ML022620332
| ML022620332 | |
| Person / Time | |
|---|---|
| Site: | Millstone, North Anna  |
| Issue date: | 09/10/2002 |
| From: | Sarver S Dominion Generation |
| To: | NRC/ADM/DAS/RDB |
| References | |
| 66FR52951 00001, GL02-002, NUREG-1748 | |
| Download: ML022620332 (4) | |
Text
Dominion Generation 5000 Dominion Boulevard, Glen Allen, VA 23060 September 10, 2002 Chief, Rules Review and Directives Branch Mail Stop: T-6 D59 U.S. Nuclear Regulatory Commission Washington, DC 20555-0001 ZSP17 PI2q Ru
- -rr Di-, cUV COMMENTS ON THE DRAFT DOCUMENT "ENVIRONMENTAL REVIEW GUIDANCE FOR LICENSING ACTIONS ASSOCIATED WITH NMSS PROGRAMS" (NUREG-1748)
Dear Sirs:
Virginia Electric and Power Company (Dominion) and Dominion Nuclear Connecticut appreciate the opportunity to provide the attached comments on draft NUREG 1748 as requested in the Federal Register, volume 66, number 202, page 52951 on October 18, 2001.
If you have any questions regarding our comments, please contact Mr. Tony Banks Mr. Don Olson tonybanks@dom.com or (804) 273-2170, or, don-olson@dom.com or (804) 273-2830 Respec ly, Ste en P. S er, Director ear Li sing and Operations Support Attachment 64 m zU'ip Dominion-9o//s1e /
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11 Attachment Dominion Comments on the Draft NUREG 1748 Section 1.2 The Environmental Review, and Section 5.4 Environmental Impacts Page 4, Lines 11-15, and Page 66, Lines 24-25:
Draft NUREG Statement:
"The NEPA document does not address accident scenarios, rather it addresses the environmental impacts which result from the accident"; and, "... the NRC should ensure consistency between the NEPA document and the SER."
"These impacts should consider normal operational events as well as reasonably foreseeable accidents (e.g. design basis event for Part 72 licensees...
Dominion Comment:
NUREG-1437 and NUREG-1 555 both provide for review of design-basis accidents and severe accidents from an applicant's ER or FSAR, and review of SAMA analyses from an applicant's ER. Although this NUREG-1748 guidance document states environmental impacts from accidents are addressed, it is not seen in the Contents or directed in the text, specifically. The purpose for mentioning design-basis events above is not clear. It is suggested therefore, that either accident and/or mitigation analyses discussion be included or directed specifically for consistency of applicant expectations with other NRC environmental documents, or additional explanation be provided for disposition of accident analyses.
Section 1.3 Utilizing Existing Environmental Analyses Page 6, Line 10:
Draft GElS Statement:
It is stated that "Existing environmental analyses should be used to evaluate impacts associated with a proposed action to the extent possible and appropriate."
Dominion Comment:
It is not stated that reviewers should identify and evaluate the quality assurance measures taken by the applicant in collecting and analyzing data. This is provided as an instruction to reviewers in NUREG-1555. It is suggested that
inclusion of this type of instruction would serve to build public confidence in NRC processes and applicant credibility.
Section 1.3.1 Tiering Page 6, Lines 23-25 and 30-32:
Draft NUREG Statement:
The new, more specific environmental document incorporates by reference the general discussions and analyses from the existing document and concentrates on the issues and impacts of the project which are not specifically covered in the broader document.
An example of tiering may include using a GElS as the basis for an EA or EIS prepared for a site-specific proposed action.
Dominion Comment:
It is suggested that a brief discussion of NUREG-1437 content applicability and usefulness be included in this paragraph. It would serve to further strengthen and clarify the explanation of adopting generic issue findings, particularly as the process applies to spent fuel storage license renewal actions.
Section 1.4 References Page 8, Lines 15-16 and 21-23:
Draft NUREG Statement:
10 CFR 51 is referenced for Environmental Regulations and NUREG-1496 is provided as a GElS reference.
Dominion Comment:
It is suggested that NUREG-1437 and Supplement I to RG 4.2 be added to the list of references, to provide reviewers and applicants additional reference guidance regarding license renewal actions.
Sections 5.3 and 6.3 Description of the Affected Environment, and Sections 5.4 and 6.4 Environmental Impacts Pages 59-65, 66-75,93-105, and 107-113:
Draft NUREG Statement:
This guidance document states that descriptions and impacts should be considered for the following resources, among others:
"* Land use
"* Ecology
"* Air quality
"* Noise
"* Historical and cultural
"* Visual/scenic Dominion Comment:
For existing licensed facilities, the above-listed resource areas with low-impact (or no-changes) should be deleted from evaluation for license renewal and continued operation.