Michael P. Gallagher Exelon Nuclear

Exelon Generation ~ Vice President License Renewal and Decomm1ss1oning

200 Exelon Way Kennett Square. PA 19348

610 765 5958 Office 610 765 5658 Fax www.exeloncorp.com

m1chaelp.gallagher@exeloncorp.com

10 CFR 50 10 CFR 51 10 CFR 54

January 7, 2019

U.S. Nuclear Regulatory Commission A TIN: Document Control Desk Washington, DC 20555-0001

Subject:

References: 1.

2.

Peach Bottom Atomic Power Station, Units 2 and 3 Renewed Facility Operating License Nos. DPR-44 and DPR-56 NRG Docket Nos. 50-277 and 50-278

Response to Request dated December 7, 2018 for Docketing of Additional Documents to Support NRC's Environmental Review of the Peach Bottom Atomic Power Station, Units 2 and 3, Subsequent License Renewal Application

Letter from Michael P. Gallagher, Exelon Generation Company, LLC (Exelon), to U.S. Nuclear Regulatory Commission (NRG) Document Control Desk, "Application for Subsequent Renewed Operating Licenses," dated July 10, 2018 Email from Barbara Hayes, NRG, to Nancy L. Ranek, Exelon, "Additional Documents Needed for Peach Bottom SLR Environmental Review," dated December 7, 2018

In the Reference 1 letter, Exelon Generation Company, LLC (Exelon) submitted the Subsequent (i.e., Second) License Renewal Application (SLRA) for the Peach Bottom Atomic Power Station, Units 2 and 3 (PBAPS). In the Reference 2 email, the NRG requested that additional documents be docketed to support the Staff's review of the PBAPS SLRA Environmental Report (Appendix E to the SLRA). The table below lists the documents requested by the Reference 2 email and describes Exelon's responses.

Each document being provided for docketing is a separate enclosure to this letter, as indicated in the table.

Two of the documents being provided (Enclosures 13 and 14) were not prepared by Exelon or its contractors (i.e., they are "NonExelon" documents), and Exelon did not control development of the documents. Accordingly, while Exelon believes the information in those documents to be accurate and complete, we cannot make any specific representation as to their accuracy or completeness. The first page of each document is marked with the designation "NONEXELON," and the electronic file names include "NON EXELON."

January 7, 2019 U.S. Nuclear Regulatory Commission Page2

Enclosure# Requested Document

01 Exelon Nuclear. 2005. "Letter to PADEP (T. Barron) regarding Peach Bottom Atomic Power Station Proposal for Information Collection for NPDES PA0009733." June 10, 2005.

02 Exelon Nuclear. 2008. "Letter to PADEP (L. McDonnell) regarding NPDES Permit PA0009733, Section 316{b) Cooling Water Intake Structure Evaluation." December 22, 2008.

03 [NAI] Normandeau Associates, Inc. 2000. "A Report on the Thermal Conditions and Fish Populations in Conowingo Pond Relative to Zero Cooling Tower Operation at the Peach Bottom Atomic Power Station (June-October 1999)." Prepared for PECO Energy Company. February 2000.

04 [NAI] Normandeau Associates, Inc. 201 Oa. "Data Report on Intake Screen Sampling at Peach Bottom Atomic Power Station in 2010." Prepared for Peach Bottom Atomic Power Station. December 2010.

05 [NAI] Normandeau Associates, Inc. 2011 a. "Data Report or Intake Screen Sampling at Peach Bottom Atomic Power Station in 2011." Prepared for Peach Bottom Atomic Power Station. December 2011 .

06 [NAI] Normandeau Associates, Inc. 2012a. "Data Report or Intake Screen Sampling at Peach Bottom Atomic Power Station in 2012." Prepared for Peach Bottom Atomic Power Station. December 2012.

07 [NAI] Normandeau Associates, Inc. 2013a. "Data Report or Intake Screen Sampling at Peach Bottom Atomic Power Station in 2013." Prepared for Peach Bottom Atomic Power Station. December 2013.

08 [NAI] Normandeau Associates, Inc. 2013b. "Peach Bottom Atomic Power Station Entrainment Characterization Study 2012." Prepared for Exelon Generation. February 2013.

09 [NAI] Normandeau Associates, Inc. 2014a. "Data Report or Intake Screen Sampling at Peach Bottom Atomic Power Station in 2014." Prepared for Peach Bottom Atomic Power Station. December 2014.

Exelon's Response

The requested document is enclosed with file name:

01 _ExelonNuclear _2005.pdf

The requested document is enclosed with file name:

02_ExelonNuclear_2008.pdf

The requested document is enclosed with file name:

03_NAl_2000.pdf

The requested document is enclosed with file name:

04_NAl_201 Oa.pdf

The requested document is enclosed with file name:

05_NAl_2011 a.pdf

The requested document is enclosed with file name:

06_NAl_2012a.pdf

The requested document is enclosed with file name:

07 _NAl_2013a.pdf

The requested document is enclosed with file name:

08_NAl_2013b_REDACTED.pdf

A review revealed that Figures 2 and 3 in NAI 2013b are photographs of the PBAPS intake structure. marked with the phrase "Non Record Content." Accordingly, pursuant to the Pennsylvania Open Records Law, Figures 2 and 3 have been redacted from the file that is provided.

The requested document is enclosed with file name:

09_NAl_2014a.pdf

January 7, 2019 U.S. Nuclear Regulatory Commission Page 3

Enclosure# Requested Document

10 [NAI] Normandeau Associates, Inc. 2015a. "Data Report or Intake Screen Sampling at Peach Bottom Atomic Power Station in 2015." Prepared for Peach Bottom Atomic Power Station. December 2015.

11 [NAI and ERM] Normandeau Associates, Inc. and Environmental Resource Management. 2014. "Final Report for the Thermal Study to Support a 316(a) Demonstration: Peach Bottom Atomic Power Station.• Prepared for Exelon Generation. February 2014

12 [NAI and ERM] Normandeau Associates, Inc. and Environmental Resource Management. 2017. "Final Report for Post-EPU Thermal and Biological Monitoring Peach Bottom Atomic Power Station." Prepared for Exelon Generation. February 2017.

13 [PADEP] Pennsylvania Department of NON EXELON Environmental Protection. 2011. "Letter to

Peach Bottom Atomic Power Station (J. Brozonis) regarding NPDES Permit PA0009733 Entrainment Characterization Study Work Plan." May 5, 2011.

14 [PADEP] Pennsylvania Department of NON EXELON Environmental Protection. 2014b. "Letter to

Exelon Generation Company, LLC (P. Navin) regarding "401 Water Quality Certification Peach Bottom Atomic Power Station Extended Power Uprate," DEP File No. EA 67-024, NRC Docket No. NRC-2013-0232, York and Lancaster County. July 23, 2014

15 [PECO] Philadelphia Electric Company. 1975. "Materials prepared for the Environmental Protection Agency, Section 316(a) Demonstration for PBAPS Units No. 2 & 3 on Conowingo Pond." July 1975.

16 [PECO] Philadelphia Electric Company. 1977. "Section 316(b) Demonstration for PBAPS Units No. 2 & 3 on Conowingo Pond." June 1977.

Not applicable [NAI] Normandeau Associates, Inc. 2006. "Characterization of Mussel Habitat Utilization in the Vicinity of the Holtwood Hydroelectric Project." Prepared for Kleinschmidt Associates. March 2006.

Exelon's Response

The requested document is enclosed with file name:

1 O_NAl_2015a.pdf

Please note that the title page of the document being provided contains a title that is not consistent with the title given in the citation for the requested document. However, page 1 in the document contains a header that matches the title in the citation. Exelon has verified that "American Shad Sampling" and "Intake Screen Sampling" refer to the same sampling activities at PBAPS during 2015.

The requested document is enclosed with file name:

11 _NAl-ERM_2014.pdf

The requested document is enclosed with file name:

12_NAl-ERM_2017 .pdf

The requested document is enclosed with file name:

13_PADEP _2011_NONEXELON.pdf

The requested document is enclosed with file name:

14_PADEP _2014b_NONEXELON.pdf

The requested document is enclosed with file name:

15_PEC0_ 1975.pdf

The requested document is enclosed with file name:

16_PEC0_ 1977.pdf

The requested document was mistakenly cited in the PBAPS SLR Environmental Report (ER), Sec. 3.6.4.1.2, as "NAI 2006." The electronic file paired in Exelon's database of references for the PBAPS SLR Environmental Report with "NAI 2006" should have been cited as follows:

January 7, 2019 U.S. Nuclear Regulatory Commission Page4

Enclosure# Requested Document

Not applicable URS Corporation. 2008. "316(b) Compliance Report With Source Waterbody Information, Impingement Mortality Characterization Study, and Design and Construction Technology Plan, Peach Bottom Atomic Power Station." Prepared for Exelon Corporation. June 2008.

Exelon's Response

[FERG] Federal Energy Regulatory Commission. 2008. "Final Environmental Impact Statement for License Amendment. Holtwood Hydroelectric Project FERG Project No. 1881-050, Pennsylvania. FERC/EIS-0224F. November 2008.

The FERG report, in which "NAI 2006" is named as a reference, is available on the internet at:

https://www.ferc.gov/industries/hydropower/ enviro/eis/2008/11-14-08.asp.

Hence, no file for this document is provided.

The requested document is dated June 2008 and is an earlier version of Exelon Nuclear 2008 (see above Enclosure 2), which is dated October 2008. Accordingly, the information in URS Corporation 2008 is redundant. Hence, no file is provided for URS Corporation 2008.

This letter and its enclosures contain no regulatory commitments.

If you have any questions, please contact Ms. Nancy Ranek, Environmental Lead, Exelon Generation License Renewal, at 267-533-1506.

I declare under penalty of perjury that the foregoing is true and correct. Executed on the 7th day of January 2019.

Respectfully,

Mi?!!d::f M1¥ ' Vice President - License Renewal and Decommissioning Exelon Generation Company, LLC

Enclosures: 1 through 16

cc: Regional Administrator - NRG Region I (w/o Enclosures) NRG Project Manager (Environmental Review), NRR-DMLR (w/o Enclosures) NRG Project Manager (Safety Review), NRR-DMLR (w/o Enclosures) NRG Project Manager, NRA-DORL Peach Bottom Atomic Power Station

(w/o Enclosures) NRG Senior Resident Inspector, Peach Bottom Atomic Power Station (w/o Enclosures) Rich Janati, PADEP-BNR (w/o Enclosures) D.A. Tancabel, State of Maryland (w/o Enclosures)