Legal- Exelon NRC/ASLB 05200007

Company's Answer in Opposition to Motion Generation P

Intervenors' Motion to Suspend Co, LLC,

Proceeding Pending Reinstatement of Morgan, Agencywide Document Access and Lewis &

Management System Bockius, LLP

8 Page(s)

11/15/2004 ML043210579 2004/11/15-Request for Additional Request for NRC/NRR/D Exelon 05200007

Information (RAI) Regarding the Additional RIP/RLEP Generation

Environmental Portion of the Early Site Information Co, LLC

Permit Application for The Exelon (RAI) Generation Company Site (TAC No.

MC1 125).

7 Page(s)

11/15/2004 ML043090029 2004/11/15-Revised Dates For Letter NRC/NRR/D Exelon 05200007

Conducting the Environmental Review RIP/RNRP Generation

of the Exelon ESP Application. Co, LLC

7 Page(s)

B-115
Document Accession TtlelDescriptlon Document Author Addressee Docket Date Number Includes Est. Page Count Type Affillatlon(s) Affillation(s) Number

11/16/2004 ML043290006 2004/11/16-Corrections / Clarifications Environmen Exelon NRC/Docu 05200007

to the Exelon Early Site Permit (ESP) tal Report, Nuclear ment

Application Environmental Report for Letter Control

the Clinton ESP Site. Desk

67 Page(s)

11/18/2004 ML043410062 2004/11/18-E-mail correspondence E-Mail Exelon Corp NRC, 05200007

regarding ER corrections relating to the NRC/NRR/

EGC ESP environmental review. DRIP/RLEP

, Pacific

1 Page(s) National

Lab

11/19/2004 ML043270432 2004/11/19-E-mail- Seismic Primer. E-Mail Exelon NRC 05200007

Generation

33 Page(s) Co, LLC

11/19/2004 ML043350394 2004/11/19-Seismic Risk (Performance Letter Exelon NRC/Docu 05200007

Goal) Based Approach Primer - Exelon Nuclear ment

Early Site Permit (ESP) Application for Control

the Clinton ESP Site. Desk

31 Page(s)

11/30/2004 ML043360250 2004/11/30-E-mail- Final 2004 NRC E-Mail Exelon Corp NRC 05200007

Invoice.

2 Page(s)

B- 16
Document Accession Title/Description Document Author Addressee Docket Date Number Includes Est. Page Count Type Affiliation(s) Affillation(s) Number

12/07/2004 ML04351017S 2n04!1.9/07-Letter from Paul M. Legal- Exeion Environme 05200007 Bessette to Shannon Fisk and Mauri T. Affidavit, Generation ntal Law & Lemoncelli attaching an update to Legal- Co, LLC, Policy Ctr, disclosures with respect to Contention Correspond Morgan, NRC/OGC 3.1 as admitted by the Licensing Board ence Lewis &

Bockius, LLP

4 Page(s)

12/07/2004 ML043510382 2004/12/07-Corrections/Clarifications to Emergency Exelon NRC/Docu 05200007 the Exelon Generation company, LLC Preparedne Nuclear ment (EGC) Early Site Permit (ESP) ss- Control Application Site Safety Analysis Report Emergency Desk and Emergency Plan for the Clinton Plan, Final

ESP Site. Safety

Analysis 56 Page(s) Report

(FSAR),

Letter

12/08/2004 ML043480194 2004/12/08-E-mail-Self identified E-Mail, Exelon Corp NRC 05200007 changes. Letter

58 Page(s)

12/09/2004 ML043380008 2004/12/09-Request for Additional

Information Letter No. 12 - Exelon ESP

Application for the Clinton ESP Site.

9 Page(s)

Letter,

Request for

Additional

Information

(RAI)

NRC/NRR/D

RIP/RNRP

Exelon

Generation

Co, LLC,

Exelon

Nuclear

05200007

B-117
Document Accession Title/Description Document Author Addressee Docket

Date Number Includes Est. Page Count Type Affiliation(s) Affillation(s) Number

12/13/2004 ML043630425 2004/12/13-Response to Request for

Additional Information (RAI) - Exelon

Early Site Permit (ESP) Application for

the Clinton ESP Site.

LegalAffidavit,

Letter

Exelon Corp,

Exelon

Nuclear

NRC/Docu

ment

Control

Desk

05200007

7 Page(s)

12/13/2004 I ML043570096 2004/12/13-E-mail correspondence E-Mail, Exelon Corp Battelle 05200007

regarding S-3 request for additional Environmen Memorial

information response pertaining to the tal Impact Institute,

Exelon ESP project. Statement Pacific

Northwest

9 Page(s) National

Lab, NRC

ML050030024 2004/12/14-Revised Response to - No Exelon Corp, NRC/Docu 05200007

Request for Additional Information Document Exelon ment

(RAI) Letter No. 3 re: Early Site Permit Type Nuclear Control

(ESP) Application for the Clinton ESP Applies Desk

Site.

13 Page(s)

12/14/2004 I

12/15/2004 ML050030022 2004/12/15-Transmittal of Revised

Response to Request for Additional

Information (RAI) Letter No. 3 re: Early

Site Permit (ESP) Application for the

Clinton ESP Site.

LegalAffidavit,

Letter

Exelon Corp,

Exelon

Nuclear

NRC/Docu

ment

Control

Desk

05200007

3 Page(s) J I - - - _______________ . -

B-118
Document Accession Title/Description Document Author Addressee Docket Date Number Includes Est. Page Count Type Affillatlon(s) Affiliatlon(s) Number

12/15/2004 ML042s3nA44 I 2004112/1 5-E-M. -Dncket ae: 52-007, -ivii Exeion N RC 05200007 EGC Revised RAI 13.3-2 Response. Generation

Co, LLC

16 Page(s)

12/15/2004 ML043520433 2004/12/15-E-mail-Docket 52-007 re: E-Mail Exelon NRC 05200007

Seismic High Frequency Effects. Generation

Co, LLC

6 Page(s) _

12/15/2004 ML043630437 2004/12/15-Early Site Permit Letter Exelon NRC/Docu 05200007

Application for Clinton ESP Site, Nuclear ment

Seismic High Frequency Control Considerations (TAC No. MCI122). Desk

4 Page(s)

12/16/2004 ML043520441 2004/12/16-E-mail-Re: Projection of E-Mail Exelon NRC 05200007

NRC Year End Invoices. Generation

Co, LLC

2 Page(s)

12/16/2004 ML043520438 2004/12/16-E-mail-Projection of NRC E-Mail Exelon NRC 05200007

Year End Invoices. Generation

Co, LLC

3 Page(s)

12/16/2004 ML043520439 2004/12/16-E-mail-Re: Projection of E-Mail NRC Exelon 05200007

NRC Year End Invoices. Generation

Co, LLC

2 Page(s)

B-119
Document Accession Title/Description Document Author Addressee Docket

Date Number Includes Est. Page Count Type Affillation(s) Affiliation(s) Number

01/14/2005 ML050250137 2005/01/14-Early Site Permit (ESP) Graphics Exelon NRC/Docu 05200007

Application for the Clinton ESP Site incl Charts Nuclear ment

Seismic Risk (Performance Goal) and Tables, Control

Based Approach Primer Revision. Legal- Desk

Affidavit,

32 Page(s) Letter

01/14/2005 ML050140051 2005/01/14-Exelon Early Site Permit Letter NRC/NRR/D Exelon 05200007

Project Manager Reassignment. RIP/RNRP Generation

Co, LLC

5 Page(s)

01/24/2005 ML050250305 2005/01/24-E-mail EP ETE RAI E-Mail, Exelon NRC/NRR/ 05200007

Responses to Letter No. 12. Graphics Generation DRIP/RNR

incl Charts Co, LLC P

88 Page(s) and Tables,

LegalAffidavit

02/01/2005 ML043570375 2005/02/01-Clinton, Withholding From Letter, NRC/NRR/D Exelon 05200007

Public Disclosure, Exelon ESP Proprietary RIP/RNRP Generation

Application - State and Local Information Co, LLC

Emergency Plans. Review

5 Page(s)

02/04/2005 ML050320230 2005/02/04-Potential Open Items for Letter NRC/NRR/D Exelon 05200007

the Draft Safety Evaluation Report for RIP Generation

the Exelon Early Site Permit Co, LLC

Application.

12 Page(s)

B-120
Document Accession Title/Description Document Author | Addressee Docket Date Number Includes Est. Page Count Type Afflilation(s) Affiliation(s) Number

02/07/2005; Ml0503Q092 205/0207-E-ma[l-Potenttai Exeiun E-Maii, NRC/NRR Exelon 05200007 ESP DSER Open Items. Letter Generation

Co, LLC

10 Page(s)

02/10/2005 ML050400350 2005/02/10-Draft Safety Evaluation Letter, NRC/NRR/D Exelon 05200007

Report for the Exelon Early Site Permit Safety RIP/RNRP Generation

Application. Evaluation Co, LLC

Report, 9 Page(s) Draft

02/11/2005 ML050480478 2005/02/11-E-mail-Re: Copy of Exelon Draft Safety NRC Exelon 05200007

ESP DSER, Appendices A & B. Evaluation Generation

Report Co, LLC, 54 Page(s) (DSER), E- NRC

Mail,

Graphics

incl Charts

and Tables

02/11/2005 ML050480447 2005/02/11-E-mail-Re: Copy of Exelon Draft Safety NRC Exelon 05200007

ESP DSER-#1. Evaluation Generation

Report Co, LLC, 169 Page(s) (DSER), E- NRC

Mail, Letter

02/11/2005 ML050670436 2005/02/11-E-mail- Re: Copy of Exelon E-Mail NRC Exelon 05200007

ESP DSER. Generation

Co, LLC,

2 Page(s) NRC . -

B-121
Document Accession Title/Description Document Author Addressee Docket Date Number Includes Est. Page Count Type Affillation(s) Affillation(s) Number

02/15/2005 ML050550356 2005/02/15-Letter from Paul M. Legal- Exelon Environme 05200007

Bessette to Shannon Fisk and Mauri T. Affidavit, Generation ntal Law &

Lemoncelli providing an update to Legal- Co, LLC, Policy Ctr, disclosures with respect to Contention Correspond Morgan, NRC/OGC

3.1 as admitted by the Licensing Board ence Lewis &

Bockius, LLP

4 Page(s) _

02/23/2005 1 ML050630552 2005/02/03-Review of Draft Safety

Evaluation Report for the Early Site

Permit (ESP) Application for the Clinton

ESP Site.

Letter Exelon

Nuclear

NRC/Docu

ment

Control

Desk

05200007

2 Page(s)

B-122
Document Accession Title/Description Document Author Addressee Docket Date Number .Includes Est. Page Count Type Affillation(s) Affiliation(s) Number

02/24/2005 ML0506n841 4 9005./0_____ -EVIL4I a VWVW DalIt SaIty

Evaluation Report for the Exelon Early

Site Permit Application.

10 Page(s)

E-Maii NRC/NHR/D

RIP/RNRP

Advanced

Technologi

es & Labs

Internationa

I, Inc, AECL

Technologi

es, nc,

Dominion,

Eckert,

Seamans,

Cherin &

Mellott,

LLC,

Entergy

Nuclear

Operations,

Inc, Exelon

Corp,

Framatome

ANP, Inc,

General

Atomics,

General

Electric Co,

Greenpeac

e, NRC,

Nuclear

Control

Institute,

Nuclear

05200007

I J. L .I

B-1 23
Document Accession Title/Description Document Author Addressee Docket Date Number Includes Est. Page Count Type Affillation(s) Affiliation(s) Number

02/28/2005 ML050400378 2005/02/28-Clinton, Early Site Permit Safety NRC/NRR/D Exelon 05200007

Draft Safety Evaluation Report, Chapter Evaluation RIP/RNRP Generation

1 with Table of Contents and Report, Co, LLC

Abbreviations. Draft

29 Page(s)

02/28/2005 ML050400411 2005/02/28-Clinton, Early Site Permit Safety NRC/NRR/D Exelon 05200007

Draft Safety Evaluation Report, Chapter Evaluation RIP/RNRP Generation

18, Review by the Advisory Committee Report, Co, LLC

on Reactor Safeguards. Draft

1 Page(s)

02/28/2005 1 ML050400404 2005/02/28-Clinton, Early Site Permit

Draft Safety Evaluation Report, Chapter

17, Quality Assurance.

Safety

Evaluation

Report,

Draft

NRC/NRR/D

RIP/RNRP

Exelon

Generation

Co, LLC

05200007

39 Page(s)

02/28/2005 I*ML050400436 2005/02/28-Clinton, Early Site Permit Safety NRC/NRR/D Exelon 05200007

Draft Safety Evaluation Report, Evaluation RIP/RNRP Generation

Appendix A, Chronology of Early Site Report, Co, LLC

Permit application for the EGC ESP Draft

Site.

43 Page(s) ._

B-124
Document Accession Title/Description Document Author Addressee Docket Date Number Includes Est. Page Count Type Affillation(s) Affillation(s) Number

02/28/2005 ML050400394 2005/02/28-Clinton, Early Site Permi t Safetyn;C/'RPJD bxeion 05200007 Draft Safety Evaluation Report, Chapter Evaluation RIP/RNRP Generation

3, Site Safety Assessment. Report, Co, LLC

Draft

26 Page(s)

02/28/2005 ML050400423 2005/02/28-Clinton, Early Site Permit Safety NRC/NRR/D Exelon 05200007 Draft Safety Evaluation Report, Chapter Evaluation RIP/RNRP Generation

19, Conclusions. Report, Go, LLC

Draft

1 Page(s)

02/28/2005 ML050400386 2005/02/28-Clinton, Early Site Permit Safety NRC/NRR/D Exelon 05200007 Draft Safety Evaluation Report, Chapter Evaluation RIP/RNRP Generation

2, Site Characteristics. Report, Go, LLC

Draft

139 Page(s)

02/28/2005 ML050400450 2005/02/28-Clinton, Early Site Permit Safety NRC/NRR/D Exelon 05200007 Draft Safety Evaluation Report, Evaluation RIP/RNRP Generation

Appendix B, References. Report, Co, LLC

Draft

9 Page(s)

03/02/2005 ML050620302 2005/03/02-Notice of Availability of the Federal NRC/NRR/D Exelon 05200007 Draft Environmental Impact Statement Register RIP Generation

(DEIS) for An Early Site Permit (ESP) Notice, Co, LLC

at the Exelon ESP Site (TAC NO. Letter

MC1 125).

10 Page(s)

B-125
Document Accession Title/Description Document Author Addressee Docket

Date Number Includes Est. Page Count Type Affiliation(s) Affiliation(s) Number

03/03/2005 ML050670270 2005/03/03-E-mail-Exelon ESP re: E-Mail Exelon NRC/NRR/ 05200007

NRC Invoice for 4 th Qtr 2004. Generation DRIP/RNR

Co, LLC P

2 Page(s)

B-126

I
Document Accession Title/Description Document Author Addressee 1 Docket Date Number Includes Est. Page Count Type Affiliation(s) Affiliation(s) Number

03/04/2005 ML050540039 2005/03104.nrnft 5 afety E=aluation

Report for the Exelon Early Site Permit

Application.

7 Page(s)

I Letter 14RPiNRRiP

RIP/RNRP

- No Known

Affiliation,

Advanced

Technologi

es & Labs

Internationa

1, Inc,

CH2M Hill,

Dominion

Generation,

Enercon

Services,

Inc,

Entergy

Nuclear,

Inc, Exelon

Generation

Co, LLC,

Exelon

Nuclear,

Framatome

ANP

Richland,

Inc,

Greenpeac

e, Morgan,

Lewis &

Bockius,

LLP,

Nuclear

05200007

I I

B-127
Document Accession Title/Description Document Author Addressee Docket

Date Number Includes Est. Page Count Type Affillation(s) Affillation(s) Number

03/04/2005 ML050670302 2005/03/04-E-mail-Exelon ESP re: E-Mail NRC/NRR/D Exelon 05200007

NRC Invoice for 4th Qtr 2004. RIP/RNRP Generation

Co, LLC __ 2 Page(s)

03/08/2005 ML050670580 2005/03/08-E-mail-Conference line for E-Mail Exelon Corp NRC/NRR/ 05200007

Thursday Hydrology call. DRIP/RNR

P _______ ____ 2 P age(s)__ _ _ _ __ _ _ _ _ _ _

B-128
Document Accession Title/Description Document Author Addressee Docket

Date Number [ Includes Est. Page Count Type Affiliation(s) Affillation(s) Number

03/0S/2005 ML-.5;7nqP22 205.n9/03./OR-;:-Mai-PA^fd: D~raft QSf^ho

Evaluation Report for the Exelon Early

Site Permit Application.

13 Page(s)

E-AMa:I - IV ILAII '41 I .dI/ I 11 f Li

RIP/RN RP

ruvac iced

Technologi

es & Labs

Internationa

I, Inc, AECL

Technologi

es, Inc,

Dominion,

Eckert,

Seamans,

Cherin &

Mellott,

LLC,

EmergiLite,

Entergy

Nuclear

Operations,

Inc, Exelon

Corp,

Framatome

ANP, Inc,

General

Atomics,

General

Electric Co,

Greenpeac

e, NRC,

Nuclear

Control

VU4JUuuu

A _________________ I I J
Document Accession Title/Description Document Author Addressee Docket Date Number Includes Est. Page Count Type Affiliation(s) Affillation(s) Number

03/11/2005 ML050800407 2005/03/11-Letter from Paul M. Legal- Exelon Environme 05200007

Bessette to Shannon Fisk and Mauri T. Interrogatori Generation ntal Law &

Lemoncelli attaching an update to es and Co, LLC, Policy Ctr, disclosures with respect to Contention Response Morgan, NRC/OGC

3.1 as admitted by the Licensing Board Lewis &

Bockius, LLP

4 Page(s)

03/16/2005 ML050810517 2005/03/16-Seismic Risk (Performance Letter Exelon NRC/Docu 05200007

Goal) Based Approach Calculation re: Nuclear ment

Early Site Permit Application for Clinton Control

Site. Desk

11 Page(s) _

03/17/2005 ML050870594 2005/03/17-Exelon's Motion for Legal- Exelon NRC/ASLB 05200007

Summary Disposition of Contention 3.1 Motion Generation P

Co, LLC,

180 Page(s) Morgan,

Lewis &

Bockius, LLP

03/18/2005 ML050800214 2005/03/18-E-mail from Eddie R. Grant E-Mail Exelon NRC/NRR/ 05200007

to John Segal regarding March 16 Generation DRIP/RNR

submittal. Co, LLC P

13 Page(s)

B-130
Document Accession Title/Description Document Author Addressee Docket Date Number Includes Est. Page Count Type Affillation(s) Affiliation(s) Number fflf~,r~J~r4 I -.. *...~.....''I

031!21!200-5 ML0N 5C01 A3 2 °O50/ 3.0.'1-11 I-Lv- s-ll et=cl I L t V I I I VJ I I I -I Lver, P .

Frantz to Members of the Licensing

Board regarding Certification for Motion

for Summary Disposition

LegaiCorrespond

ence

Exeion

Generation

Co, LLC,

Morgan,

Lewis &

Bockius, LLP

NHC/ASLB

P

05200007

4 Page(s)

03/29/2005 I

I 03/31/2005 I

ML051010274 2005/03/29-Two E-Mails to Bill Maher E-Mail, NRC/NRR Exelon 05200007 for the public hearing record for the Environmen Corp Exelon ESP site. tal Impact

Statement 4 Page(s)

ML050920004 2005/03/3-Notice of Change of Federal NRC/NRR/D Exelon 05200007 Location for Public Meeting on the Draft Register RIP/RLEP Generation

Environmental Impact Statement Notice, Co, LLC

(DEIS) for an Early Site Permit (ESP) at Letter,

the Exelon ESP Site (TAC No. Meeting

MC1 125). Notice

11 Page(s) .

ML051020249 2005/04/04-Partial Response to Draft Letter Exelon NRC/Docu 05200007 Safety Evaluation Report (DSER) Nuclear ment

Items. Control

Desk

63 Page(s) .

04/04/2005 I

B-1 31
Document 'Accession Title/Description Document Author Addressee Docket

Date Number Includes Est. Page Count Type Affiliation(s) Affiliation(s) Number

04/05/2005 ML051010295 2005/04/05-E-mail from Eddie R. Grant E-Mail, Exelon NRC/NRR/ 05200007

to John Segala regarding April 4 Letter Generation DRIP/RNR

submittal. Co, LLC P

65 Page(s)

04/07/2005 ML051080047 2005/04/07-Letter from Paul M. Legal- Exelon Environme 05200007

Bessette to Shannon Fisk and Mauri T. Interrogatori Generation ntal Law &

Lemoncelli providing an update to es and Co, LLC, Policy Ctr,

disclosures with respect to Contention Response Morgan, NRC/OGC

3.1 as admitted by the Licensing Board Lewis &

Bockius, LLP

4 Page(s) _

04/08/2005 ML050980379 2004/04/08-Notice of Change of Federal NRC/NRR/D Exelon 05200007

Location for Public Meeting on the Draft Register RIP Generation

Environmental Impact Statement Notice, Co, LLC

(DEIS) for an Early Site Permit (ESP) at Letter

the Exelon ESP Site (TAC No.

MC1 125).

10 Page(s)

04/19/2005 1 ML051150509 2005/04/19-E-mail from Eddie R. Grant

to John Segala Regarding Exelon ESP

DSER Hydrology Discussion Items.

E-Mail Exelon

Generation

Co, LLC

NRC/NRR/

DRIP/RNR

P

05200007

5 Paae(s)

B-132
Document Accession Title/Description Document Author | Addressee | Docket Date Number Includes Est. Page Count Type Affiliation(s) Affiliation(s) Number

04/22/20ni MI nA11 On0 2005/06!22-Intervt:j, oi-s' Mot o Legai- Blue Ridge NRC/ASLB 05200007 Amend Contention 3.1 Motion Environment P

al Defense

78 Page(s) League,

Environment

al Law &

Policy Ctr,

Exelon

Generation

Co, LLC,

Harmon,

Curran,

Spielberg &

Eisenberg,

LLP, Nuclear

Energy

Information

Service,

Nuclear

Information

& Resource

Service

(NIRS),

Public

Citizen, Inc

B-1 33
Document Accession Title/Description Document Author Addressee Docket Date Number Includes Est. Page Count Type Affiliation(s) Affillation(s) Number

04/25/2005 ML051240310 2005/04/25-Letter from Paul M. Legal- Exelon Environme 05200007

Bessette to Shannon Fisk and Mauri T. Interrogatori Generation ntal Law &

Lemoncelli providing an update to es and Co, LLC, Policy Ctr, disclosures with respect to Contention Response Morgan, NRC/OGC

3.1 as admitted by the Licensing Board Lewis &

Bockius, LLP

4 Page(s)

04/26/2005 ML051170014 2005/04/26-E-mail from Eddie R. Grant E-Mail Exelon NRC/NRR/ 05200007

to John Segala Regarding Exelon ESP Generation DRIP/RNR

DSER 01 Response. Co, LLC P

82 Page(s)

04/26/2005 ML051230326 2005/04/25-Response to Draft Safety Letter Exelon NRC/Docu 05200007

Evaluation Report (DSER) Regarding Nuclear ment

the Early Site Permit (ESP) Application Control

for the Clinton ESP Site. Desk

79 Page(s) .

B-134
Document Accession Title/Description Document Author Addressee Docket Date Number Includes Est. Page Count Type Affiliation(s) Affiliation(s) Number

05/05/2005 MLo51 320313 2005!t5!05-Sith AddtionaI DlSdusuie LeyW-Environment NHC/ASLB 05200007 of Intervenors Environmental Law and Intervention al Law & P

Policy Center, Blue Ridge Petition, Policy Ctr, Environmental Defense League, Responses Exelon

Nuclear Information and Resource and Generation

Service, Nuclear Energy Information Contentions Co, LLC, Service, and Public Citizen Harmon,

Curran, 7 Page(s) Spielberg &

Eisenberg,

LLP, Nuclear

Energy

Information

Service,

Nuclear

Information

& Resource

Service

(NIRS),

Public

Citizen, Inc

05/06/2005 ML051320285 2005/05/06-Exelon's Answer to Legal- Exelon NRC/ASLB 05200007 Intervenors' Motion to Amend Motion Generation P

Contention 3.1 Co, LLC,

Morgan, 52 Page(s) Lewis & ._ Bockius, LLP

B-135
Document Accession TltlelDescription Document Author Addressee Docket

Date Number Includes Est. Page Count Type Affillation(s) Affillation(s) Number

05/06/2005 ML051290002 2005/05/06-E-mail from Eddie R. Grant E-Mail, Exelon NRC 05200007

to John Segala Regarding May 6 Letter Letter Generation

on NRC Fee Payment. Co, LLC

4 Page(s)

05/11/2005 ML051390202 2005/05/11 -Letter from Paul M. Legal- Exelon Environme 05200007

Bessette to Shannon Fisk and Mauri T. Interrogatori Generation ntal Law &

Lemoncelli providing an update to es and Co, LLC, Policy Ctr,

disclosures pursuant to 10 CFR § Response Morgan, NRC/OGC

2.336(d) (Supplement 8) Lewis &

Bockius, LLP

4 Page(s)

05/17/2005 ML051430338 2005/05/17-Exelon Brief in Response to Legal-Brief Exelon NRC/OCM 05200007

Commission Memorandum and Order Generation

(CLI-05-09) Co, LLC,

Morgan,

28 Page(s) Lewis &

Bockius, LLP

05/24/2005 ML051540317 2005/05/24-Comment (32) of Marilyn C. General FR Exelon NRC/ADM/ 05200007

Kray on behalf of Exelon Nuclear on Notice Nuclear DAS/RDB

Review of Draft Environmental Impact Comment

Statement for Clinton ESP Site. Letter

46 Page(s) .

B-136
Document Accession Title/Description Document Author Addressee Docket Date Number Includes Est. Page Count Type Affillation(s) Affiliation(s) Number

06/0.3/2005 MlA-nr64043q qonAf/lnInl-If3rEar!y SiCt P ermit =sn}En-v-- :X. N u. --.. y~It% I's) MIIUMI11 CUIr1 NHUocu 0520000/

Application for the Clinton ESP Site, tal Report Nuclear ment

Submittal of Revision 1 to Exelon Control

Generation Company's Early Site Desk

Permit, Environmental Report, Figure

2.3-14 - Figure 2.3-25..

12 Page(s)

06/03/2005 I ML051640440 2005/06/03-Early Site Permit (ESP)

Application for the Clinton ESP Site,

Submittal of Revision 1 to Exelon

Generation Company's Early Site

Permit, Environmental Report, Figure

2.4-1 - Figure 2.5-9.

Environmen

tal Report

Exelon

Nuclear

NRC/Docu

ment

Control

Desk

05200007

12 Page(s)

I 06/03/2005 ML051640436 2005/06/03-Early Site Permit (ESP) Environmen Exelon NRC/Docu 05200007

Application for the Clinton ESP Site, tal Report Nuclear ment

Submittal of Revision 1 to Exelon Control

Generation Company's Early Site Desk

Permit, Environmental Report, Figure

2.3-7 - Figure 2.3-12.

6 Page(s) _ _

B-137
Document Accession Title/Description Document Author Addressee Docket

Date Number Includes Est. Page Count Type Affiliation(s) Afflilation(s) Number

06/03/2005 ML051640428 2005/06/03-Transmittal of Early Site Legal- Exelon NRC/Docu 05200007

Permit (ESP) Application for the Clinton Affidavit, Nuclear ment

ESP Site, Submittal of Revision 1 to Letter Control

Exelon Generation Company's Early Desk

Site Permit, Environmental Report,

Cover Letter.

3 Page(s)

06/03/2005 ML051640438 2005/06/03-Early Site Permit (ESP) Environmen Exelon NRC/Docu 05200007

Application for the Clinton ESP Site, tal Report Nuclear ment

Submittal of Revision 1 to Exelon Control

Generation Company's Early Site Desk

Permit, Environmental Report, Figure

2.3-13.

1 Page(s)

06/03/2005 ML051640441 2005/06/03-Early Site Permit (ESP) Environmen Exelon NRC/Docu 05200007

Application for the Clinton ESP Site, tal Report Nuclear ment

Submittal of Revision 1 to Exelon Control

Generation Company's Early Site Desk

Permit, Environmental Report, Figure

2.7-1 - Figure 2.7-18.

18 Page(s)

B-138
Document Accession Title/Description Document Author Addressee Docket Date Number Includes Est. Page Count Type Affiliation(s) Affiliation(s) Number

/q3n2nl I0 ML 051 64011% 2005/06%03-Early site Perfiii (ESP) Environmen Exelon NRC/Docu 05200007 Application for the Clinton ESP Site, tal Report Nuclear ment

Submittal of Revision 1 to Exelon Control

Generation Company's Early Site Desk

Permit, Environmental Report,

Environmental Consequences of the

Proposed Action - Table B-1.

60 Page(s)

06/03/2005 ML051640446 2005/06/03-Early Site Permit (ESP) Environmen Exelon NRC/Docu 05200007

Application for the Clinton ESP Site, tal Report Nuclear ment

Submittal of Revision 1 to Exelon Control

Generation Company's Early Site Desk

Permit, Environmental Report,

Environmental Measurement and

Monitoring Programs - Figure 9.2-4.

212 Page(s)

06/03/2005 ML051640444 2005/06/03-Early Site Permit (ESP) Environmen Exelon NRC/Docu 05200007

Application for the Clinton ESP Site, tal Report Nuclear ment

Submittal of Revision 1 to Exelon Control

Generation Company's Early Site Desk

Permit, Environmental Report,

Environmental Impacts of Station

Operation - Figure 5.3-2.

127 Page(s)

B-1 39
Document Accession Title/Description Document Author Addressee Docket

Date Number Includes Est. Page Count Type Affillation(s) Affillation(s) Number

06/03/2005 ML051640434 2005/06/03-Early Site Permit (ESP) Environmen Exelon NRC/Docu 05200007

Application for the Clinton ESP Site, tat Report Nuclear ment

Submittal of Revision 1 to Exelon Control

Generation Company's Early Site Desk

Permit, Environmental Report, Figure

2.2-6 - Figure 2.3-6.

9 Page(s) .

06/03/2005 ML051640431 2005/06/03-Early Site Permit (ESP) Environmen Exelon NRC/Docu 05200007

Application for the Clinton ESP Site, tal Report Nuclear ment

Submittal of Revision 1 to Exelon Control

Generation Company's Early Site Desk

Permit, Environmental Report,

Contents - Figure 2.2-5.

245 Page(s)

06/03/2005 ML051640442 2005/06/03-Early Site Permit (ESP) Environmen Exelon NRC/Docu 05200007

Application for the Clinton ESP Site, tal Report Nuclear ment

Submittal of Revision 1 to Exelon Control

Generation Company's Early Site Desk

Permit, Environmental Report, Plant

Description - Figure 4.5-1.

120 Page(s)

B-140
Date Number Includes Est. Page Count Type Affiliation(s) Affillation(s) Number

06/30/2005 ML051920121 n of - I Ro'uer rs Lsy;- Exeion NRC;/Docu 05200007 Aid for Revision 1 to Exelon Generation Affidavit, Nuclear ment

Company's Early Site Permit, Letter Control

Environmental Report. Desk

l __ 3 Page(s)

06/30/2005 ML051920127 2005/06/30-Reviewers Aid for Revision Environmen Exelon NRC/Docu 05200007

1 to Exelon Generation Company's tat Report Nuclear ment

Early Site Permit, Environmental Control

Report. Desk

95 Page(s)

07/14/2005 ML051960277 2005/07/14-E-Mail re: Revised DSER E-Mail, Exelon Corp NRC/NRR/ 05200007

Response. Legal- DRIP/RNR

Affidavit, P

64 Page(s) Letter

07/14/2005 ML052150136 Revised Response to Draft Safety Letter Exelon NRC/Docu 05200007

Evaluation Report (DSER) Items re: Nuclear ment Letter, U.S. NRC (W. D. Beckner) to Control Exelon Generation Company, LLC, (M. Desk Kray), dated February 10, 2005, Draft

Safety Evaluation Report for the Exelon

ESP Application.

62 Page(s)

B-141
Document Accession Title/Description Document Author Addressee Docket

Date Number Includes Est. Page Count Type Affiliation(s) Affillation(s) Number

07/18/2005 ML051930155 Clinton ESP Quality Assurance Letter NRC/NRR/D Exelon 05200007

Assessment and Resolution of RIP/RNRP Generation

Confirmatory Item (Cl) and Open Item Co, LLC

(_8 ) 17.1-1.

8 Pagefs)

08/03/2005 1 ML052210410 2005/08/03-Letter from Paul M.

Bessette to Shannon Fisk and Mauri T.

Lemoncelli enclosing updates to

disclosures with respect to Contention

3.1 (Supplement 9)

LegalInterrogatori

es and

Response

Exelon

Generation

Co, LLC,

Morgan,

Lewis &

Bockius, LLP

Environme

ntal Law &

Policy Ctr,

NRC/OGC

05200007

35 Page(s)

B-142
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08/12/200m5 n.Mq60A16R onn5a0811-lntvenom Witia-% s' lar Legai-Briet Blue Ridge NRC/OCM 05200007

Review of the Atomic Safety and Environment

Licensing Board's Dismissal of al Defense

Contention 3.1 and Rejection of League, Intervenors' Proposed Amended Exelon

Contention 3.1 Generation

Co, LLC, 23 Page(s) Harmon,

Curran,

Spielberg &

Eisenberg,

LLP, Nuclear

Energy

Information

Service,

Nuclear

Information

& Resource

Service

(NIRS)

08/16/2005 ML051540054 Revised Schedule for Review of the Letter NRC/NRR/D Exelon 05200007

Exelon Early Site Permit Application for RIP/RNRP Generation

the Exelon ESP Site. Co, LLC

10 Page(s)

B-143
Document Accession Title/Description Document Author Addressee Docket

Date Number Includes Est. Page Count Type Affillation(s) Affiliation(s) Number

08/19/2005 ML052300522 Potential Open Items for the Letter NRC/NRR/D Exelon 05200007

Supplemental Draft Safety Evaluation RIP/RNRP Generation

Report for the Exelon ESP Application. Co, LLC

14 Page(s)

08/22/2005 ML052410437 2005/08/22-Exelon Generation Legal-Brief Exelon NRC/OCM 05200007

Company's Answer in Opposition to Generation

Intervenors' Petition for Review Co, LLC,

Morgan, 30 Page(s) Lewis &

Bockius, LLP

08/26/2005 ML052310469 Cover Letter to M. Kray re: Draft Safety NRC/NRR/D Exelon 05200007

Supplemental Draft Safety Evaluation Evaluation RIP/RNRP Generation

Report for the Exelon Early Site Permit Report Co, LLC

Application. (DSER),

Letter

4 Page(s)

08/31/2005 ML052310478 Supplemental Draft Safety Evaluation Draft Safety NRC/NRR/D Exelon 05200007

Report for the Exelon Early Site Permit Evaluation RIP/RNRP Generation

Application. Report Co, LLC

(DSER)

125 Page(s)

B-144
Document Accession Title/Description Document Author Addressee | Docket Date Number Includes Est. Page Count Type Affillation(s) Affiliation(s) Number

09/07/2005 ML052.59q00n7 2005!09/07-L-ctt ',.,r Ir.- om1-..I Paul M1. Leyai- Exeion Environme 05200007 Bessette to Shannon Fisk and Mauri T. Interrogatori Generation ntal Law &

Lemoncelli providing updates to es and Co, LLC, Policy Ctr, disclosures with respect to Contention Response Morgan, NRC/OGC 3.1 (Supplement 10) Lewis &

Bockius, LLP

4 Page(s)

09/30/2005 MLO52860134 Early Site Permit (ESP) Application for Letter Exelon NRC/Docu 05200007 the Clinton ESP Site - Revised Nuclear ment

Response to Draft Safety Evaluation Control

Report (DSER) Items. Desk

6 Page(s) .

10/11/2005 ML052860325 10/11/05 - Request for Additional

Information (RAI) Regarding the

Environmental Portion of the Early Site

Permit Application for the Exelon

Generation Company Site (TAC No.

MC1 125).

8 Page(s)

Letter,

Request for

Additional

Information

(RAI)

NRC/NRR/D

RIP/RLEP

Exelon

Generation

Co, LLC

05200007

_

B-145

,
Document Accession Title/Description Document Author Addressee Docket Date Number Includes Est. Page Count Type Affiliation(s) Affiliation(s) Number

10/11/2005 ML052860274 10/11/05 - Summary of Telephone Meeting NRC/NRR/D Exelon 05200007

Conference Call Held on September Summary, RIP/RLEP Generation

19, 2005 Between the U.S. Nuclear Note to File Co, LLC

Regulatory Commission (NRC) and the incl Telcon

Illinois Department of Natural Record,

Resources (IDNR) Regarding the Verbal

Review of the Exelon Early Site Permit Comm

(ESP).

6 Page(s)

10/11/2005 ML052860253 10/11/05 - Summary of Telephone Note NRC/NRRID Exelon 05200007

Conference Call Held on September RIP/RLEP Generation

13, 2005 Between the U.S. Nuclear Co, LLC

Regulatory Commission (NRC) and the

Illinois Environmental Protection

Agency (EPA) Regarding the Review of

the Exelon Early Site Permit (ESP).

6 Page(s)

10/12/2005 1 ML052930270 Early Site Permit Application for the

Clinton ESP Site, ESP Site Soil Hazard

Data.

Letter Exelon

Nuclear

NRC/Docu

ment

Control

Desk

05200007

6 Page(s) I _ . .

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10/27/2005 ML0o3On7nrnR Early Site Peormt (CSP) Applicatbor- for etter Exelon NRC/Docu 05200007

the Clinton ESP Site, Revised Nuclear ment Response to Request for Additional Control Information Letter No. 12. Desk

10 Page(s)

10/31/2005 ML053120131 Clinton ESP Site, Responses to Graphics Exelon NRC/Docu 05200007 Supplemental Draft Safety Evaluation incl Charts Nuclear ment

Report (DSER) Items. and Tables, Control

Letter, Map Desk 285 Page(s)

11/23/2005 ML053420057 Submittal of Revision 1 to Exelon Letter Exelon NRC/Docu 05200007 Generation Company's Early Site Generation ment

Permit Application. Co, LLC Control

Desk

4 Page(s)

12/13/2005 ML053540218 Response to Request for Additional Legal- Exelon NRC/Docu 05200007 Information (RAI) - Exelon Early Site Affidavit, Nuclear ment Permit (ESP) Application for the Clinton Letter Control

ESP Site. Desk

4 Page(s)

12/21/2005 ML060030484 Early Site Permit Application for the Letter Exelon NRC/Docu 05200007

Clinton ESP Site, Revised Response to Nuclear ment Draft Safety Evaluation Report Open Control

Items. Desk

13 Page(s)

B-147
Document Accession Title/Description Document Author Addressee Docket

Date Number Includes Est. Page Count Type Affillation(s) Affillation(s) Number

01/10/2006 ML060460042 Clinton ESP Site - Submittal of Revision Legal- Exelon NRC/Docu 05200007

2 to the Exelon Generation Company's Affidavit, Nuclear. ment

Early Site Permit Application Letter Control

Desk

B-1 48
APPENDIX C

References

American National Standards Institute (ANSI)

----- , ANSI A58.1, "Minimum Design Loads for Buildings and Other Structures," 1982.

----- , ANSI N45.2, "Quality Assurance Program Requirements for Nuclear Facilities,"

1977.

American National Standards Institute and American Nuclear Society (ANSI/ANS)

----- , ANSI/ANS-2.8, "American National Standard for Determining Design Basis

Flooding at Power Reactor Sites," 1992.

Advanced National Seismic System (ANSS)

ANSS catalog for 1995 through June 2002, <http://www.anss.org>.

American Society of Civil Engineers (ASCE)

Youd, T. L. et al., "Liquefaction Resistance of Soils: Summary Report from the 1996 NCEER

and 1998 NCEER/NSF Workshops on Evaluation of Liquefaction of Soils," ASCE Journal of

Geotechnical and Environmental Engineering, Volume 127, No. 10, October 2001.

American Society of Civil Engineers (ASCE) / Structural Engineering Institute (SEI)

-, ASCE/SEI 43-05, "Seismic Design Criteria for Structures, Systems, and

Components in Nuclear Facilities and Commentary," 2005.

American Society of Civil Engineers and Structural Engineering Institute (SEI/ASCE)

SEI/ASCE 7-98, "Minimum Design Loads for Buildings and Other Structures,"

March 200)0.

American Society of Mechanical Engineers (ASME)

------ , ASME NQA-1 -2000, "Quality Assurance Requirements for Nuclear Facility

Applicatio is," 2000.

C-1
American Society for Testing and Materials (ASTM)

ASTM D3740, "Standard Practice for Minimum Requirement for Agencies

Engaged in the Testing and/or Inspection of Soil and Rock as Used in Engineering Design and

Construction," 2001.

--- --- , ASTM D4945, "Standard Test Method for High-Strain Dynamic Testing of Piles,"

2000.

, ...-- ASTM D1586-99, "Standard Test Method for Penetration Test and Split-Barrel

Sampling of Soils," January 10, 1999.

----- ASTM D1 587-00, "Standard Practice for Thin-Walled Tube Sampling of Soils for

Geotechnical Purposes," August 10, 2000.

----- , ASTM D2113-99, "Standard Practice for Rock Core Drilling and Sampling of

Rock for Site Investigations," January 10, 1999.

American Society of Heating, Refrigerating and Air-Conditioning Engineers (ASHRAE)

-- --- , "2001 ASHRAE Handbook -Fundamentals," July 2001.

Electric Power Research Institute (EPRI)

, ...- "Seismic Hazard Methodology for the Central and Eastern United States,"

Volumes 5-10, EPRI: Palo Alto, California, July 1986.

--- , --- 1008910, "CEUS Ground Motion Project: Model Development and Results,'

EPRI: Palo Alto, California, August 2003.

--- --- TR-1 02293, "Guidelines for Determining Design Basis Ground Motions,"

Volumes 1-5, EPRI: Palo Alto, California, May 1993.

Johnston, A. C., et al. TR-102261-V1, 'The Earthquakes of Stable Continental Regions:

Volume 1 - Assessment of Large Earthquake Potential," EPRI: Palo Alto, California, 1994.

Exelon Generation Company (EGC)

--- ---, Early Site Permit (ESP) Application for the EGC ESP Site, Revision 0,

September 2003.

------ ,ESP Application for the EGC ESP Site, Revision 1, November 2005.

--- --- ,ESP Application for the EGC ESP Site, Revision 2, January 2006.

C-2
--- --- , ESP Application for the EGC ESP Site, Revision 3, March 2006.

--- --- , ESP Application for the EGC ESP Site, Revision 4, April 2006.

----- , AP-AA-1 000, Revision 0, "Early Site Permit Project Quality Assurance

Instructions," Exelon Nuclear: Kennett Square, PA, September 7, 2004.

"Emergency Plan for the Exelon Generation Company, LLC Early Site Permit,"

Exelon Generation Company, LLC.: Chicago, Illinois, (ADAMS Accession Nos. ML032721599,

ML032721600, ML0327211601, ML032721602).

----- , Letter from Marilyn C. Kray, Exelon Nuclear, to U.S. NRC, "Response to Draft

Safety Evaluation Report (DSER) Items," April 26, 2005 (ADAMS Accession No.

ML051 230326).

Federal Emergency Management Agency (FEMA)

Federal Radiological Emergency Response Plan (1996).

Illinois Compiled Statues (ILCS)

Division of Nuclear Safety Law, 20 ILCS 2005/2005-1 (amended June 2001),

<http://wNww.state.il.us/idns/html/legaVstatutes/genadm/enable.htm>.

Illinois Emergency Management Agency Act, 20 ILCS 3305 (amended June 2002),

<http://www.state.il.us/iema/Laws/l EMAact.htm>.

Illinois Nuclear Facility Safety Act, 420 ILCS 10 (1992),

<http://www.state.il.us/idns/htmVlegal/statutes/nucpwr/nucfac.htm>.

Illinois Nuclear Safety Preparedness Act, 420 ILCS 5 (amended June 2002),

<http://wwvw.state.il.us/idns/html/lega Vstatutes/genadm/inspa.htm>.

Radiation Protection Act of 1990,420 ILCS 40 (amended August 2001)

<http://www.state.il.us/idns/html/legal/statutes/genadrm/radpro.htm>.

Illinois State Climatologist Office (ISCO)1

-, "Climate of Illinois," <http://www.sws.uiuc.edu/atmos/statecli/GeneraV

Illinois-clirnate-narrative.pdf> (December 1, 2004), (ADAMS Accession No. ML043370319).

'Data provided by the Illinois State Climatologist's Office, a part of the Illinois State Water Survey

(ISWS) located in Champaign, Peoria, Carbondale, and Chicago, Illinois, and on the web at

www.sws.'iuc.edu/atmos/statecli.

C-3
"Historical Climate Summary - 111743 Clinton, IL,"

<http://www.sws.uiuc.edu/atmos/

statecli/Summary/1 11743.htm> (December 3, 2004), (ADAMS Accession No. ML043410077).

"Historical Climate Summary - 112193 Decatur, IL,"

<http://www.sws.uiuc.edu/atmos/

statecli/Summary/1 12193.htm> (December 1, 2004), (ADAMS Accession No. ML043370363).

"Historical Climate Summary - 115079 Lincoln, IL,"

<http://www.sws.uiuc.edu/atmos/

statecli/Summary/1 15079.htm> (December 1, 2004), (ADAMS Accession No. ML04337031 1).

,"Historical Climate Summary - 116711 Peoria WSO Airport, IL,"

<http://www.sws.uiuc.edu/atmos/statecli/Summary/1 16711 .htm> (December 1, 2004), (ADAMS

Accession No. ML043370337).

"Historical Climate Summary - 118179 Springfield WSO AP, IL,"

<http://www.sws.uiuc.edu/atmos/statecli/Summary/1 18179.htm> (December 1, 2004), (ADAMS

Accession No. ML043370356).

"Illinois Records," <http://www.sws.uiuc.edu/atmos/stateclilGeneral/records.htm>

(December 1, 2004), (ADAMS Accession No. ML043370323).

Lawrence Livermore National Laboratory (LLNL)

------- , Lawrence Livermore National Laboratory (LLNL), "Eastern Seismic Hazard

Characterization Update," 1993.

National Climatic Data Center (NCDC)

-- ----, "Central Illinois Divisional Normals-Temperature, Period 1971-2000,"

Climatography of the United States, No. 85, NCDC: Asheville, North Carolina, June 15, 2002.

,"Engineering Weather Data CDROM," Version 1.0, NCDC: Asheville, North

Carolina, December 23, 1999.

,"Peoria, Illinois, 2003 Local Climatological Data, Annual Summary with

Comparative Data," NCDC: Asheville, North Carolina, 2003.

"Severe Thunderstorm Climatology, Total Threat," National Severe Storms

Laboratory, <http://www.nssl.noaa.gov/hazard/totalthreat.html> (December 1, 2004), (ADAMS

Accession No. ML043370314).

"Solar and Meteorological Surface Observational Network (SAMSON) for

Central U.S. CDROM," NCDC: Asheville, North Carolina, September 1993.

C-4
"Springfield, Illinois, 2003 Local Climatological Data, Annual Summary with

Comparative Data," NCDC: Asheville, North Carolina, 2003.

"Temperature Extremes," <http://www.ncdc.noaa.gov/oa/climate/severeweather/

temperatures.html> (November 29, 2004), (ADAMS Accession No. ML043370330).

National Oceanic and Atmospheric Administration (NOAA)

--- --- , Hydrometeorological Report No. 51, "Probable Maximum Precipitation

Estimates. United States East of the 105th Meridian," NOAA: Washington, D.C., June 1978.

--- --- ,Hydrometeorological Report No. 52, "Application of Probable Maximum

Precipitation Estimates - United States East of the 105th Meridian," NOAA: Washington, D.C.,

August 1982.

Hydrometeorological Report No. 53, "Seasonal Variation of 10-Square-Mile

Probable Maximum Precipitation Estimates. United States East of the 105th Meridian," NOAAk:

Washington, D.C., April 1980.

"Tsunami: The Great Waves," NOAA: Washington, D.C., 2002,

<http://www.prh.noaa.gov/itic/library/pubs/great waves/tsunami_great-waves.html>.

"Unit Hydrograph (UHG) Technical Manual," National Weather Service, Office of

Hydrology, Hydrologic Research Laboratory and National Operational Hydrologic Remote

Sensing Center, <http://www.nohrsc.noaa.gov/technology/gis/uhg-manual.html> (April 17,

2006).

Seismological Society of America (SSA)

Atkinson, G.M. and D.M. Boore, "Ground Motion Relations for Eastern North America," Bulletin

of the Seismological Society of America, Vol. 85, No. 1, pp. 17-30, 1995.

Bakun , W.H., and M.G. Hopper, 'The 1811-12 New Madrid, Missouri, and the 1886 Charleston,

South Carolina, Earthquakes," Bulletin of the Seismological Society of America, 2003 (in press).

State of Illinois

"Concepts of Operations," The Illinois Plan for Radiological Accidents (IPRA),

Volume I, State of Illinois: Springfield, Illinois, May 2001.

"Clinton," The Illinois Plan for Radiological Accidents (IPRA), Volume Vill, State

of Illinois: Springfield, Illinois, July 2001.

C-5
U.S. Army Corps of Engineers

--- --- , EM 1110-2-1100 (Revision 1), "Coastal Engineering Manual," Department of the

Army: Washington, D.C., July 2003.

--- --- ,EM 1110-2-1411, "Standard Project Flood Determinations," Department of the

Army: Washington, D.C., March 1, 1965.

- , EM 11110-2-1612, "Engineering and Design - Ice Engineering," Department of

the Army: Washington, D.C., October 30, 2002.

"HEC-1 Download," U.S. Army Corps of Engineers Hydrologic Engineering

Center, 1998, <http://www.hec.usace.army.mil/software/legacysoftware/hec1/hecldownload.htm> (September 1, 2004).

----- , "Ice Jam Database," <http://www.crrel.usace.army.mil/ierd/ijdb/> (September 16,

2004).

----- , "Major Dams of the United States," <http://nationalatlas.gov/damsm.html> (July

27,2004).

------ "National Inventory of Dams," <http:Hlcrunch.tec.army.mil/nid/webpages/nid.cfm>

(July 27, 2004).

--- ---, Technical Manual 5-1300, "Structures to Resist the Effects of Accidental

Explosions," Department of the Army: Washington, D.C., November 19, 1990.

U.S. Atomic Energy Commission (AEC)

--- -- , Technical Information Document (TID)-14844, "Calculation of Distance Factors

for Power and Test Reactor Sites," AEC: Washington, D.C., March 1962 (ADAMS Accession

No. ML021750625).

U.S. Census Bureau

, ...- "Census 1990," U.S. Census Bureau: Washington, D.C., 1990,

<http://www.census.gov/main/www/cen1 990.html>.

, ...- "Census 2000," U.S. Census Bureau: Washington, D.C., 2000,

<http://www.census.gov/main/www/cen2000.html>.

U.S. Code of Federal Regulations

--- --- Title 10, Energy, Part 20, "Standards for Protection Against Radiation."

C-6
-- -- ,Title 10, Energy, Part 21, "Reporting of Defects and Noncompliance."

Title 10, Energy, Part 50, "Domestic Licensing of Production and Utilization

Facilities."

-Ttle 10, Energy, Part 52, "Early Site Permits; Standard Design Certifications;

and Combined Licenses for Nuclear Power Plants."

Title 10, Energy, Part 71, "Packaging and Transportation of Radioactive

Material."

,Title 10, Energy, Part 73, "Physical Protection of Plants and Materials."

Title 10, Energy, Part 100, "Reactor Site Criteria."

Title 15, Commerce and Foreign Trade, Part 950, "Environmental Data and

Information."

Title 49, Transportation, Part 173, "Shippers-General Requirements for

Shipments and Packagings."

U.S. Environmental Protection Agency (EPA)

- -, EPA 400-R-92-001, "Manual of Protective Action Guides and Protective Actions

for Nuclear Incidents," EPA: Washington, D.C., May 1992.

U.S. Geological Survey

",Clinton, Illinois, 7.5-Minute Quadrangle, Topographic Map," U.S. Geological

Survey: Reston, Virginia, 2001.

,Daily Streamflow for the Nation, USGS gauge 05578500, SALT CREEK NEAR

ROWELL, IL,"

<http://waterdata.usgs.gov/il/nwis/nwisman/?site no=05578500&agencyscd=USGS> (August

18, 2004).

-, "Daily Streamf low for the Nation, USGS gauge 05579000, SALT CREEK NEAR

KENNEY, IL,"

<http://wa terdata.usgs.gov/il/nwis/nwisman/?siteno=05579000&agencyscd=USGS> (August

18, 2004).

-, "Heyworth, Illinois, 7.5-Minute Quadrangle, Topographic Map," U.S. Geological

Survey: Reston, Virginia, 2000.

"Maroa, Illinois, 7.5-Minute Quadrangle, Topographic Map," U.S. Geological

Survey: Reston, Virginia, 1990.

C-7
"Farmer City North, Illinois, 7.5-Minute Quadrangle, Topographic Map," U.S.

Geological Survey: Reston, Virginia, 1990.

"Farmer City South, Illinois, 7.5-Minute Quadrangle, Topographic Map," U.S.

Geological Survey: Reston, Virginia, 1990.

"LeRoy, Illinois, 7.5-Minute Quadrangle, Topographic Map," U.S. Geological

Survey: Reston, Virginia, 1990.

"Peak Streamf low for the Nation, USGS 05578500 SALT CREEK NEAR

ROWELL, IL,"

<http://nwis.waterdata.usgs.gov/nwis/peak?siteno=05578500&agency-cd=USGS&format=htm

I> (August 19, 2004).

,"U. S. Geological Survey NWISWeb Data for the Nation,"

<http:l/waterdata.usgs.gov/nwis/> (September 16,2004).

'Weldon East, Illinois, 7.5-Minute Quadrangle, Topographic Map," U.S.

Geological Survey: Reston, Virginia, 1990.

-- ----, 'Weldon West, Illinois, 7.5-Minute Quadrangle, Topographic Map," U.S.

Geological Survey: Reston, Virginia, 1990.

- , "DeWitt, Illinois, 7.5-Minute Quadrangle, Topographic Map," U.S. Geological

Survey: Reston, Virginia, 1979.

Frankel, A. D., et al., Open-File Report 96-532, "National Seismic-Hazard Maps, Documentation

June 1996," USGS, 1996, <http://eqhazmaps.usgs.gov/hazmapsdoc/Junedoc.pdf>.

Frankel, A. D., et al., Open-File Report 02-420, "Documentation for the 2002 Update of the

National Seismic Hazard Maps," USGS: Reston, Virginia, 2002,

<http://pubs.usgs.gov/of/2002/ofr-02-420/OFR-02-420.pdf>.

U.S. Nuclear Regulatory Commission (NRC)

Commission Papers

--- --- ,SECY-93-087, "Policy, Technical , Licensing Issues Pertaining to Evolutionary

and Advanced Light-Water Reactor (ALWR) Designs, 1993 (ADAMS Accession

No. ML003708021).

Inspection Reports

--- --- ,Inspection Report 0520007/2004001, "Exelon Generation Company, LLC - NRC

Inspection of Applicant and Contractor Quality Assurance Activities Involved with Preparation of

the Application for an Early Site Permit," NRC: Washington, D.C., February 20, 2004 (ADAMS

Accession No. ML040540622).

C-8
NUREG-Series Reports

NUREG-0654/FEMA-REP-1, Revision 1, "Criteria for Preparation and Evaluation

of Radiological Emergency Response Plans and Preparedness in Support of Nuclear Power

Plants," Washington, D.C., November 1980.

--- --- , NUREG-06541FEMA-REP-1, Revision 1, Supplement 2, "Criteria for Preparation

and Evaluation of Radiological Emergency Response Plans and Preparedness in Support of

Nuclear Power Plants - Criteria for Emergency Planning in an Early Site Permit Application -

Draft Report for Comment," NRC: Washington, D.C., April 1996.

--- --- , NUREG-0654/FEMA-REP-1, Revision 1, Supplement 3, "Criteria for Preparation

and Evaluation of Radiological Emergency Response Plans and Preparedness in Support of

Nuclear Power Plants - Criteria for Protective Action Recommendations for Severe Accidents -

Draft Report for Interim Use and Comment," NRC: Washington, D.C., July 1996.

--- ---, NUREG-0696, "Functional Criteria for Emergency Response Facilities - Final

Report," NRC: Washington, D.C., February 1981.

-- --- , NUREG-0800, Revision 3, "Standard Review Plan for the Review of Safety

Analysis Reports for Nuclear Power Plants," NRC: Washington, D.C., July 1981.

--- *--, NUREG-1742, "Perspectives Gained from the IPEEE Program," 2002.

, NUREG/CR-4013, "LADTAP Il-Technical Reference and User Guide," April

1986.

- , NUREG/CR-4653, "GASPAR Il-Technical Reference and User Guide," March

1987.

- - -, NUREG/CR-4831, "State of the Art in Evacuation Time Estimate Studies for

Nuclear F'ower Plants," NRC: Washington, D.C., March 1992.

,NUREG/CR-6372, "Recommendations for Probabilistic Seismic Hazard

Analysis: Guidance on Uncertainty and Use of Experts," NRC: Washington, D.C., November

1997.

---- , NUREG/CR-6728, 'Technical Basis for Revision of Regulatory Guidance on

Design Ground Motions: Hazard and Risk Consistent Ground Motion Spectral Guidelines,"

2001.

Draft Regilatory Guides

------ , Draft Regulatory Guide DG-1 105, "Procedures and Criteria for Assessing

Seismic Soil Liquefaction at Nuclear Power Plant Sites," NRC: Washington, D.C., March 31,

2001 (ADAMS Accession No. ML01 0650295).

C-9
Regulatory Guides

- Regulatory Guide 1.3, "Assumptions Used for Evaluating the Potential

Radiological Consequences of a Loss-of-Coolant Accident for Boiling Water Reactors," June

1974 (ADAMS Accession No. ML003739601).

--- --- , Regulatory Guide 1.25, "Assumptions Used for Evaluating the Potential

Radiological Consequences of a Fuel Handling Accident in the Fuel Handling and Storage

Facility for Boiling and Pressurized Water Reactors," March 1972.

--- --- , Regulatory Guide 1.27, "Ultimate Heat Sink for Nuclear Power Plants," NRC:

Washington, D.C., January 1976 (ADAMS Accession No. ML003739969).

--- --- ,Regulatory Guide 1.29, Revision 3, "Seismic Design Classification," NRC:

Washington, D.C., September 1978 (ADAMS Accession No. ML003739983).

--- --- ,Regulatory Guide 1.59, Revision 2, "Design Basis Floods for Nuclear Power

Plants," NRC: Washington, D.C., August 1977 (ADAMS Accession No. ML003740388).

Regulatory Guide 1.60, Revision 1, "Design Response Spectra for Seismic Design of

Nuclear Power Plants," NRC: Washington, D.C., December 1973.

,Regulatory Guide 1.70, Revision 3, "Standard Format and Content of Safety

Analysis Reports for Nuclear Power Plants - LWR Edition," NRC: Washington, D.C., November

1978 (ADAMS Accession Nos. ML003740072, ML003740108, & ML003740116).

--- --- ,Regulatory Guide 1.78, Revision 1, "Evaluating the Habitability of a Nuclear

Power Plant Control Room During a Postulated Hazardous Chemical Release," NRC:

Washington, D.C., December 2001 (ADAMS Accession No. ML013100014).

--- --- ,Regulatory Guide 1.91, Revision 1, "Evaluations of Explosions Postulated to

Occur on Transportation Routes Near Nuclear Power Plants," NRC: Washington, D.C.,

February 1978 (ADAMS Accession No. ML003740286).

--- --- , Regulatory Guide 1.102, Revision 1, "Flood Protection for Nuclear Power

Plants," NRC: Washington, D.C., September 1976 (ADAMS Accession No. ML003740308).

--- --- ,Regulatory Guide 1.109, "Calculation of Annual Doses to Man From Routine

Releases of Reactor Effluents for the Purpose of Evaluating Compliance with 10 CFR Part 50,

Appendix I," October 1977 (ADAMS Accession No. ML003740384).

--- --- ,Regulatory Guide 1.111, "Methods for Estimating Atmospheric Transport and

Dispersion of Gaseous Effluents in Routine Releases from Light-Water-Cooled Reactors," July

1977 (ADAMS Accession No. ML003740354).

--- --- ,Regulatory Guide 1.113, "Accidental and Routine Reactor Releases for the

Purpose of Implementing Appendix I," NRC: Washington, D.C., April 1977 (ADAMS Accession

No. ML003740390).

C-10
Regulatory Guide 1.125, Revision 1, "Physical Models for Design and Operation

of Hydraulic Structures and Systems for Nuclear Power Plants," NRC: Washington, D.C.,

October 1978 (ADAMS Accession No. ML003739388).

-, Regulatory Guide 1.132, Revision 1, "Site Investigations for Foundations of

Nuclear Power Plants," NRC: Washington, D.C., March 1979 (ADAMS Accession No.

ML003740350).

Regulatory Guide 1.138, "Laboratory Investigations of Soils for Engineering

Analysis and Design of Nuclear Power Plants," NRC: Washington, D.C., April 30,1978

(ADAMS' Accession No. ML003740184).

--- --- , Regulatory Guide 1.145, "Atmospheric Dispersion Models for Potential Accident

Consequence Assessments at Nuclear Power Plants," November 1982 (ADAMS Accession

No. MLC003740205).

--- ---, Regulatory Guide 1.165, "Identification and Characterization of Seismic Sources

and Determination Safe Shutdown Earthquake Ground Motion," NRC: Washington, D.C., March

1997 (ADAMS Accession No. ML003740084).

--- --- , Regulatory Guide 1.183, "Alternative Radiological Source Terms for Evaluating

Design-E3asis Accidents at Nuclear Power Reactors," July 2000 (ADAMS Accession

No. ML003716792).

--- ---, Regulatory Guide 1.198, "Procedures and Criteria for Assessing Seismic Soil

Liquefaction at Nuclear Power Plant Sites," NRC: Washington, D.C., November 2003 (ADAMS

Accession No. ML033280143).

Regulatory Guide 4.4, "Reporting Procedure for Mathematical Models Selected

to Predict Heated Effluent Dispersion in Natural Water Bodies," NRC: Washington, D.C., May

1974 (ADAMS Accession No. ML003739535).

--- *-- , Regulatory Guide 4.7, Revision 2, "General Site Suitability Criteria for Nuclear

Power Stations," NRC: Washington, D.C., April 1998 (ADAMS Accession No. ML003739894).

Other NRFC Documents

Memorandum from Harold R. Denton, NRC, to R. R. Maccary, NRC, Subject:

Site Analysis Branch Position - Winter Precipitation Loads, March 24,1975 (ADAMS Accession

No. MLOiE0630277).

-, Memorandum from R. N. Gardner, NRC, to J. E. Lyons, NRC, Subject: PreApplication Site Visit to Clinton Nuclear Station to Observe Early Site Permit (ESP) PreApplication Subsurface Investigation Activities (Project No. 718), September 9, 2002 (ADAMS

Accession No. ML022530396).

NRR Review Standard, RS-002, "Processing Applications for Early Site

Permits," NRC: Washington, D.C., May 3, 2004, (ADAMS Accession No. ML040700236).

C-1I
- June 22, 2004, Letter from James E. Lyons, NRC to Adrian Heymer, NEI,

Subject: Applicability of 10 CFR Part 21 (ADAMS Accession No. ML040430041).

--- --- October 26, 2004, Summary of September 9, 2004, Meeting with NEI to Discuss

Emergency Planning (EP) Aspects of Early Site Permit (ESP) Reviews, Applicability of 10 CFR

Part 21 to ESP Applicants and Holders, and Inclusion of Plant Parameters in ESPs (ADAMS

Accession No. ML042610277).

--- --- , December 28, 2004, Summary of November 10, 2004, Meeting with the Nuclear

Energy Institute (NEI) to Discuss Applicability of 10 CFR Part 21 to ESP Applicants and

Holders, Emergency Planning (EP) Aspects of Early Site Permit (ESP) Reviews, Inclusion of

Plant Parameters in ESPs, and ESP/Combined License (COL) Interface Issues (ADAMS

Accession No. ML043290195).

Other References

Corporate Authors

CH2M Hill, DEL-01-4, Rev. 4, "Project Quality Plan for Exelon Early Site Permit," CH2M Hill:

Idaho Falls, Idaho, December 2002.

HMM Associates, Inc., "Evacuation Time Estimates for the Clinton Power Station".

HMM Associates, Inc.: Bedford, New Hampshire, July 1993, (ADAMS Accession

No. ML0409790812).

Interagency Advisory Committee on Water Data. Bulletin 17B , "Guidelines for Determining

Flood Flow Frequency," Water Resources Council, U.S. Department of the Interior: Reston,

Virginia, 1981.

Platts, "POWERmap Geographic Information System Spatial Data," Platts: Boulder, Colorado,

2004.

Individual Authors

Bakun, W. H. and M. G. Hopper, 'The 1811-1812 New Madrid, Missouri, and the 1886

Charleston, South Carolina Earthquakes," Bulletin of the Seismological Society of America,

Vol. 94, No. 1, pp. 64-75, 2004.

Johnston, A. C., "Seismic Moment Assessment of Earthquake in Stable Continental Regions -

Ill. New Madrid 1811-1812, Charleston 1886 and Lisbon 1755," Geophysical Journal

International, Vol. 126, pp. 314-344,1996.

McNulty, W.E., and S.F. Obermeier, "Liquefaction Evidence for at least Two Strong Holocene

Paleoearthquakes in Central and Southwestern Illinois, USA," Environmental and Engineering

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C-12
Mitchell, W.D., "Unit Hydrographs in Illinois, Illinois Division of Waterways (IDOW) and U.S.

Geological Survey (USGS)," 1948.

Silva, W. J., et al., "Development of Regional Hard Rock Attenuation Relations for Central and

Eastern North America," Pacific Engineering and Analysis, El Cerrito, CA. 2002.

Tuttle et al., 'The Earthquake Potential of the New Madrid Seismic Zone," Bulletin of the

Seismolcgical Society of America, Vol. 92, No. 6, pp. 2080-2089, August 2002.

Chow, V. T. Handbook of Applied Hydrology, McGraw-Hill: New York, 1964.

Chow, V. T. Open Channel Hydraulics, McGraw-Hill: New York, 1959.

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Hutter, Hydrodynamics of Lakes, pp. 153-207, Springer Verlag: New York, 1984.

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Extreme Ice Loads," National Climatic Data Center: Asheville, North Carolina, December 2002.

Korshover, J., NOAA Technical Memorandum ERL ARL-55, 'Climatology of Stagnating

Anticyclones East of the Rocky Mountains, 1936-1975," NOAA Environmental Research

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Linsley Jr., R. K., M. A. Kohler, and J. L. H. Paulhus. Hydrology for Engineers, Third Edition,

McGraw-Hill: New York, 1982.

Lloyd, 0. B. and W. L. Lyke. HA730-K, "Illinois, Indiana, Kentucky, Ohio, and Tennessee,"

Ground ViaterAtlas of the United States, United States Geologic Survey: Reston, Virginia,

1995, <http://capp.water.usgs.gov/gwa/chk/index.html>.

Mitchell, W. D., "Unit Hydrographs in Illinois," Illinois Department of Public Works and Buildings,

Division of Waterways: Urbana, Illinois, 1948.

Ramsdell, Jr., V. A., "Technical Evaluation Report on Design Basis Tornadoes for the Clinton

ESP Site,' Pacific Northwest National Laboratories: Richland, Washington, November 9, 2004,

(ADAMS Accession No. ML043370309).

Reigel, J. T., J. F. Appleby, and R. W. Schloemer, Hydrometeorological Report 33, "Seasonal

Variation of the Probable Maximum Precipitation East of the 105th Meridian for Areas of 10 to

1,000 Square Miles and Durations of 6, 12, 24, and 48 Hours," U. S. Weather Bureau:

Washington, D.C., April 1956.

Roberts, WN. J. and J. B. Stall, "Lake Evaporation in Illinois," Board of Investigation 57, State

Water Survey Division, State of Illinois, Urbana, 1967.

Stall, J. B., Bulletin 51, "Low Flows of Illinois Stream for Impounding Reservoir Design," Illinois

State Water Authority, 1964.

Wilson, B. W., "Seiches," Advances in Hydoscience, Vol. 8, Academic Press: New York, 1972.

C-13

APPENDIX D

PRINCIPAL CONTRIBUTORS

Name Responsibility

Araguas, Christian

Bagchi, Goutam

Campe, Kazimieras

Cheng, Thomas

Gilles, Nanette

Harvey, R. Brad

Hinson, Charles

Klementowicz, Stephen

Lee, Jay

Moody, Robert

Munson, Cliff

Patel, Nitin

Prescott, Paul

Segala, John

Tardiff, Albert

Project Management

Hydrology

Site Hazards

Geotechinical Engineering

Project Management

Meteorology

Occupational Radiation Safety Analysis

Normal Radiological Dose Analyses

Accident Analyses

Emergency Planning

Geology and Seismology

Project Management

Quality Assurance

Project Management

Security

Contractors Technical Area

Brookhaven National Laboratory

Federal Emergency Management Agency

Pacific Northwest Laboratory

U.S. Geologic Survey

Geotechinical Engineering

Emergency Planning

Emergency Planning, Hydrology, Meteorology, and

Site Hazards

Geology and Seismology

D-1
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APPENDIX E

REPORT BY THE ADVISORY COMMITTEE ON REACTOR

,of% f~at"SAFEGUARDS

UNITED STATES

NUCLEAR REGULATORY COMMISSION

ADVISORY COMMITTEE ON REACTOR SAFEGUARDS ACRSR-2182

WASHINGTON, DC 20555 -0001

March 24, 2006

The Honorable Nils J. Diaz

Chairman

U.S. Nuclear Regulatory Commission

Washington, D.C. 20555-0001

SUBJECT: FINAL REVIEW OF THE EXELON GENERATION COMPANY, LLC,

APPLICATION FOR EARLY SITE PERMIT AND THE ASSOCIATED NRC

STAFF'S FINAL SAFETY EVALUATION REPORT

Dear Chairman Diaz:

During the 530'N meeting of the Advisory Committee on Reactor Safeguards, March 9-11, 2006,

we completed our review of the early site permit application for the Clinton site and the

associated final Safety Evaluation Report (SER) prepared by the NRC staff. We reviewed the

application and the final SER to fulfill the requirement of 10 CFR 52.23 that the ACRS report on

those portions of an early site permit application that concern safety. We issued an interim

letter on this application and the associated draft SER on September 22, 2005.. This matter

was also discussed during our Subcommittee meeting on March 8, 2006. During these

reviews, we had the benefit of discussions with representatives of the NRC staff and Exelon

Generation Company, LLC (Exelon). We also had the benefit of the documents referenced.

CONCLUSIONS AND RECOMMENDATIONS

* The early site permit application and the staff's final SER show that the proposed

nuclear power plant site adjacent to the existing Clinton Nuclear Power Station is an

acceptable site for nuclear power plants that meet the plant parameter envelope

proposed by the applicant.

* The staff has thoroughly reviewed a performance-based method proposed by the

applicant for determining the safe shutdown earthquake (SSE) ground motion. This

method is an attractive alternative to methods endorsed in current regulatory guides.

* The staff should consider development of a regulatory guide dealing with the alternative,

performance-based, method for assessing the seismic hazard of a site.

DISCUSSION

Exelon has applied for an early site permit for locating nuclear power plants or modules having

a total power generation rate of 2400 to 6800 MWt on a site adjacent to the currently operating

Clinton plant, which is a BWR 6 within a Mark IlIl containment. The early site permit application

is based on the now familiar "plant parameter envelope" approach since the applicant has not

identified the particular reactor technology that will be adopted. The plant parameter envelope

is based on the characteristics of certified designs such as the AP1000 and Advanced Boiling

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Water Reactor (ABWR) as well as other designs such as the International Reactor Innovative

and Secure (IRIS). Economic Simplified Boiling Water Reactor (ESBWR), Gas-Turbine Modular

Helium Reactor (GT-MHR), and Pebble Bed Modular Reactor (PBMR).

The staffs reviewof this application included a detailed review of the alternative, performance- based method proposed by the applicant for determining the SSE ground motion spectrum.

The staff identified six permit conditions for the proposed site. The staff has used technically sound. objective criteria for identifying these permit conditions. The staff and the applicant

have agreed to 32 combined license (COL) action items. The action items for the proposed Clinton site can be compared to 30 action Items for the North Anna early site pemit and 26

action [ters for the Grand Gulf early site permit.

Nature of the Site

The proposed site is located in a rural setting In central Illinois. The terrain is essentially flat

with some rolling hills. Nearby populations centers with populations In excess of 25,000 include

Springfield (74 km). Peoria (75 km), Champaign (49 km), Urbana (66 km). Decatur (36 kIn),

and Bloomington (36 km). Near the site (c16 km) are the small towns Clinton (population

7,000). as well as DeWitt, Weldon, and Wapella each with a population of less than 1,000.

Population trends in the larger cities near the site have been estimated based on census data.

Modest growth in population Is anticipated in these cities over the next 60 years. Interestingly, data obtained from other sources led the applicant to anticipate that populations In the rural

regions around the site will decline modestly over the next 60 years.

Weather

Weather at the proposed site is well characterized in recent years as would be expected for a

she with an operating nuclear power plant. The weather is marked by rather warm summer

periods and harsh winters. Weather extreme characteristics of the site have been based on

historical data. Neither the applicant nor the staff has considered the potential for cycles in

weather that may complicate the prediction of future weather extremes based on historical

records. Nevertheless, we believe that the applicant has adequately characterized the site

weather for the purposes of an early site permit.

Seismicity

The proposed site Is affected by the New Madrid seismic zone and the Wabash Valley seisrnic

zone. Since the nuclear power plant at the Clinton site was licensed, the estimated frequency of major earthquakes at the New Madrid seismic zone has been increased. The estimate of the

maximum potential magnitude of earthquakes at the Wabash Valley seismic zone has also

been Increased. There is a background selsmicity of the site represented by the Springfield earthquake estimated to have occurred at a location about 70 km from the site, approximately

6,000 years ago and to have had a magnitude of 6.2 to 6.8 on the Richter scale.

In other applications for early site permits, the applicants have adopted the methods

recommended in Regulatory Guide 1.165 to estimate the SSE ground motion spectrum. Exelon

has adopted an alternative method. This alternative is based on an industry standard (ASCE 43-05) that itself is based on work done by the Department of Energy for assessing the seismic

safety of its nuclear facilities. The alternative Is considered performance based' because it

uses a target probability for the maximum acceptable facility damage from an earthquake.

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Exelon has selected the frequency of 10'styr for the onset of significant inelastic deformation of

systems, structures, and components. This target provides a rather substantial margin to core

damage and containment failure.

The staff has reviewed thoroughly the proposed alternative method for estimating the seismic

hazard at the proposed site. The staff's review included examination of the credibility of

parametric quantities in the models and an Independent assessment of the analysis results by

direct integration of the seismic risk equation. Also, the staff has reviewed carefully the

applicant's assessment of the local seismic hazard. We concur with the staff that the

alternative approach adopted by Exelon for this application provides a high level of safety. The

seismic core damage frequency that can be inferred from the proposed ground motion

spectrum (-2xl 4 iyr) Is significantly less than the median found In selsnic probabilistic risk

assessments for 29 existing nudear power plants. The performance-based alternative method

yields results that are in concert with the Comnission's expectation that advanced reactors will

provide enhanced margins of safety and/or utilize simplified, Inherent, passive, or other

innovative means to accomplish their safety functions.

The alternative, performance-based, method uses a target frequency that does not change with

time as new Information on the seismicity of power plant sites changes. In this sense, the

alternative method provides some additional regulatory stability. For this reason, if no other, we

expect that the alternative method will be attractive to licensees and applicants for a variety of

purposes. The staff may want to consider developing a regulatory guide on the use of the

altemative methodology. Certainly, the detailed review of the method conducted by the staff for

this early site perrnit would provide a substantial technical basis for the development of such a

regulatory guide.

Sincerely,

RMU

Graham B. Wallis

Chairman

References:

1. Exelon Generation Company, LLC, Early Site Permit Application, September 23, 2003.

2. ACRS Interim Letter, Exelon Generation Company, LLC, Application for Early Site Permit and

the Associated NRC Staff's Draft Safety Evaluation Report, dated September 22, 2005.

3. EDO response to ACRS Interim Letter, 'Interim Letter: Exelon Generation Company, LLC,

Application for Early Site Permit and the Associated NRC Staffs Draft Safety Evaluation Report

on the Clinton Early Site Permit Site,' dated October 26, 2005.

4 Final Safety Evaluation Report for Exelon Early Site Permit Application, dated February 17,

2006.

5. Exelon Generation Company, LLC, letter to the U.S. Nuclear Regulatory Commission Sutbect:

*Seismic Risk (Performance Goal) Based Approach Primer Revision,' dated January 14, 2005.

6. NRC Regulatory Guide 1.165, 'Identification and Characterization of Seismic Sources and

Determination of Safe Shutdown Earthquake Ground Motion,' March 1997.

7. American Society of Civil Engineers, Seismic Design Criteria for Stnrctures, Systems, and

Components in Nuclear Facilities, ASCE/SEI 43-05 (ASCE Standard 43-05), 2005

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Exelon has selected the frequency of 10451yr for the onset of significant inelastic deformation of

systems, structures, and components. This target provides a rather substantial margin to core

damage and containment failure.

The staff has reviewed thoroughly the proposed alternative method for estimating the seisnic

hazard at the proposed site. The staff's review included examination of the credibility of

parametric quantities in the models and an independent assessment of the analysis results by

direct integration of the seismic risk equation. Also, the staff has reviewed carefully the

applicant's assessment of the local seismic hazard. We concur with the staff that the

alternative approach adopted by Exelon for this appication provides a high level of safety. The

seismic core damage frequency that can be inferred from the proposed ground motion

spectrum (-2xl1 6Iyr) is significantly less than the median found in seismic probabilistic risk

assessments for 29 existing nudear power plants. The performance-based alternative method

yields results that are in concert with the Commission's expectation that advanced reactors will

provide enhanced margins of safety andlor utilize simplified, inherent, passive, or other

innovative means to accomplish their safety functions.

The alternative, performance-based, method uses a target frequency that does not change with

time as new Information on the seismicity of power plant sites changes. In this sense, the

alternative method provides some additional regulatory stability. For this reason, if no other, we

expect that the alternative method will be attractive to licensees and applicants for a variety of

purposes. The staff may want to consider developing a regulatory guide on the use of the

alternative methodology. Certainly, the detailed review of the method conducted by the staff for

this early site permit would provide a substantial technical basis for the development of such a

regulatory guide.

Sincerely,

Graham B. Walis

Chairman

References:

1. Exelon Generation Company, LLC, Early Site Permit Application, September 23, 2003.

2. ACRS Interim Letter, Exelon Generation Company, LLC, Application for Early Site Permit and

the Associated NRC Staff's Draft Safety Evaluation Report, dated September 22, 2005.

3. EDO response to ACRS Interim Letter, 'Interim Letter: Exelon Generation Company, LLC,

Application for Early Site Permit and the Associated NRC Staffs Draft Safety Evaluation Report

on the Clinton Early Site Permit Site,' dated October 26, 2005.

4. Final Safety Evaluation Report for Exelon Early Site Permit Application, dated February 17,

2006.

5. Exelon Generation Company, LLC, letter to the U.S. Nuclear Regulatory Commission Subject:

'Seismic Risk (Performance Goal) Based Approach Primer Revision,' dated January 14, 2005.

6. NRC Regulatory Guide 1.165, 'Identification and Characterization of Seismic Sources and

Determination of Safe Shutdown Earthquake Ground Motion,' March 1997.

7. American Society of Civil Engineers, Seismic Design Criteria for Structures, Systems, and

Components In Nuclear Facilities, ASCE/SEI 43-05 (ASCE Standard 43-05), 2005.

DOCUMENT NAME: E:AFiIenetIML060860098.wpd

To receive a copy of this document, Indicate In the box: C'- = Copy without attachrrentienclosure "E" = Copy

with attachment~enclosure 'N" = No copy Accession #. ML060860098

OFFICE ACRSVACNW IYIACRS/ACNWlvi YACRS1ACNW IYIACRSIACNW | Y ACRSIACNW I IACRS/ACNWI Y I

NAME DFischer CSantos MSnodderty AThadan I JLarkins JTL for GBW

DATE 03r23406 I 0236 03/24V6 1 406 103124406 03206

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OFFICIAL RECORD COPY

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NRC FORM 335 U.S. NUCLEAR REGULATORY COMMISSION 1. REPORT NUMBER

(9.2004) (Assigned by NRC, Add Vol., Supp, Rev.,

NRCMD 3.7 and Addendum Numbers, t ainy.)

BIBLIOGRAPHIC DATA SHEET

(See instructions on the reverse) NUREG-18,14

2. TITLE AND SUBTITLE 3. DATE REPORT PUBLISHED

Safety Evaluation Report for an MONTH YEAR

Early Site Permi: (ESP) at the

Exelon Generation Company, LLC (EGC) ESP Site Ma 2006

4. FIN OR GRANT NUMBER

5. AUTHOR(S) 6. TYPE OF REPORT

Safety Evaluation Report

7. PERIOD COVERED (Inctusive Dates)

8. PERFORMING ORGANIZATION - NAME AND ADDRESS (if tRC, provide Division. Office orRegion, US. NucdearRegulatory Commission. andmailing address;ifcontiactor,

provide name and maflirg address.)

Division of New Reactor Licensing

Office of Nuclear Reactor Regulation

U.S. Nuclear Regulatory Commission

Washington, D.C. 20555-0001

9. SPONSORING ORGAkNIZATION - NAME AND ADDRESS (UtNRC. type 'Same as above; 1contrator. provide NRCDhision, Offilce orRegion, US. NudearReguiatory~brnmission.

and mailing address.)

Division of New Reactor Licensing

Office of Nuclear Reactor Regulation

U.S. Nuclear Regulatory Commission

Washington, D.C. 20555-0001

10. SUPPLEMENTARY NOTES

Proiect No. 718, Docket No. 52-007

11. ABSTRACT (200 words or less)

This safety evaluation report (SER) documents the U.S. Nuclear Regulatory Commission (NRC) staffs technical review of the

site safety analysis report (SSAR) and emergency planning information in the early site permit (ESP) application submitted by

Exelon Generation Company, LLC (EGC or the applicant), for the EGC ESP site. By letter dated September25, 2003, Exelon

submitted the ESP application for the EGC ESP site in accordance with SubpartA, "Early Site Permits," of Titlel0 of the Code of

Federal Regulations (1OCFR) Part52, "Early Site Permits; Standard Design Certifications; and Combined Licenses for Nuclear

Power Plants." The EGC ESP site is located approximately 6miles east of the city of Clinton in central Illinois, and is adjacent

to an existing nuclear power reactor operated by AmerGen, which is a subsidiary of Exelon Generation Company. In its

application, EGC seeks an ESP that could support a future application to construct and operate additional nuclear power

reactors at the lESP site with a total nuclear generating capacity of up to 6800megawatts (thermal).

This SER presents the results of the staffs review of information submitted in conjunction with the ESP application. The staff

has identified, in AppendixA to this SER, certain site-related Items that will need to be addressed at the combined license or

construction permit stage, if an applicant desires to construct one or more new nuclear reactors on the EGC ESP site. The

staff determined that these items do not affect the staffs regulatory findings at the ESP stage and are, for reasons specified in

Sectionl.7, more appropriately addressed at later stages in the licensing process. AppendixA to this SER also identifies the

permit conditiors that the staff recommends the Commission impose, if an ESP is issued to the applicant.

12. KEY WORDS/DESCRIPTORS (List words orphrases that wit assist researchers hI locating the report.) 13. AVAILABILITY SIATEMENT

Early Site Permit (ESP) unlimited

Final Safety Evaluation Report 14.,SECURITY CLASSIFICATION

Combined License (COL) (This Page)

Permit Conditions unclassified

COL Action Items (This Report)

Site Characteri;tics unclass ified

Bounding Parameters

Exelon Generation Company, LLC (EGC) ESP Site 15. NUMBER OF FAGES

16. PRICE

NRC FORM 335 (9-2004) PRINTED ON RECYCLED PAPER
Federal Recycling Program
III
UNITED STATES

NUCLEAR REGULATORY COMMISSION

WASHINGTON, DC 20555-0001

OFFICIAL BUSINESS