ML070920453

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NUREG-1873, Dfc, Draft Environmental Impact Statement for License Renewal of the National Bureau of Standards Reactor.
ML070920453
Person / Time
Site: National Bureau of Standards Reactor
Issue date: 06/27/2007
From:
Office of Nuclear Reactor Regulation
To:
Beissel, Dennis, DLR/REBA, 415-2145
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ML070990079 List:
References
NUREG-1873
Download: ML070920453 (118)


Text

Draft Environmental Impact Statement for License Renewal

of the National Bureau of

Standards Reactor Draft Report for Comment U.S. Nuclear Regulatory Commission Office of Nuclear Reactor Regulation

Washington, D.C. 20555-0001 NUREG-1873

NUREG-1873 Draft Environmental Impact Statement for License Renewal

of the National Bureau of

Standards Reactor Draft Report for CommentManuscript Completed:

Date Published: Division of License Renewal Office of Nuclear Reactor Regulation

U.S. Nuclear Regulatory Commission

Washington, DC 20555-0001

COMMENTS ON DRAFT REPORTAny interested party may submit comments on this report for consideration by the NRC staff. Commentsmay be accompanied by additional relevant information or supporting data. Please specify the report number Draft NUREG-1873 in your comments, and send them by the end of the 60 day comment period specified in

the Federal Register notice announcing availability of this draft. Chief, Rulemaking, Directives and Editing Branch Mail Stop: T6-D59 U.S. Nuclear Regulatory Commission Washington, DC 20555-0001You may also provide comments at the NRC Web site:

http://www.nrc.gov/public-involved/doc-comment/form.htmlFor any questions about the material in this report, please contact:

Dennis Beissel Mail Stop: O-11F1 U.S. Nuclear Regulatory Commission Washington, DC 20555-0001

Phone: (301) 415-2145 E-mail: DRB1@nrc.gov iii Abstract 1 2 3 This draft environmental impact statement (EIS) has been prepared in response to an 4 application submitted to the U.S. Nuclear Regulatory Commission (NRC) by the National 5 Institute of Standards and Technology (NIST) to renew the operating license for the National 6 Bureau of Standards Reactor (NBSR) for a period of an additional 20 years. This is the second 7 license renewal application for the NBSR. The first license renewal was granted May 16, 1984, 8 and included a power uprate from 10 megawatts (MW) to 20 MW of thermal power. This draft 9 EIS includes the NRC staff's analysis that considers and weighs the environmental impacts of 10 the proposed action, as well as mitigation measures available for reducing or avoiding adverse 11 impacts. It also includes the staff's recommendation regarding the proposed action.

12 13 No public comments were received during the scoping process. The staff determined from its 14 review of the application that no issues hav ing a significant environmental impact exist, and 15 additional mitigation measures are not likely to be sufficiently beneficial as to be warranted.

16 17 The NRC staff's recommendation is that the Commission determine the adverse environmental 18 impacts of license renewal for the NBSR are not so great that license renewal would be 19 unreasonable. This recommendation is based on (1) the Environmental Report submitted by 20 NIST; (2) consultation with Federal, State, and local agencies; and (3) the staff's own 21 independent review.

22 23 24 Paperwork Reduction Act Statement 25 26 This draft environmental impact statement does not contain information collection requirements 27 and, therefore, is not subject to the requirements of the Paperwork Reduction Act of 1995 (44 28 U.S.C. 3501 et seq.).

29 30 Public Protection Notification 31 32 The NRC may not conduct or sponsor, and a person is not required to respond to, a request for 33 information or an information request requirement unless the requesting document displays a 34 currently valid OMB control number.

35

Contents v Contents 1 2 3Abstract..............................................................iii 4

5Executive Summary.....................................................xi 6

7Abbreviations/Acronyms..................................................xiii 8

91.0Introduction........................................................1-1 10 111.1Report Contents................................................1-1 12 131.2Background...................................................1-2 14 151.3The Proposed Federal Action......................................1-3 16 171.4The Purpose and Need for the Proposed Action.......................1-4 18 191.5Compliance and Consultations.....................................1-5 20 211.6References....................................................1-5 22 232.0Description of Reactor, Site, and Reactor Interaction with the Environment......2-1 24 252.1Reactor and Site Description and Proposed Reactor Operation During 26the License Renewal Term........................................2-1 272.1.1External Appearance and Setting...........................2-2 282.1.1.1 Specification and Location..............................2-5 29 2.1.1.2 Access Control and Emergency Planning Zone.............2-5 302.1.1.3 Population Distribution.................................2-7 312.1.1.4 Nearby Industrial, Transportation, and Military Facilities.......2-9 322.1.2Description of Reactor Complex............................2-10 332.1.3Experimental Facilities....................................2-11 342.1.3.1 Neutron Beams......................................2-12 352.1.3.2 Thermal Column Facility...............................2-13 362.1.3.3 Pneumatic System and In-Core Exposure Facilities..........2-13 372.1.3.4 Cold Neutron Experiments..............................2-13 382.1.4Radioactive Waste Management Systems and Effluent 39Control Systems........................................2-13 402.1.4.1 Radiation Sources....................................2-14 41 2.1.4.2 Liquid Waste Processing Systems and Effluent Controls......2-14 42 Contents vi 2.1.4.3 Gaseous Waste Processing Systems and Effluent Controls....2-17 12.1.4.4 Solid Waste Processing................................2-19 22.1.5Nonradioactive Waste Systems.............................2-22 3 42.2Interaction of the Reactor with the Environment.......................2-23 52.2.1Land Use..............................................2-23 62.2.2Water Use.............................................2-24 72.2.3Water Quality...........................................2-24 82.2.4Meteorology and Air Quality...............................2-24 92.2.5Aquatic Resources......................................2-26 102.2.6Terrestrial Resources....................................2-27 112.2.7Radiological Impacts.....................................2-28 122.2.7.1 Environmental Monitoring..............................2-28 132.2.7.2 Impacts From Radiological Liquid Emissions...............2-29 142.2.7.3 Impacts From Radiological Air Emissions..................2-29 152.2.7.4 Dose to Workers.....................................2-30 162.2.8Socioeconomic Factors...................................2-31 172.2.8.1 Housing............................................2-31 182.2.8.2 Public Services......................................2-33 192.2.8.3 Offsite Land Use.....................................2-35 202.2.8.4 Visual Aesthetics and Noise............................2-35 21 2.2.8.5 Demography........................................2-36 222.2.9Historic and Cultural Resources............................2-39 232.2.10Related Federal Project Activities and Consultations............2-39 24 252.3References....................................................2-40 26 273.0Environmental Impacts of Operation.....................................3-1 28 293.1Cooling System................................................3-1 30 313.2Radiological Impacts............................................3-2 32 333.3Socioeconomic Impacts..........................................3-3 343.3.1Housing Impacts........................................3-3 353.3.2Public Services: Public Utilities.............................3-4 363.3.3Public Services: Transportation............................3-5 373.3.4Offsite Land Use........................................3-5 383.3.5Environmental Justice....................................3-5 39 40 41 Contents vii3.4Historic and Archaeological Resources..............................3-7 1 23.5Ecology......................................................3-8 33.5.1Aquatic Ecology.........................................3-8 43.5.2Terrestrial Ecology.......................................3-8 53.5.3Threatened and Endangered Species........................3-8 6 73.6Cumulative Impacts of Operations During the License Renewal Term......3-9 83.6.1Cumulative Impacts Resulting from Operation of the Plant 9Cooling System.........................................3-9 103.6.2Cumulative Radiological Impacts...........................3-10 113.6.3Cumulative Socioeconomic Impacts.........................3-10 123.6.4Cumulative Impacts on Historic and Archaeological Resources....3-10 133.6.5Cumulative Impacts on Ecology Including Threatened and 14Endangered Species.....................................3-11 15 163.7Summary of Impacts of Operations During the License Renewal Term.....3-11 17 183.8References....................................................3-11 19 204.0Environmental Impacts of Postulated Accidents............................4-1 21 224.1Postulated Facility Accidents......................................4-1 234.1.1Design-Basis Accidents...................................4-1 244.1.2Severe Accidents........................................4-3 25 264.2References....................................................4-4 27 285.0Environmental Impacts of the Uranium Fuel Cycle and Solid Waste 29 Management......................................................5-1 30 315.1The Uranium Fuel Cycle..........................................5-2 32 335.2References....................................................5-5 34 356.0Environmental Impacts of Decommissioning..............................6-1 36 376.1Decommissioning...............................................6-1 38 396.2References....................................................6-3 40 41 42 Contents viii7.0Environmental Impacts of the Alternatives................................7-1 1 27.1No-Action Alternative............................................7-2 37.1.1Land Use..............................................7-2 47.1.2Aquatic and Terrestrial Resources..........................7-2 57.1.3Water Use and Quality...................................7-3 67.1.4Air Quality.............................................7-3 77.1.5Waste................................................7-4 87.1.6Human Health..........................................7-4 97.1.7Socioeconomics........................................7-4 107.1.8Environmental Justice....................................7-4 117.1.9Aesthetics and Noise.....................................7-5 127.1.10Historic and Archaeological Resources.......................7-5 13 147.2Construction of a Replacement Reactor and Associated Facilities.........7-5 157.2.1Land Use..............................................7-6 167.2.2Aquatic and Terrestrial Resources..........................7-7 177.2.3Water Use and Quality...................................7-8 187.2.4Air Quality.............................................7-9 197.2.5Waste................................................7-9 207.2.6Human Health..........................................7-9 217.2.7Socioeconomics........................................7-10 227.2.8Environmental Justice....................................7-10 237.2.9Aesthetics and Noise.....................................7-10 247.2.10Historic and Archaeological Resources.......................7-11 25 267.3Summary of Alternatives Considered................................7-11 27 287.4References....................................................7-12 29 308.0Summary and Conclusions............................................8-1 31 328.1Environmental Impacts of the Proposed Action - License Renewal........8-2 338.1.1Unavoidable Adverse Impacts..............................8-3 348.1.2Irreversible or Irretrievable Resource Commitments.............8-3 358.1.3Short-Term Use Versus Long-Term Productivity................8-3 36 378.2Relative Significance of the Environmental Impacts of License Renewal 38 and Alternatives................................................8-4 39 40 41 Contents ix8.3Staff Conclusions and Recommendations............................8-5 1 28.4References....................................................8-5 3

4 Appendix A - Contributors to the Document...................................A-1 5 Appendix B - Comments Received on the Environmental Review..................B-1 6 Appendix C - Chronology of NRC Staff Environmental Review Correspondence 7 Related to National Institute of Standards and Technology's 8 Application for License Renewal for the National Bureau of 9Standards Reactor...........................................C-1 10Appendix D - Organizations Contacted......................................D-1 11 12 x Figures 1 2 32-1Regional Map...................................................2-2 42-2Immediate Area..................................................2-3 52-3Photographic View...............................................2-4 62-4NIST Center for Neutron Research...................................2-6 72-5Major Federal Installations in Montgomery County, Maryland..............2-38 8 9 10 11 Tables 12 13 142-1Population Estimates.............................................2-7 152-2Montgomery County Population.....................................2-8 162-3Montgomery County Population Forecasts.............................2-8 172-4Montgomery County Planning Area Forecasts for Population..............2-8 182-5NBSR Site Area Census Data.......................................2-9 192-6NBSR Systems and Radiation Sources...............................2-15 202-7Total Occupied and Vacant (Available) Housing Units by County, 21 1990 and 2000..................................................2-32 222-8Population Growth in Montgomery County, Maryland - 1980 to 2020........2-33 232-9Number of Jobs in Montgomery County and the State of Maryland 24 (2004 to 2010)...................................................2-39 25 267-1Summary of Environmental Impacts of the No-Action Alternative............7-3 277-2Characterization of Impacts Associated with Construction and 28Operation of a Replacement Reactor and Associated Support Facilities......7-6 29 308-1Summary of Environmental Significance of License Renewal, the 31 No-Action Alternative, and Construction and Operation of Alternative 32Research Facilities...............................................8-4 33 xi Executive Summary 1 2 3 By letter dated April 9, 2004, the National Institute of Standards and Technology (NIST) 4 submitted an application to the U.S. Nuclear Regulatory Commission (NRC) to renew the 5 operating license (OL) for the National Bureau of Standards Reactor (NBSR) for an additional 6 20-year period. If the OL is not renewed, then the reactor must be shut down.

7 8 Section 102 of the National Environmental Policy Act (NEPA) (42 USC 4321 et seq.) directs that 9 an environmental impact statement (EIS) is required for major Federal actions that significantly 10 affect the quality of the human environment. The NRC has implemented Section 102 of NEPA 11 in Title 10 of the Code of Federal Regulations (CFR) Part 51. Part 51 identifies licensing and 12 regulatory actions that require an EIS. In 10 CFR 51.20(b)(2), the Commission requires 13 preparation of an EIS for renewal of a testing facility (test reactor) OL.

14 15 Upon acceptance of the NIST application, the NRC began the environmental review process 16 described in 10 CFR Part 51 by publishing a notice of intent to prepare an EIS and conduct 17 scoping (70 FR 56935) on September 29, 2005. The staff visited the NIST site in September 18 2006. In the preparation of this draft EIS for the NBSR, the staff reviewed the NIST 19 Environmental Report (ER), consulted with other agencies, and conducted an independent 20 analysis of the issues. No comments were received from the public during the scoping process.

21 22 This draft EIS includes the NRC staff's preliminary analysis that considers and weighs the 23 environmental effects of the proposed action, the environmental impacts of alternatives to the 24 proposed action, and mitigation measures for reducing or avoiding adverse effects. It also 25 includes the staff's preliminary recommendation regarding the proposed action. When the 26 45-day comment period on the draft EIS ends, the staff will consider comments received. Any 27 comments received will be addressed in Appendix B, Part II, of the final EIS.

28 29 For the evaluation of the NBSR license renewal action, the staff has applied the NRC's three-30 level standard of significance - SMALL, MODE RATE, or LARGE - developed using the Council 31 on Environmental Quality guidelines. The following definitions of the three significance levels 32 are set forth in the footnotes to Table B-1 of 10 CFR Part 51, Subpart A, Appendix B:

33 34 SMALL - Environmental effects are not detectable or are so minor that they will neither 35 destabilize nor noticeably alter any important attribute of the resource.

36 37 MODERATE - Environmental effects are sufficient to alter noticeably, but not to 38 destabilize, important attributes of the resource.

39 40 LARGE - Environmental effects are clearly noticeable and are sufficient to destabilize 41 important attributes of the resource.

42 Executive Summary xii The staff's analysis revealed that all of the environmental impacts considered in this EIS for 1 continued operation of the NBSR during the term of the renewed OL would be expected to be 2 SMALL.3 4 If the NBSR operating license is not renewed and the unit ceases operation, then the adverse 5 impacts of the most likely alternative, construction of a replacement facility, will not be smaller 6 than those associated with continued operation of the NBSR. The impacts may, in fact, be 7 greater in some areas.

8 9 The preliminary recommendation of the NRC staff is the Commission determine the adverse 10 environmental impacts of license renewal for the NBSR are not so great that preserving the 11 option of license renewal for NIST decisionmakers would be unreasonable. This 12 recommendation is based on (1) the ER submitted by NIST; (2) consultation with other Federal, 13 State, and local agencies; and (3) the staff's own independent review. There were no 14 comments received from the public during the scoping process that would require the NRC to 15 consider additional environmental issues above t hose anticipated by the staff to be relevant.

16 xiii Abbreviations/Acronyms 1 2 3Cimicrocurie(s) 4 5alpha 6acacre(s)7ADAMSAgencywide Document Access and Management System 8ALARAas low as reasonably achievable 9AQCRAir Quality Control Region 10AQIAir Quality Index 11 12BWIBaltimore-Washington International Airport 13 14Cdegrees Celsius 15CAMcontinuous air monitor 16CEQCouncil on Environmental Quality 17CFRCode of Federal Regulations 18cfscubic feet per second 19Cicurie(s) 20cmcentimeter(s) 21 22DACderived air concentration 23DBAdesign basis accident 24DCAWashington Reagan Airport 25DOEU.S. Department of Energy 26 27EISenvironmental impact statement 28EPAU.S. Environmental Protection Agency 29EPZemergency planning zone 30EREnvironmental Report 31ESFEngineered Safety Features 32 33Fdegrees Fahrenheit 34FESFinal Environmental Statement 35 FR Federal Register 36ftfoot/feet 37 38gamma 39galgallon 40GEISGeneric Environmental Impact Statement for License Renewal of Nuclear Plants, 41 NUREG-1437 42 Abbreviations/Acronyms xivgpdgallon(s) per day 1gpmgallon(s) per minute 2 3hahectare(s) 4HEPAhigh-efficiency particulate air (filter) 5HEUhighly enriched fuel 6HLWhigh-level waste 7hrhour(s)8 9IADDulles International Airport 10in.inch(es) 11 12kgkilogram(s) 13kmkilometer(s) 14 15Lliter(s)16lbpound(s) 17LEUlow enriched fuel 18LLWlow-level radioactive waste 19LWRlight-water reactor 20 21mmeter(s)22MGDmillion gallons per day 23MHAmaximum hypothetical accident 24mimile(s)25minminute(s) 26mLmilliliter(s) 27MLLWmixed low level waste 28mmmillimeters 29mremmillirem(s) 30m/smeters per second 31mSvmillisievert(s) 32MTRmaterials testing reactor 33MWmegawatt(s) 34MWemegawatt(s) electric 35MWtmegawatt(s) thermal 36 37nneutron 38NAAQSNational Ambient Air Quality Standards 39NBSRNational Bureau of Standards Reactor 40NEPANational Environmental Policy Act of 1969, 42 USC 4321, et seq.

41NHPANational Historic Preservation Act of 1966, 16 USC 470, et seq.

42 Abbreviations/Acronyms xvNISTNational Institute of Standards and Technology 1NRCU.S. Nuclear Regulatory Commission 2NTSBNational Transportation Safety Board 3NWSNational Weather Service 4 5OLoperating license 6OSTPOffice of Science and Technology Policy 7

8pproton 9 10remspecial unit of dose equivalent, equal to 0.01 Sv 11REMPradiological environmental monitoring program 12 13ssecond(s) 14SARsafety analysis report 15SERSafety Evaluation Report 16SRSSavannah River Site 17Svsievert (special unit of dose equivalent) 18 19TLDthermoluminescent dosimeter 20 21USCBU.S. Census Bureau 22 23WSSCWashington Suburban Sanitary Commission 24 25yryear(s)26 1-1 1.0 Introduction 1 2 3 Under the U.S. Nuclear Regulatory Commission's (NRC's) environmental protection regulations 4 in Title 10 of the Code of Federal Regulations (CFR) Part 51, which implement the National 5 Environmental Policy Act of 1969 (NEPA), renewal of a nuclear test reactor operating license 6 (OL) requires the preparation of an environmental impact statement (EIS). In preparing the EIS, 7 the NRC staff is required first to issue the statement in draft form for public comment, and then 8 issue a final statement after considering public comments on the draft.

9 10 The National Institute of Standards and Technology (NIST) operates the National Bureau of 11 Standards Reactor (NBSR) in Gaithersburg, Maryland, under OL No. TR-5, which was issued 12 by the NRC. By letter dated April 9, 2004, NIST submitted an application to the NRC to renew 13 the OL for the NBSR for an additional 20 year period under 10 CFR 51.20(b)(2). Pursuant to 14 10 CFR 51.53, NIST submitted an Environmental Report (ER) (NIST 2004), which analyzed the 15 environmental impacts associated with the proposed license renewal action and evaluated 16 mitigation measures for reducing adverse environmental effects. The current OL for the NBSR 17 was scheduled to expire on May 16, 2004. However, in accordance with 10 CFR 2.109(a) 18 NIST's application for renewal was received at least 30 days prior to the expiration of an 19 existing license, and therefore, the existing OL will not be considered expired until the 20 application has been finally determined.

21 22 This report is the draft EIS for the NIST application for license renewal of the NBSR. The staff 23 will also prepare a separate safety evaluation report.

24 251.1Report Contents 26 27 The following sections of this Introduction (1) describe the background for the preparation of this 28 draft EIS and the process used by the staff to assess the environmental impacts associated with 29 license renewal; (2) describe the proposed Federal action to renew the NBSR OL; (3) discuss 30 the purpose and need for the proposed action; and (4) discuss the NBSR's compliance with 31 environmental quality standards and requirement s that have been imposed by Federal, State, 32 regional, and local agencies that are responsible for environmental protection.

33 34 The ensuing chapters of this draft EIS include the following information. Chapter 2 describes 35 the site, reactor, and interactions of the reactor with the environment. Chapter 3 discusses the 36 environmental impacts of operation during the renew al term. Chapter 4 contains a summary of 37 the evaluation of potential environmental impacts of plant accidents, including consideration of 38 the maximum hypothetical event. Chapter 5 discusses the environmental impacts of the 39 uranium fuel cycle and solid waste managemen

t. Chapter 6 examines the impacts of 40 decommissioning. Chapter 7 discusses the impacts of alternatives to license renewal.

41 Introduction(a)The GEIS was originally issued in 1996. Addendum 1 to the GEIS was issued in 1999. Hereafter, all referenced to the "GEIS" include the GEIS and its Addendum 1.

1-2 Chapter 8 summarizes the findings of the preceding chapters and draws conclusions about the 1 adverse impacts that cannot be avoided, the re lationship between short-term uses of the 2 environment and the maintenance and enhancement of long-term productivity, and any 3 irreversible or irretrievable commitment of resources. Chapter 8 also presents the staff's 4 preliminary recommendation with respect to the proposed license renewal action.

5 6 Additional information is included in appendixes. Appendix A lists the contributors to the 7 document. Appendix B addresses the public response to scoping for the environmental review 8 for license renewal. Appendix C provides a chronology of the NRC staff's environmental review 9 correspondence related to this draft EIS, and Appendix D identifies the organizations contacted 10 during the development of this draft EIS.

11 121.2Background 13 14 An applicant seeking to renew its OL is required to submit an ER as part of its application. The 15 NRC license-renewal evaluation process involves careful (1) review of an applicant's ER; 16 (2) review of records of public comments; (3) review of environmental quality standards and 17 regulations; (4) coordination with Federal, State, and local environmental protection and 18 resource agencies; and (5) review of the technical literature to verify the environmental impacts 19 of the proposed license renewal. Using the NRC's established license renewal evaluation 20 framework for commercial power reactors ensures a thorough evaluation of the impacts of 21 renewal of the OL for the NBSR. The Generic Environmental Impact Statement for License 22 Renewal of Nuclear Plants (GEIS), NUREG-1437, Volumes 1 and 2 (NRC 1996, 1999)(a) was 23 written specifically for use in the renewal of OLs for commercial power reactors. In conducting 24 the staff review of the NIST application, the NRC staff was informed by certain GEIS features 25 including the use of the three-level standard of significance.

26 27 In following the precedent of the GEIS and the site-specific supplemental license renewal EISs, 28 environmental issues in this draft EIS have been evaluated using a three-level standard of 29 significance - SMALL, MODERATE, or LARGE

- developed by NRC using guidelines from the 30 Council on Environmental Quality. The definitions of the three significance levels are set forth in 31 the footnotes to Table B-1 of 10 CFR Part 51, Subpart A, Appendix B, as follows:

32 33 SMALL - Environmental effects are not detectable or are so minor that they will 34 neither destabilize nor noticeably alter any important attribute of the resource.

35 36 MODERATE - Environmental effects are sufficient to alter noticeably, but not to 37 destabilize, important attributes of the resource.

38 39 Introduction 1-3 LARGE - Environmental effects are clearly noticeable and are sufficient to 1 destabilize important attributes of the resource.

2 3 When the findings in the GEIS are used in this document, there is a description of the finding 4 and a brief discussion on how the findings can also be applicable to or bound the environmental 5 effects of a test reactor such as the NBSR.

6 7 As a part of its review, the NRC prepares an independent analysis of the environmental impacts 8 of license renewal and compares these impacts wi th the environmental impacts of alternatives.

9 The evaluation of the NIST license renewal application began with the publication of a notice of 10 acceptance for docketing and opportunity for a hearing in the Federal Register (69 FR 56462) 11 on September 21, 2004. The staff issued a notice of intent to prepare a draft EIS and to 12 conduct scoping (70 FR 56935) on September 29, 2005.

13 14 The NRC staff and contractors retained to assist the staff visited the NIST site on 15 September 26, 2006, to gather information and to become familiar with the NBSR, the NIST 16 site, and its environs. The staff also consulted with Federal, State, regional, and local agencies.

17 A list of the organizations consulted is provided in Appendix D. Other documents related to the 18 NBSR were reviewed and are referenced. There were no comments received from the public 19 related to the NBSR during the scoping period, which ended November 28, 2005.

20 21 This draft EIS presents the staff's analysis that considers and weighs the environmental effects 22 of the proposed renewal of the OL for the NBSR , the environmental impacts of alternatives to 23 license renewal, and mitigation measures availabl e for avoiding adverse environmental effects.

24 Chapter 8, Summary and Conclusions, provides the staff's preliminary recommendation to the 25 Commission on whether or not the adverse envir onmental impacts of license renewal are so 26 great that preserving the option of license renewal would be unreasonable.

27 28 As provided by 10 CFR Part 51, a 45-day comment period will begin on the date of publication 29 of the U.S. Environmental Protection Agency's Notice of Filing of the draft EIS to allow members 30 of the public to comment on the preliminary results of the NRC staff's review.

31 321.3The Proposed Federal Action 33 34 The proposed Federal action is renewal of the OL for the NBSR. This reactor is located on the 35 NIST campus in upper Montgomery County, Ma ryland, approximately 32 km (20 mi) northwest 36 of the District of Columbia. The NBSR is a heavy water-moderated and cooled, enriched-fuel, 37 tank-type reactor designed to operate at 20 megawatts (MW) of thermal power. It is a 38 custom-designed variation of the Argonne CP-5 class reactor. The primary coolant system is 39 closed, recirculating heavy water (D 2 O) in an aluminum and stainless steel system. Heat from 40 the reactor is transferred to a secondary cooling system of light water, and then to the 41 Introduction 1-4 atmosphere by means of evaporation from a cooling tower located outside the confinement 1 building (NIST 2004). The current OL for the NBSR expired on May 16, 2004. By letter dated 2 April 9, 2004, NIST submitted an application to the NRC to renew this OL for an additional 3 20 years of operation (NIST 2004). Because the license renewal application was filed in a 4 timely manner under 10 CFR 2.109, the license is not deemed to have expired until a final 5 determination has been made on the application.

6 71.4The Purpose and Need for the Proposed Action 8 9 Although a licensee must have a renewed license to operate a reactor beyond the term of the 10 existing OL, the possession of that license is just one of a number of conditions that must be 11 met for the licensee to continue plant operation during the term of the renewed license.

12 13 The NIST Center for Neutron Research is a national resource used by up to 2000 engineers 14 and scientists per year for research in materials science, non-destructive evaluation, chemistry, 15 biology, trace analysis, neutron standards and dosimetry, nuclear physics, and quantum 16 metrology. A large cold neutron source (which slows neutrons to speeds of 1000 m/s or less 17 and produces very low energy neutrons for research purposes) and seven neutron guides 18 provide the United States with world-class capabilities in cold neutron research. The NBSR is 19 used by engineers and scientists from all over the country, and is operated 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> a day, 7 20 days a week with routine shutdowns every 5 to 6 weeks for partial refueling and, as needed, for 21 maintenance. A study by an interagency working group of the Office of Science and 22 Technology Policy (OSTP 2002) stated that the NIST Center for Neutron Research was the 23 highest performing neutron facility in the United States at that time.

24 25 Thus, for this license renewal review, the NRC considers the purpose and need for the 26 proposed action (renewal of the NIST NBSR operating license) is to provide an option allowing 27 for neutron research capabilities beyond the term of the current reactor OL to meet national 28 research and test facility needs, as such needs may be determined by NIST (and other Federal 29 decisionmakers).

30 31 This definition of purpose and need reflects the Commission's recognition that, unless there are 32 findings in the safety review required by the At omic Energy Act of 1954 or findings in the NEPA 33 environmental analysis that would lead the NRC to reject this license-renewal application, the 34 NRC does not have a role in the research-planning decisions as to whether this reactor should 35 continue to operate. From the perspective of the licensee, the purpose of renewing this OL is to 36 maintain the availability of specific research capabilities beyond the current term of NIST's OL.

37 38 39 Introduction 1-51.5Compliance and Consultations 1 2 The NBSR uses municipal water for cooling and discharges into the municipal sewer in 3 accordance with the NIST campus discharge permit. The NIST campus is not within Maryland's 4 coastal zone; therefore, the site is not subject to the Coastal Zone Management Act. NRC staff 5 consulted with the Maryland Historical Trust regarding the potential renewal of the OL for the 6 NBSR and determined, in accordance with 36 CFR 800.3(a)(1), that renewal would be an 7 activity that does not have the potential to cause effects on historic properties.

8 9 Section 7(a)(2) of the Endangered Species Act states that Federal agencies are to consult with 10 the U.S. Fish and Wildlife Service (FWS) to ensure that any agency action is not likely to 11 jeopardize the continued existence of any endangered species or threatened species or result 12 in the destruction or adverse modification of habitat of such species. Although no threatened or 13 endangered species are known to occur on the NIST campus, official consultation has been 14 initiated with the FWS.

15 161.6References 17 18 10 CFR Part 51. Code of Federal Regulations, Title 10, Energy, Part 51, "Environmental 19 Protection Regulations for Domestic Licensing and Related Regulatory Functions."

20 21 69 FR 56462. "Notice of Acceptance for Docketing of the Application and Notice of Opportunity 22 for a Hearing Regarding Renewal of the National Bureau of Standards Reactor (The NBSR) 23 Facility Operating License No. TR5 for an Additional Twenty-Year Period."

Federal Register

, 24 Vol. 69, No. 182, pp. 56,462-56,464. September 21, 2004.

25 26 70 FR 56935. "National Institute of Standards and Technology, National Bureau of Standards 27 Reactor; Notice of Intent to Prepare an Environmental Impact Statement and Conduct Scoping 28 Process."

Federal Register , Vol. 70, No. 188, pp. 56,935-56,936. September 29, 2005.

29 30 Atomic Energy Act of 1954 (AEA). 42 USC 2011, et seq.

31 32 Coastal Zone Management Act (CZMA). 16 USC 1451, et seq.

33 34 Endangered Species Act of 1973. 16 USC 1531, et seq.

35 36 National Environmental Policy Act of 1969 (NEPA). 42 USC 4321, et seq.

37 38 National Historic Preservation Act of 1966. 16 USC 470, et seq.

39 40 National Institute of Standards and Technology (NIST). 2004. Environmental Report for 41 Introduction 1-6 License Renewal for the National Institute of Standards and Technology Reactor - NBSR. 1 Docket No. 50-184, License No. TR5, Gaithersburg, Maryland. ML041120176.

2 3 National Institute of Standards and Technology (NIST). 2004. Letter dated April 9, 2004 from 4 Seymore H. Weiss, Chief Reactor Operations and Engineering.

Subject:

License Renewal 5 Application for the National Institute of Standards and Technology Reactor. ML041120167.

6 7 Office of Science and Technology Policy (OSTP). 2002.

Report on the Status and Needs of 8Major Neutron Scattering Facilities and Instruments in the United States. Washington, D.C.

9 10 U.S. Nuclear Regulatory Commission (U.S.NRC). 1996. Generic Environmental Impact 11Statement for License Renewal of Nuclear Plants. NUREG-1437, Volumes 1 and 2, 12 Washington, D.C.

13 14 U.S. Nuclear Regulatory Commission (U.S.NRC). 1999. Generic Environmental Impact 15Statement for License Renewal of Nuclear Plants, Main Report , "Section 6.3 - Transportation, 16 Table 9.1, Summary of findings on NEPA issues for license renewal of nuclear power plants, 17 Final Report." NUREG-1437, Volume 1, Addendum 1, Washington, D.C.

18 2-1 2.0 Description of Reactor, Site, and Reactor 1 Interaction with the Environment 2 3 4 The National Institute of Standards and Technology (NIST) Center for Neutron Research is a 5 reactor-laboratory complex providing NIST and the nation with a facility for the performance of 6 neutron-based research. The heart of this facility is the National Bureau of Standards Reactor 7 (NBSR). The facility is located on the 234.5-ha (579.5-ac) NIST campus in upper Montgomery 8 County, Maryland, approximately 32 km (20 mi) northwest of the District of Columbia (U.S.

9 NRC 2007). NIST is a non-regulatory Federal agency of the U.S. Commerce Department within 10 the Technology Administration.

11 12 The NIST Center for Neutron Research is a national resource used by nearly 2000 engineers 13 and scientists each year. In 2002, researchers came to the center from all areas of the country, 14 including 30 other Federal laboratories, 127 universities, 47 industrial laboratories, and 21 NIST 15 divisions and offices. The major research areas include materials science, non-destructive 16 evaluation, chemistry, biology, trace-el ement analysis, neutron standards and dosimetry, 17 nuclear physics, and quantum metrology. A large cold neutron source and seven neutron 18 guides provide the United States with capabilities in cold-neutron research, and up to 25 cold 19 and thermal neutron instruments provide neutron scattering capability. As a result, the Center 20 for Neutron Research served over 60 percent of the neutron users in the United States during 21 the period 2000 through 2003. The reactor is operated 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> per day, 7 days per week, 22 which allows for the operation of an extensive user program (NIST 2004).

23 24 Unless otherwise indicated, information in the following sections was adapted from the 25 Environmental Report (ER) submitted by NIST for renewal of the NBSR operating license (OL) 26 (NIST 2004a) and was independently verified by the staff. Additional information was obtained 27 by the staff during the site audit (U.S. NRC 2007); appropriate citations will be made for other 28 sources. The plant and its environment are described in Section 2.1, interactions of the plant 29 with the environment are presented in Section 2.2, and references are listed in Section 2.3.

30 312.1Reactor and Site Description and Proposed Reactor 32 Operation During the License Renewal Term 33 34 The NIST Center for Neutron Research reactor-laboratory complex provides NIST and the 35 nation with an extensive facility for neutron-based research in biology, chemistry, engineering, 36 materials science, and physics.

37 38 Reactor and the Environment 2-22.1.1External Appearance and Setting 1 2 NIST is located within the Interstate-270 (I-270) Technology Corridor, as shown in Figures 2-1 3 and 2-2. This corridor is sited strategically in the center of Montgomery County and constitutes 4 the county's primary focus of economic and transportation activity. The corridor straddles I-270 5 from the I-495 Washington Beltway to the south, to Clarksburg on the north. Figure 2-3 6 provides an overview of the NIST campus, and Fi gure 2-5 shows the layout of the NIST Center 7 for Neutron Research reactor-laboratory complex in Building 235.

8 9 The site is suitable for the NBSR, given the reactor's characteristics (see Section 2.1.2). In 10 particular, it operates at low power, at near-atmospheric pressure, and at low temperature.

11 Consequently, there is neither a large inventory of radioactive fission products nor stored 12 thermal energy to disperse that inventory to the surrounding area. The NBSR facility also has a 13 confinement building to limit any radiological re lease to the environment in the unlikely event of 14 an accident.

15 Figure 2-1. Regional Map 16 Reactor and the Environment 2-3 Figure 2-2. NIST Immediate Area 1 2 3

Reactor and the Environment 2-4 Figure 2-3. NIST Photographic View 1 2 3

Reactor and the Environment 2-5 2.1.1.1 Specification and Location 1 2 The NIST Center for Neutron Research is located on the 234.5-hectare (579.5-acre) NIST 3 campus (U.S. NRC 2007) in upper Montgomery C ounty, approximately 32 km (20 mi) northwest 4 of Washington, D.C. (Figure 2-1). The NIST Center for Neutron Research reactor-laboratory 5 complex is located on Center Drive in the southern portion of the NIST campus in Gaithersburg, 6 Montgomery County, Maryland (Figures 2-2, 2-3, and 2-4). There are no prominent natural 7 features in the immediate vicinity of the reactor, and the most prominent man-made feature is 8 I-270 adjacent to the eastern boundary of the NIST campus.

9 102.1.1.2 Access Control and Emergency Planning Zone 11 12 Only portions of the Center for Neutron Research facility in Building 235 are directly affected 13 by the U.S. Nuclear Regulatory Commission (NRC) license: those include parts of the 14 confinement building in C-Wing under licensed operations, the Guide Hall and its auxiliary 15 building in the Cold Neutron Guide Hall in G-Wing, the ventilation stack east of the pump house, 16 the emergency control station (ECS) and the fuel storage area (FSA) located in the A-Wing 17 basement area, the heating, ventilation and air conditioning (HVAC) and electrical service 18 equipment in the B-Wing basement, and also the high-bay area located on the main level of the 19 B-Wing immediately adjacent to the east side of the confinement building.

20 21 There are a number of access controls related to the reactor:

22 23 The NIST boundary fence, which surrounds the campus - Access is 24 controlled by NIST Security, and access is limited to employees, 25 contractors, and individuals who have business onsite. This includes 26 the NIST Child Care Center, which lies within 1 km (0.6 mi) of the 27 reactor.28 29 The NBSR site boundary, which is marked by the perimeter fence that 30 surrounds Building 235, including the nearby cooling towers, the 31 chemical building, and Building 418, which includes a radioactive waste 32 storage and shipment building in the H-Wing. Within this area, 33 unescorted access is limited to those individuals on the access list; all 34 others require an escort.

35 36 The reactor operations boundary, which coincides with the building 37 perimeter - This includes the G-Wing and its auxiliary support building 38 (compressor building for cold neutron cryostat in F-Wing and the 39 experiment support space in J-Wing), the office areas and support 40 spaces in E-Wing, and the radioactive waste storage area west of 41 B-Wing.42 Reactor and the Environment 2-6 1 Figure 2-4. NIST Center for Neutron Research 2 3 Reactor and the Environment 2-7 The Emergency Planning Zone (EPZ) is marked by a 400-m (0.25-mi) radius centered on the 1 ventilation stack. There is no public access to the EPZ, which is located entirely within the NIST 2 campus, and access is limited to individuals having business there. The NIST Child Care 3 Center lies outside the EPZ.

4 5 2.1.1.3 Population Distribution 6

7 Because the NBSR lies entirely on the NIST campus, the area immediately around the reactor 8 contains laboratories and office buildings but no residential buildings and no part-time, transient, 9 or seasonal residents. Permanent residences are at least 400 m (0.25 mi) directly to the east 10 and the west of the reactor.

11 12 Populations within the 1-, 2-, 4-, 6-, and 8-km (0.6-, 1.2-, 2.5-, 3.7-, and 5-mi) radii around the 13 reactor were estimated from the 2000 Census population counts by jurisdiction for the voting 14 districts located within these areas. Table 2-1 provides current populations for the five radii for 15 the year 2000, based on the voting district data, as well as projections for the population in 2010 16 and in 2025. These values were derived by applying the percentage changes, as determined 17 from the Montgomery County planning area forecasts listed in 2000 Census data (USCB 2000).

18 For voting districts that cross into more than one of the zones around the NBSR, the percentage 19 area located within each ring was estimated, and the population distribution within any one 20 district was assumed to be in proportion to the area.

21 22 NIST and the NBSR lie within Montgomery County, which is the most populous county in the 23 State of Maryland. Table 2-2 provides the 1950 to 2000 Census Population and percentage 24 changes for the County. Table 2-3 lists population forecasts from 2000 through 2025 for 25 Montgomery County, as provided by the National Capital Park and Planning Commission -

26 Montgomery County Planning Board, and Table 2-4 provides the Montgomery County Planning 27 Area forecasts for 2005 to 2025.

28 29 Table 2-1. Population Estimates 30 31 Circle Radii (km) 32200020102025 133346236774054 23419,17820,36722,457 43573,12177,65485,624 636155,402168,163180,247 837218,752237,848253,100 38 39 Reactor and the Environment 2-8 Table 2-2. Montgomery County Population 1 2 Year 3PopulationPercentage Change 19504164,401n/a 19605340,928107.4 19706522,80962.0 19807579,05310.8 19908757,02730.7 20009873,34115.4 10 Table 2-3. Montgomery County Population Forecasts 11 12 Year 13PopulationPercentage Change 200014873,341n/a 200515925,0006.0 201016975,0005.4 2015171,020,0004.6 2020181,050,0002.9 2025191,070,0001.9 20 Table 2-4. Montgomery County Planning Area Forecasts for Population 21 22 Planning 23 Area 24 Year20052010201520202025 Darnestown2512,900013,30013,90014,60014,600 Gaithersburg26125,400127,900133,300139,000141,000 Germantown2781,00082,30085,60086,80086,800 Potomac2844,80046,00047,80049,60050,200 Rockville2948,90052,50051,00050,10050,000 30 Reactor and the Environment 2-9 Surrounding the NIST campus is the city of Gaithersburg, which encompasses all of the 2-km 1 (1.25-mi) radius around the reactor and most of 4-km (2.5-mi) radius. All of the town of 2 Washington Grove and much of the city of Rockville lie within the 8-km (5-mi) circle. Other 3 unincorporated areas of Montgomery County with in an 8-km (5-mi) radius are Germantown, 4 Montgomery Village, Darnestown, and North Potomac. According to the 2000 Census, the 5 Germantown area was the seventh most populous community in Maryland with 55,419 6 residents; Gaithersburg was tenth with 52,613; Rockville was fourteenth at 47,388; and 7 Montgomery Village was twenty-first at 38,051. In terms of percentage growth of their 8 populations between 1990 and 2000, this represents an increase of 35, 33, 5.7, and 18 percent, 9 respectively. Table 2-5 presents the 1990 and 2000 Census Data for these communities.

10 11 Table 2-5. NBSR Site Area Census Data 12 13 141990 Population2000 Population Gaithersburg1539,54252,613 Rockville1644,83547,388 Washington Grove17--515 Germantown1841,14555,419 Montgomery Village1932,31538,051 North Potomac20--23,044 Darnestown21--6378 222.1.1.4 Nearby Industrial, Transportation, and Military Facilities 23 24 NIST is located between several major roads, with I-270 at the northeast boundary. I-270 is a 25 major commuter and truck route between northern Montgomery County, Frederick County, and 26 other points north to the employment areas in the Washington, D.C., metropolitan area. The 27 I-270 Technology Corridor is also a major research and development center in the State of 28 Maryland. Nevertheless, no significant manufacturing plants, such as chemical plants or 29 refineries, are located near the reactor, and mining and quarrying operations are limited to those 30 associated with constructing new office buildings. A natural gas pipeline lies 3.2 km (2 mi) 31 south of the reactor, and a liquid petroleum/gas pipeline is located 1.6 km (1 mi) north.

32 33 Three arterial and collector roads abut the NIST campus boundaries: West Diamond Avenue 34 forms the northern campus boundary; Quince Orchard Road the northwest boundary; and 35 Muddy Branch Road the southeast boundary. The arterials and collectors serve the 36 Gaithersburg area, providing truck access. Parallel to the northeast boundary of the NIST 37campus is a CSX rail line (CSX Transportation Corporation). At its closest point to the reactor, it 38 is approximately 2 km (1.25 mi) away from the NIST boundary. This rail line carries goods and 39 commuters through the region, providing service to the Maryland Rail Commuter (MARC) train 40 Reactor and the Environment 2-10 in northern Montgomery County, Frederick County, and other points north for commuters 1 traveling to Washington, D.C. The nearest MARC station is the Gaithersburg Station, 3 km 2 (1.75 mi) away; the nearest Metro Station into the Washington, D.C. area is the Shady Grove 3 Station, 5 km (3 mi) away.

4 5 Three commercial airports serve the region: Dulles International Airport (IAD) in northern 6 Virginia is 29 km (18 mi) from the reactor, Ronald Reagan Washington National Airport (DCA) in 7 Virginia just across the Potomac River from Washington, D.C. is 40 km (25 mi) away, and 8 Baltimore-Washington International Thurgood Marshall Airport (BWI) near Baltimore, Maryland 9 is 47 km (29 mi) away. Andrews Air Force Base , the nearest military airbase, is approximately 10 52 km (32.5 mi) away. No normal air routes, holding patterns, or approach patterns associated 11 with these airports cross the airspace above the NIST campus.

12 13 The Montgomery Airpark , a general aviation airpor t, is approximately 7 km (4.5 mi) northeast of 14 the reactor and it lies 140°/320° relative to magnetic north; that is, it is nearly perpendicular to 15 the line between the reactor and the airfield. Approximately 140,000 annual take-offs and 16 landings occur at this field, with the typical air traffic consisting of small local aircraft, news 17 aircraft, and an occasional military helicopter. The National Transportation Safety Board 18 database (covering 1962 to the present) revealed 6 fatal air accidents and 18 non-fatal 19 accidents in the Gaithersburg area. All but one of these accidents involved either airplanes or 20 helicopters (one involved a balloon), and all were within 3 km (2 mi) of the Airpark. Small 21 planes using the Airpark pose minimal risk to safe operation of the reactor.

22 23 Although there are a few recreational lakes within the area, the nearest major waterway is the 24 Potomac River that forms the border between Maryland and Virginia. Its nearest point is 10 km 25 (6.2 mi) from the reactor.

26 27 As described in the preceding sections, the NBSR is located in an urban setting with certain 28 normal risks associated with transporting goods and materials on nearby highways and rail 29 lines. These risks are regulated by several agenc ies, primarily by the U.S. Department of 30 Transportation, to ensure safety. Also, the NIST campus serves as a buffer separating these 31 transportation corridors from the reactor. The NIST campus also acts as a buffer between the 32 NBSR and the surrounding community. This provides operators with greater control over the 33 immediate area should there be an accident at the reactor.

34 352.1.2Description of Reactor Complex 36 37 The NBSR is a heavy-water-moderated and -cooled, enriched fuel, tank type reactor designed 38 to operate at 20-MWt (megawatts thermal power). It is a custom-designed variation of the 39 Argonne CP-5 class reactor. The NBSR uses U 3 O 8 aluminum dispersion fuel enriched to 40 93 percent. The fuel is aluminum-clad materials-testing-reactor (MTR) plate-type fuel. The core 41 Reactor and the Environment 2-11 is immersed in heavy water (D 2 O) to slow the fast-moving neutrons that sustain the nuclear 1 fission reactor, to dissipate heat created by the reaction, and to function as the first stage of 2 shielding. Heavy water also allows high neutron fluxes that would not be otherwise achievable 3 in a facility the size of the NBSR. This type of reactor (using MTR fuel and heavy water coolant) 4 is similar to those used at a number of other government research facilities.

5 6 The primary coolant is also heavy water, which is circulated through a closed aluminum and 7 stainless steel system. The heavy water is pumped through plate-type heat exchangers, where 8 heat is transferred to a secondary cooling system before returning it to the core. The secondary 9 system consists of plate-type heat exchanger s and a plume suppression cooling tower that 10 contains about 500,000 L (132,000 gal) of light water (H 2 O). Heat in the secondary system is 11 transferred to the atmosphere by evaporation of water from the cooling tower, which is located 12 outside the confinement building.

13 14 The design of the NBSR includes many inherent passive safety features. The prompt neutron 15 lifetime is relatively long as a result of heavy water moderation. The reactivity coefficients of 16 void and temperature are negative. The reactor operates in a low temperature, unpressurized 17 condition and does not have a large stored energy content. Two inner structures within the 18 reactor vessel retain heavy water in the event of a loss of water from the reactor core. In the 19 event of a loss of cooling water, one of these structures immediately supplies emergency 20 coolant flow to the fuel elements without any operator intervention, while the other maintains 21 water around the lower half of the core. An overhead reserve tank can supply heavy water for 22 emergency cooling either to the top or to the bottom of the elements for extended periods of 23 time.24 25 The NIST laboratory complex includes the NBSR confinement building, which is constructed of 26 reinforced concrete and situated partially below grade. The complex includes nuclear-science-27 related research and other reactor support functions. The confinement building has an 28 independent ventilation control system, and is capable of operating in isolation mode or dilution 29 mode to exhaust air to the atmosphere through a 30-m (100-ft) stack.

30 312.1.3Experimental Facilities 32 33 The NBSR is used for research, the majority of which uses neutrons to study material 34 constituents, processes, and structure. The reactor design was chosen because of its 35 thermalized (low energy) neutron spectrum, its hi gh neutron flux, its flexibility for research, and 36 its inherent safety. The high neutron fluxes generated by the NBSR are used in five principal 37 ways: 38 39 to characterize the structure and dynamics of materials critical to the U.S. economy 40 to image large structures, and to study nuclear and neutron physics 41 Reactor and the Environment 2-12 to develop material and radiation standards 1 to generate radioisotopes for activation analysis and tracer production 2 to study the effects of radiation on materials through in-core irradiation.

3 4 Experimental facilities supporting these activities are described in the following sections.

5 6 The NBSR has a wide range of research capabilities and a large number of experimental beam 7 lines. The liquid hydrogen cold source provides cold neutrons (neutrons slowed to speeds of 8 1000 m/s or less) directly to experiments in the confinement building, and through a network of 9 seven neutron guides, to experiments located in the Cold Neutron Guide Hall. Beam tubes 10 provide thermal neutrons for experiments locat ed within the confinement area immediately 11 adjacent to the reactor. A pneumatic "rabbit" system provides researchers with the ability to 12 automatically inject samples into the core region of the reactor, while vertical thimbles provide 13 for manual sample loading.

14 15 Eleven insertion positions are available for experiments within the core structure itself, and 16 seven positions are available in the reflector. Nine beam tubes are arranged in a radial pattern 17 within the central plane of the core and "see" the neutron flux in the unfueled gap region. Two 18 beam tubes run completely through the reactor on either side of the core just below the radial 19 tubes. The reactor includes a large experimental thimble within which a low temperature liquid 20 hydrogen moderator or cold source is installed. This moderator increases the intensity of cold 21 neutrons available to the beams from this neutron source. Seven neutron guide tubes, which 22 transport cold neutron beams with losses of less than 1 percent per meter into an adjacent 23 neutron experimental building or neutron guide hall, and one beam port, which does not go to 24 the Guide Hall, are served by this source. Five pneumatic tubes comprise the rabbit system 25 that operates using pressurized carbon dioxide (CO 2). This system allows the rapid insertion 26 and removal of small samples into various parts of the core, reflector, and thermal column. A 27 large volume of well-thermalized neutrons is also available in the graphite thermal column.

28 29 2.1.3.1 Neutron Beams 30 31 The cross-sectional area of the neutron beams at the NBSR typically have ranges from a 32 few mm 2 to 200 cm

2. Beams associated with an in-beam dose rate in excess of 1 mSv/hr 33 (100 mrem/hr) and are accessible (have an open path in excess of 30 cm) are designated as 34 High Radiation Areas. A characteristic of neutron beams is the radiation field outside of the 35 beam is typically less than 0.05 mSv/hr (5 mr em/hr). Occasionally, experimental samples or 36 equipment, such as collimators or filters, can result in Radiation Area or possibly High Radiation 37 Area conditions near the beams. These areas are controlled as required by Title 10 of the Code 38 of Federal Regulations (CFR) Part 20, Sections 1601 and 1902. Non-beam-related and 39 short-term experiments are shielded and controlled to keep personnel exposures "as low as 40 reasonably achievable" (ALARA).

41 42 Reactor and the Environment 2-13 2.1.3.2 Thermal Column Facility 1 2 The Thermal Column Facility provides highly thermalized neutron beams and is typically 3 controlled as a High Radiation Area (per 10 CFR 20.1601). The facility is used to perform 4 experiments requiring large cross-section exposur es involving irregular exposure geometries or 5 full-field exposure geometries.

6 72.1.3.3 Pneumatic System and In-Core Exposure Facilities 8

9 Experiments using the pneumatic system and in-c ore exposure facilities are highly variable, 10 frequently producing multi-curie activity sources. ALARA concerns are addressed by shielding 11 the source and by allowing sufficient decay time prior to direct manipulation, processing, or 12 analysis. Technical review and administrative authorization processes are used to control these 13 facilities' activities, usage, disposal, and potential personnel exposures.

14 15 2.1.3.4 Cold Neutron Experiments 16 17 The guides for cold neutron experiments are fully shielded to the point of neutron beam 18 extraction where possible. At the entry wall to the Guide Hall, the unshielded dose rate from a 19 typical guide is 3 mSv/hr (300 mrem/hr) (neutron) and 1 mSv/hr (100 mrem/hr) (gamma) at 1 m 20 (3.3 ft) from the guide. All seven guides in the Guide Hall have primary shutters. These 21 shutters are key-controlled and have status indicators (opened or closed). With the shutter 22 closed, the design allows unrestricted access for disassembly and work on experiments 23 associated with a particular guide.

24 252.1.4Radioactive Waste Management Systems and Effluent Control Systems 26 27 NIST has a structured radiation protection program that supports all aspects of the NBSR 28 operations. The health physics staff is equipped with radiation detection equipment to 29 determine, control, and document all occupational radiation exposures. An environmental 30 monitoring program is in place to determine if potential radiation exposures to members of the 31 public in unrestricted areas surrounding the reactor remain within regulatory standards and 32 guidelines.

33 34 The overall radioactive waste management and e ffluent control programs for the NBSR are 35 described in this section. NIST has established policies that employ the ALARA concept in all 36 operations at the NBSR, and operations at the NBSR and experimental facilities are conducted 37 to minimize radioactive effluents and waste production consistent with ALARA objectives.

38 39 Reactor and the Environment 2-14 2.1.4.1 Radiation Sources 1 2 Sources of radiation monitored and controlled by the radiation protection and radioactive waste 3 management programs are described in this section.

4 5 Radiation sources at the NBSR can be classified into four general classes:

6 7 Calibration and check sources 8 9 Startup sources and other sources used for instrumentation and nuclear support 10 functions 11 12 Gaseous, liquid, and solid radiation sources from reactor operations 13 14 Radiation sources produced within the experimental facilities.

15 16 Sources of radioactivity that may be found in various reactor and support systems are listed in 17 Table 2-6.

18 192.1.4.2 Liquid Waste Processing Systems and Effluent Controls 20 21 The dominant radionuclides in liquid effluents at the NBSR are tritium (H-3) and N-16. Other 22 minor liquid sources are also discussed in subsequent sections.

23 24Reactor Primary Coolant 25 26 The NBSR primary coolant consists of high purity heavy water. The radionuclides in liquid 27 effluents at the NBSR are primarily tritium and N-16.

28 29 The following reactions produce most of the radioactive materials in the primary coolant:

30 31 Tritium, a low-energy beta-emitter, produced via H-2(n,)H-3 32 33 N-16, a high-energy beta- and gamma-emitter, produced via O-16(n,p)N-16 34 35 36 Reactor and the Environment 2-15 Table 2-6. NBSR Systems and Radiation Sources 1 2NBSR System 3 Major Sources ofRadioactivity Minor Sources ofRadioactivity Primary coolant4H-3, N-16, Co-60Ar-41, Na-24, Mn-54, Mn-56, Cr-51, Sb-122, Sb-124 Primary pipe (internal 5 contamination) 6Co-60, H-3Cr-51, Zn-65 Helium sweep7Ar-41Kr-85m, Kr-87, Kr-88, Xe-131m, Xe-133, Xe-135, Xe-135m, Xe-138, Cs-138Thermal Shield Cooling System8Cu-66, Cu-64, Ag-110m, Zn-65N-16 Reactor shield plug/refueling 9 plug 10---------------Al and steel activation products, C-14 Air11Ar-41, H-3Br-82, Cl-38, Cs-138 CO 2 sweep gas12Ar-41Br-82, Cl-38, S-35 Storage pool13H-3Aluminum activation products from fuel cutting Fuel pieces (6061 aluminum, 14 stainless steel) 15Fe-55, Co-60, Zn-65Ni-63, Mn-54 Resin beds16Co-60, Zn-65-------------------

Neutron guides17Zn-65Co-58, Ni-59 Pneumatic system18Co-60, Ag-110m, Zn-65-------------------

19 Na-24, a high-energy beta- and gamma-emitter, produced via Al-27(n,)Na-24 20 21 Al-28, a high-energy beta- and gamma-emitter, produced via Al-27(n,)Al-28 22 23 Co-60, a low-energy beta- and high-energy gamma-emitter, produced via 24 Co-59(n,)Co-60 25 26 Cr-51, a low-energy gamma-emitter, produced via Cr-50(n,)Cr-51.27 28 Other radionuclides in the primary coolant that contribute minor portions to the total liquid 29 radiation source include Zn-65, Mn-56, Tc-99m, and Sb-122, which are associated with 30 suspended corrosion products activated by neutrons.

31 32 Tritium could potentially be a significant sour ce of exposure from airborne contamination 33 because of evaporation of tritiated heavy water. Either inhalation or exposure by direct contact, 34 through skin absorption, could result in significant exposures. Therefore, any work involving 35 potential exposure by these mechanisms requires control measures, such as containment, eye 36 protection, gloves, and protective clothing, to minimize and prevent such an occurrence.

37 Reactor and the Environment 2-16 Individuals who perform this work are required to undergo periodic tritium bioassays. Other 1 radionuclides are present at such low concentrations they have minimal potential for intake via 2 inhalation or skin absorption.

3 4 N-16 is the greatest operational source of external radiation exposure from the primary piping 5 system. N-16 has a short half-life (7 seconds), so exposure from this source diminishes very 6 rapidly after the reactor is shut down. At the NBSR, the Process Room and the Monitoring 7 Room are areas where a potential for exposure from N-16 exists.

8 9 Na-24 is present in the primary coolant at concentrations on the order of 0.1 mCi/L. It 10 represents a transient source of external exposur e in the process room. Because of its short 11 half-life (15 hours1.736111e-4 days <br />0.00417 hours <br />2.480159e-5 weeks <br />5.7075e-6 months <br />), work in the process room is limited for the first day following shutdown as an 12 ALARA measure.

13 14 Other than tritium, Cr-51 is the highest activi ty and longest-lived (half-life 27.7 days) primary 15 system contaminant. Because it is a low-energy gamma emitter, Cr-51 is almost completely 16 self-shielded by the primary system components.

The activity is dominated by Cr-51 in primary 17 components immediately following removal from the reactor.

18 19 Because Cr-51 decays relatively quickly, Zn-65 and Co-60 become the dominant sources of 20 residual contamination after several months. Loca lized external contamination occurs at valves, 21 heat exchangers, filters, and resin beds, and ranges from a few hundredths of a mSv/hr (few 22 mrem/hr) to 0.5 Sv/hr (50 rem/hr). Control of personnel exposure is accomplished through 23 shielding and posting of areas. Components with higher dose rates, such as primary coolant 24 filters and resin beds, are shielded to reduce the radiation levels to less than 0.05 mSv/hr 25 (5 mrem/hr), and exposures from other areas are controlled through local posting. The general 26 area dose rates in the process room are routinely surveyed because of the cumulative effect of 27 the longer-lived internal contaminants. Proce ss room survey data are made available for work 28 planning.29 30 Other potential, but unlikely sources of radionuclides from liquid sources include the reactor 31 secondary coolant system, the thermal column D 2 O tank coolant system, the thermal shield 32 cooling system, and the fuel storage pool.

33 34 Liquid Waste 35 36 The liquid waste collection facility consists of a 3785-L (1000-gal) tank, two 18,900-L (5000-gal) 37 tanks, various filters, and related pumps and valves. Water is collected, sampled, and analyzed 38 for its radioactive constituents and then filtered to meet 10 CFR 20.2003 solubility requirements 39 before being released to the sanitary sewer. Credit is taken for the daily NIST site release 40 volume of approximately 984,100 L (260,000 gal) to meet the 10 CFR 20.2003 concentration 41 limits.42 Reactor and the Environment 2-17 If unanticipated quantities of radioactive material are accumulated in the system, the 1 contaminated water can either be circulated through filters or resin beds to reduce the 2 radionuclide concentration, transferred to containers for offsite processing at a NRC licensed 3 facility, or stored to allow radioactive decay to reduce the level of activity. When practicable, a 4 general ALARA operating practice at the NBSR is to collect any higher activity liquid wastes at 5 the source and to process and dispose of that waste separately.

6 72.1.4.3 Gaseous Waste Processing Systems and Effluent Controls 8

9 Three gaseous waste streams associated with the reactor facility include the normal air, 10 irradiated air, and process room ventilation syst ems. Processes that might generate airborne 11 particulate or gaseous contamination are vented through one of these systems. Gases in these 12 systems are passed through high efficiency particulate air (HEPA) filters prior to release via the 13 stack. For an upset or abnormal operating condition, these ventilation systems can be operated 14 in recirculation mode, and a standby charcoal f ilter is made operational. Monitoring systems in 15 the stack and in the building ventilation utilize both installed and periodic sampling. This 16 provides redundant methods for assessing and controlling both occupational and public 17 exposure.18 19 Ar-41 Sources 20 21 Ar-40 is a natural constituent of air, at about 0.93 percent. Any air volume that is exposed to 22 neutrons will contain Ar-41 produced by the Ar-40(n,)Ar-41 reaction. Ar-41 is a strong beta-23 and gamma-emitter with a half-life of 110 minutes. At the NBSR, engineering and procedural 24 measures have been established to minimize Ar-41 production.

25 26 Tritium 27 28 The tritium produced by the heavy water moderator/coolant of the reactor yields a primary 29 coolant tritium concentration of 1.1 x 10 10 Bq/L/yr (0.3 Ci/L/yr). As an ALARA measure, NIST 30 replaces the heavy water at intervals designed to limit exposure to tritium. All used heavy water 31 is stored onsite until transfer to authorized processors for recycling. With a maximum tritium 32 production concentration of 18.5 x 10 10 Bq/L (5 Ci/L), the exposures discussed in this section for 33 the NBSR would increase by no more than a factor of 5.

34 35 During normal operations, the primary release pathway for tritium results from helium leakage 36 into the ventilation system. Helium can become saturated with heavy water vapor when used 37 as a cover gas to minimize air intrusion into the primary cooling system. Activation of heavy 38 water in the helium cover gas produces tritium. Secondary pathways include refueling or any 39 maintenance activity that exposes heavy water to the air. Conditions involving an abnormal loss 40 of coolant, such as a seal failure or a primary coolant boundary failure, would be identified by 41 Reactor and the Environment 2-18 monitoring and leak detection systems. The airbor ne tritium monitoring system at the NBSR is 1 capable of detecting tritium concentrations that can occur by water evaporation following a few 2 milliliters of leakage.

3 4 Fission Products 5

6 Noble gas fission products, including gaseous xenon, krypton, and Cs-138 (a decay product of 7Xe-138), can be detected in the helium sweep system over the primary coolant. Based on the 8 typical make-up rate for the helium system, less than 3.7 x 10 9 Bq (0.1 Ci) of those 9 radionuclides are released annually, resulting in release concentrations so low that they 10 represent a negligible contribution to the total gaseous emissions.

11 12 Air Monitoring 13 14 Conditions requiring airborne radioactivity monitoring under 10 CFR 20.1502(b) are rarely 15 present at the NBSR. Two primary airborne radionuclides are detectable at the NBSR: Ar-41 16 and tritium. Area radiation monitors are used to control personnel radiation exposures to Ar-41, 17 and Cary ion chambers or gas Marinelli chambers detect airborne activity concentrations with a 18 sensitivity greater than 0.1 derived air concentration (DAC). For tritium, an installed gas-flow 19 ion chamber system samples representative ar eas of the NBSR building and its ventilation 20 system; it can detect H-3 concentrations of 0.1 DAC and is sensitive to Ar-41. A cold trap also 21 samples for tritium, with samples analyzed using liquid scintillation at a sensitivity greater than 22 10-6 DAC.23 24 In addition to the Ar-41 and tritium monitoring, continuous air monitors (CAMs) are available for 25 airborne particulate and iodine monitoring on an as-needed basis. For instance, one CAM is 26 located in the spent fuel storage pool area. Filter and charcoal cartridge samplers may also be 27 used for iodine and particulate sampling.

28 29 Effluent Monitors 30 31 Airborne effluent at NBSR is monitored for Ar-41 using a G-M (Geiger-Mueller) detector located 32 in the stack. This system is calibrated by comparison to a grab sample that is analyzed in the 33 radioanalysis laboratory. The nominal monitor sensitivity is 1.4 x 10 8 µCi/m.34 35 Tritium in the NBSR stack effluent is continuously monitored by the building tritium monitoring 36 system. Monthly grab samples from the stack are also collected and analyzed for verification.

37 More frequent sampling or additional continuous monitoring is implemented when unusual or 38 non-routine activities involving the potential for additional tritium releases are performed.

39 Effluent sampling can also be performed with a particulate filter and charcoal cartridge, which 40 are analyzed on an as-required basis.

41 42 Reactor and the Environment 2-19 Environmental Monitors 1 2 Environmental (ambient) monitoring is accomplished in several ways. Ambient gamma-3 monitoring is conducted with thermoluminescent dosimeters (TLDs), by a pressurized 4 tissue-equivalent ion chamber system with sens itivity of 0.1 µrad/hr, by environmental G-M 5 monitors with data logging, and by a gain-stabiliz ed sodium iodide system (with a sensitivity of 6 0.01 µrad/hr for Ar-41) for monitoring Ar-41 or other specific gamma-emitters.

7 8 2.1.4.4 Solid Waste Processing 9 10 Solid radioactive waste is any contaminated item having no further usefulness, and for which 11 further decontamination is not practicable. Radioactive wastes are segregated from 12 non-radioactive wastes based on knowledge of where the material was used or from which 13 system it originated. Items that are exposed to neutrons or to sources of contamination are 14 considered potentially radioactive, including irr adiated hardware from experiments or items that 15 came in contact with primary reactor coolant. On occasion, process knowledge suggests an 16 item can be decontaminated. If an item is su ccessfully decontaminated, as determined by a 17 radiation survey and contamination check, it may be released for unrestricted use or disposal.

18 19 Solid Radiation Sources 20 21 Reactor operations include solid sources of radi ation at the NBSR, ranging from items having 22 very low specific activity (e.g., used rubber gloves from handling potentially contaminated 23 materials) to intermediate activity (e.g., activated foils from experiments), and high activity 24 (e.g., spent fuel from the reactor).

25 26 Fuel Elements 27 28 All operations involving movement of irradiated reactor fuel elements are performed underwater 29 to provide shielding. An underwater saw is used to separate non-fuel portions of the spent fuel 30 elements from the fueled portions of the elements, and they are disposed of separately. The 31 dominant radionuclides are Fe-55, Co-60, and Zn-65. Shielding is used to reduce personnel 32 exposure during spent fuel handling operations.

33 34 The fission product inventory for one NBSR fuel element includes radionuclides with a total 35 activity of 1.5 x 10 16 Bq (3.97 x 10 5 Ci). Personnel protection is needed primarily to reduce dose 36 rates from the fuel elements, and all fuel transfers are performed within a shielded pathway.

37 The room through which the elements are transferred is controlled as a Very High Radiation 38 Area during these transfers per 10 CFR 20.1602 requirements. All fuel-handling in the storage 39 pool is monitored with area monitors or surv ey instruments to determine that shielding is 40 adequate.41 42 Reactor and the Environment 2-20 New NBSR fuel elements nominally contain 350 g (0.77 lb) of U-235 and are surveyed for 1 external radiation levels and surface contami nation when they are received. Each element 2 undergoes a quality assurance evaluation before being inserted in the reactor. Dose to 3 operators when handling new unirradiated fuel is minimal because there are no fission or 4 activation products present.

5 6 Other Radioactive Solids 7

8 Other radioactive solids that contribute to personnel dose and waste volume include the 9 following:

10 11 Reactor shims 12 Reactor primary resins, replaced once every 10 to 20 years 13 Reactor primary filters, replaced as needed, usually once or twice per year 14 Filters and resins from other systems 15 Shielding plugs and related neutron beam shields 16 Experiments or experimental components re moved from high neutron flux locations 17 Activated experiment samples and 18 Miscellaneous contaminated materials, such as laboratory waste.

19 20 The radioactive material content of these items ranges from barely detectable levels in the bulk 21 of the waste volume, to curie-quantity material for specific items such as resins. The primary 22 contributor to personnel external dose rate is the Co-60 in the activated metals, resins, and 23 much of the other waste. Material contaminated with Co-60 is stored in restricted areas where 24 access and area dose rates are controlled. Local shielding is used as necessary to limit spaces 25 to less than Radiation Area conditions. Two storage areas are maintained as restricted areas.

26 The concrete shield cave facility in the G-Wing is used to store shielded casks. Other items, 27 such as bulky items with low-level activation (e.g., experiment shields and components), may be 28 stored in Building 418 adjacent to the reactor building.

29 30 Solid Radioactive Waste Characterization and Disposition 31 32 Solid radioactive waste is characterized by direct assay, which involves sampling and direct 33 gamma spectroscopy, as well as by process knowledge.

34 35 Solid radioactive waste is accumulated at the point of production and collected consistent with 36 keeping exposures ALARA. All accumulation containers are appropriately labeled. Collected 37 low-level waste is typically transferred to the H-Wing. Records of the origin of the waste and its 38 radiological contents are kept in preparation for packaging and shipment. Other waste requiring 39 special handling or containing high levels of radioactivity, such as primary filters and large 40 neutron beam shields, is stored at other locations.

41 42 Reactor and the Environment 2-21 Systems, components, and experiments are designed to minimize the production of mixed 1 waste (which contains both chemically hazardous and radioactive constituents) to the maximum 2 extent practicable. Any such waste (e.g., lead or cadmium) that has been exposed to neutrons 3 is segregated and stored until disposal at an authorized facility is arranged.

4 5 All radioactive waste is disposed of in accordance with 10 CFR Part 20, Subpart K. Solid waste 6 is transferred to organizations specifically authorized or licensed to receive the material, such as 7 permitted commercial treatment and disposal facilities or the U.S. Department of Energy (DOE).

8 Materials designated as radioactive waste are transferred to the H-Wing of the NBSR for 9 characterization, packaging, and preparation for transfer to authorized recipients. Annual 10 radioactive waste volumes during 2001 to 2005 ranged from 12 to 16 m 3 (440 to 574 ft 3). During 11 that period, the total radioactivity in waste shipments designated Class A under 10 CFR Part 20 12 was less than 5.6 x 10 10 Bq (1.5 Ci). Two shipments of Class C waste during the same period 13 contained a total of about 5.2 x 10 13 Bq (1400 Ci) of radioactive material. Larger quantities of 14 radioactive waste may be generated in years when unfueled element shipments occur, or when 15 major facility modifications are performed. Based on past experience, these events occur on 16 the order of once every 5 or more years. No radioactive waste designated as Greater than 17 Class C or transuranic waste has been generated at the Center for Neutron Research, nor is 18 such waste anticipated in the future.

19 20 All solid radioactive waste is disposed of by transfer to either licensed disposal sites or 21 processing facilities. It is transported as required by 10 CFR Parts 61 and 71 and by the 22 applicable licenses issued by states to the receiving facilities. Detailed radioactive waste 23 characterization documents and manifests are prepared and retained in accordance with 24 10 CFR 20.2006.

25 26 Reactor and laboratory operations generate small quantities of mixed low-level waste (MLLW), 27 which contains both radioactive and chemically hazardous components. Solid MLLW consists 28 mainly of activated cadmium and lead experim ental components or shielding and is generated 29 at the rate of about 0.06 m 3 (2 ft 3) per year. Removal of reactivity control blades from the 30 reactor accounts for an additional 0.06 m 3 (2 ft 3) of MLLW about every 8 years. The control 31 blades are stored for 7 years to allow radioactive decay so they can be disposed of as Class A 32 waste. Liquid MLLW consists of contaminated cleaning solvents or organic assay solutions 33 generated at the rate of about two 55-gal drums (about 420 L) per year. MLLW is treated as 34 required prior to disposal at facilities specifically permitted for such waste.

35 36 Some structural components of the reactor and neutron beam ports also contain lead and will 37 require disposal as MLLW upon reactor decommissioning. Those components include the 38 reactor thermal shield, which consists of approximately 114,000 kg (250,000 lb) of lead bonded 39 to carbon steel. An additional 4.3 m 3 (150 ft 3) of MLLW consists of neutron beam-port shutters 40 that contain lead incorporated into stainless steel alloys. Those components have been placed 41 into long-term storage until decommissioning.

42 Reactor and the Environment 2-22 Spent fuel is generated at a rate of approximately 28 elements per year and is stored onsite in a 1 storage pool until it can be cut into sections and shipped. Each element contains two 34.37 x 2 8.55 x 7.62 cm (13.5 x 3.4 x 3.0 in.) fueled sections, which are shipped to DOE's Savannah 3 River Site (SRS). Approximately 252 sections with a total volume of about 0.6 m 3 (20 ft 3) are 4 shipped to SRS every 41/2 years. The unfueled sections of the fuel elements are segregated 5 and disposed of as low-level radioactive waste.

6 7 Solid Waste Minimization 8

9 Because the costs of solid radioactive waste disposal are high, materials with low activation 10 potential are used wherever practical to minimize the production of radioactive waste. At the 11 NBSR, experiments are designed to be reusable and to minimize the generation of radioactive 12 material by neutron activation. Radioactive contamination of materials used in experiments and 13 processes is also minimized to the extent practicable.

14 15 Components are disassembled and segregated where possible to minimize quantities of 16 radioactive waste. To the extent practicable, a commercial, HEPA-filtered compactor is used to 17 reduce the volume of compressible materials such as laboratory paper waste and contaminated 18 gloves.19 20 Long-Term Storage 21 22 The policy at the NBSR is to dispose of items identified as waste in a timely manner. There is a 23 long-term storage area located in the G-Wing of Building 235 to accommodate radioactive 24 materials that require storage prior to disposal or for potential reuse. The facility contains 25 33 shielded concrete cavities, each about 3 m (10 ft) deep and varying in diameter. The 26 shielded facility is used to store items that could produce a significant exposure to workers, but 27 which have potential future use. It is also used to store some higher-activity items to allow 28 radioactive decay prior to disposal.

29 302.1.5Nonradioactive Waste Systems 31 32 NIST does not dispose of any non-hazardous solid waste onsite. Tree limbs, shrubs, and other 33 organic matter are chipped, stockpiled, and reused as mulch. During 2005, the NIST site 34 recycled approximately 760 tonnes (840 tons) of waste materials consisting of scrap metal, 35 computers, electronics, paper products, cans, glass, plastic, fluorescent light bulbs, lead-acid 36 batteries, waste oil, mercury, and other chemicals. The remaining non-hazardous solid waste 37 generated at the NIST site, estimated at about 45 tonnes (50 tons) per year, is sent to 38 Montgomery County solid waste processing facilities.

39 40 Reactor and the Environment 2-232.2Interaction of the Reactor with the Environment 1 2 The siting requirements contained in 10 CFR Part 100 apply to applications for site approval for 3 the purpose of operating stationary nuclear power reactors as well as testing reactors. The site 4 evaluation criteria for the NBSR at the NIST Center for Neutron Research within the NIST 5 campus are defined in 10 CFR Part 100, Subpart A, "Evaluation Factors for Stationary Power 6 Reactor Site Applications Before January 10, 1997, and for Testing Reactors."

7 8 The following sections provide general descriptions of the environment near NIST as 9 background information. They also provide detailed descriptions where needed to support the 10 analysis of potential environmental impacts of operation during the renewal term, as discussed 11 in Chapter 3. Section 2.2.11 describes possible impacts associated with other Federal project 12 activities. The discussions presented in this chapter are based on reviews of the most recent 13 site-related information, several past reports, and information published since the last 14 application for license renewal and power upgrade that would have an impact on site safety.

15 162.2.1Land Use 17 18 The NBSR is located on the NIST campus in an unincorporated portion of Montgomery County, 19 Maryland. The campus is approximately 32 km (20 mi) northwest of Washington, D.C. The 20 NBSR is part of the NIST Center for Neutron Research.

21 22 The NIST campus encompasses 234.5 ha (579.5 ac). The Center for Neutron Research 23 reactor-laboratory complex is located on Center Drive in the southern portion of the NIST 24 campus. The NIST campus is located between several major roads. The northeast boundary 25 of the campus abuts Interstate-270 (I-270), a major commuter artery connecting communities in 26 northern Montgomery County, Frederick County, and other points north to the employment 27 areas in the Washington, D.C., metropolitan area. West Diamond Avenue forms the northern 28 boundary of NIST, with Quince Orchard Road as the northwest boundary, and Muddy Branch 29 Road as the southeast boundary. The closest railway parallels the northeast boundary of the 30 NIST campus at a distance of approximately 2 km (1.25 mi) from the NBSR at its closest point.

31 This line carries goods and commuters through the region. The nearest waterway to the NIST 32 campus is the Potomac River, which forms the border between Maryland and Virginia. Its 33 nearest point is approximately 10.3 km (6.4 mi) from the NBSR.

34 35 Montgomery County is not within Maryland's coastal zone for purposes of the Coastal Zone 36 Management Act (MDNR 2002).

37 38 Reactor and the Environment 2-242.2.2Water Use 1 2 The NIST reactor uses from 568,000 to 662,000 liters (150,000 to 175,000 gal) per day of water 3 from the Washington Suburban Sanitary Commission's (WSSC) water supply system. The 4 primary consumptive use of this water is associated with the cooling towers, which provide 5 secondary cooling for the reactor. The average loss of 376,000 liters (100,000 gal) per day 6 from evaporation and drift from the reactor's cooling towers represents less than 0.1 percent of 7 the WSSC's average capacity. The sources of WSSC's water are the Potomac and Patuxent 8 Rivers. About 24 percent of the water withdrawn from the WSSC system is returned as 9 blowdown to the WSSC sanitary system.

10 112.2.3Water Quality 12 13 The NIST reactor discharges non-radiological liquid effluents to the WSSC sanitary sewer 14 system. The majority of the effluent is bl owdown from the cooling towers. The blowdown 15 contains zinc from corrosion prevention measures and elevated dissolved solids from 16 evaporative concentration of existing dissolved solids in the makeup water. NIST operates 17 under the WSSC Discharge Authorization Permit (05813). The permit was issued by the State 18 of Maryland on June 1, 2004, and is scheduled to expire on May 31, 2008.

19 202.2.4Meteorology and Air Quality 21 22 The NIST site is located on the Piedmont Plateau of Maryland, a transitional region between the 23 Blue Ridge Mountains to the west and the Atlantic Coastal Plain to the east. Because of its 24 mid-latitude location and elevation of approximately 128 m (420 ft), the site's climate is 25 classified as continental, with four distinct seasons.

26 27 The climatology of the NIST site can be descr ibed using archived data from two nearby National 28 Weather Service (NWS) observing stations: Dulles International Airport (IAD) (NCDC 2005a) 29 and Ronald Reagan Washington National Airport (DCA) (NCDC 2005b). Although an AWS 30 Convergence Technologies Inc. WeatherNet Weather Station has been installed on the roof of 31 the NIST confinement building since 2002, there is not a sufficient period of data to develop a 32 complete climatology of the site from this data set alone (NIST 2004a).

33 34 Normal daily maximum temperatures for IAD range from a high of 30.8C (87.4F) in July to a 35 low of 5.2C (41.4F) in January. Normal daily minimum temperatures range from 17.8C 36 (64.0F) in July to -5.6C (21.9F) in January. At DCA, average temperatures are somewhat 37 greater, especially normal daily minimum temperatures, which is a result of the station's location 38 in relation to the surrounding city, resulting in a phenomenon called the urban heat island effect.

39 40 Reactor and the Environment 2-25 Precipitation is distributed evenly throughout the year, with annual liquid precipitation amounts 1 averaging 106.17 cm (41.80 in.) at IAD and 99.95 cm (39.35 in.) at DCA. Spring and 2 summertime precipitation is generally from thunderstorms, whereas the bulk of autumn and 3 winter precipitation is from large-scale weather systems moving through the region.

4 Occasionally during the late summer and autumn months, tropical storm remnants can affect 5 the area, bringing widespread and significant precipitation events. Indeed, the greatest 24-hour 6 precipitation amounts of 30.18 cm (11.88 in.) at IAD and 18.26 cm (7.19 in.) at DCA were from 7 hurricane Agnes as it passed east of the region as a tropical storm on June 21-22, 1972 8 (NCDC 2005a, b).

9 10 Annual average snowfall amounts for the area r ange from 53.85 cm (21.2 in.) at IAD to 11 38.61 cm (15.2 in.) at DCA, where it tends to be slightly warmer. January is usually the 12 snowiest month, with two days averaging above 2.

54 cm (1 in.) of snowfall. Heavy snowfall 13 events, though rare, do occur and can bring some 50.8 cm (20 in.) of snow in a 24-hour period 14 to the region.

15 16 Thunderstorms occur approximately 30 days out of the year, with the majority of the 17 thunderstorms occurring during the months of May through August (NCDC 2005a, b). On 18 occasion, these storms are severe, with gusty winds and hail the primary threat. On average, 19 there are 1.1 high wind events and 2.1 hail events per year in Montgomery County 20 (NIST 2004a). Tornado climatology statisti cs from 1950 through 2003 also show that 21 83 tornadoes have occurred within a 1º box that includes the NIST site (Ramsdell 2005). Of 22 these, only 13 tornadoes had intensities of F2 or F3 (winds between 113 and 206 mph) on the 23 Fujita intensity scale, and no reported tornadoes had intensities of F4 or greater. The 24 probability of a tornado striking the site is expected to be 8.3 x 10

-5 per year (Ramsdell 2005).

25 26 The average wind direction for the region is bimodal, with southerly winds dominating during the 27 summer and northwesterly winds from mid-autumn through early spring. The change in 28 direction results from different influencing features: the Bermuda High during the summer 29 months and large-scale weather systems and a ssociated fronts during the winter months.

30 Wintertime winds average around 3.8 m/s (8.5 mph), whereas summertime winds tend to be 31 weaker, averaging around 2.9 m/s (6.5 mph). Occasionally, wind gusts can reach 22.4 to 32 26.8 m/s (50 to 60 mph) from passing fronts, thunderstorm outflow, or tropical storms 33 (NCDC 2005a, b).

34 35 The NIST site is in Montgomery County, Maryland, which is part of the National Capital 36 Interstate Air Quality Control Region (AQCR) (40 CFR 81.12). This AQCR also includes the 37 District of Columbia, Prince Georges County in Maryland, and Arlington, Fairfax, Loudoun, and 38 Prince William Counties in Virginia.

39 40 With respect to criteria pollutants regulated under the National Ambient Air Quality Standards 41 (NAAQS), Montgomery County is designated as unclassifiable, in attainment, or better than the 42 Reactor and the Environment 2-26 national standards for nitrogen dioxide, sulfur dioxide, carbon monoxide, and total suspended 1 particulates (TSP) (40 CFR 81.321). On March 25, 2003, this County was designated as in 2 severe nonattainment to the 1-hour ozone standard and more recently (June 15, 2004) 3 designated as in moderate nonattainment to the newly promulgated 8-hour ozone standard 4 (40 CFR 81.321). In addition, Montgomery County is in nonattainment for fine particles, which 5 are particles with a diameter of 2.5 µm or less (PM2.5) (40 CFR 81.321).

6 7 The Air Quality Index (AQI) is a national standard method for reporting daily air-pollution levels 8 to the general public (40 CFR Part 58, Appendix G). The AQI is a composite index based upon 9 the criteria pollutants that are in the NAAQS. Depending on the value of the index, days are 10 classified as Good, Moderate, Unhealthy for S ensitive Groups, Unhealthy, Very Unhealthy, and 11 Hazardous. For the 5 years from 2001 through 2005 in which the AQI was calculated, 12 Montgomery County had 76 percent of the days classified as Good, 21.5 percent were 13 Moderate, 2.4 percent were Unhealthy for Sensitive Groups, and 0.1 percent were Unhealthy 14 (U.S. EPA 2005).

15 16 Emergency power generators and other facilities and activities associated with the NIST site 17 emit various pollutants, which are regulated under a Title V operating permit (24-030-00323) by 18 the Maryland Department of the Environment, Ai r Quality Permits Program, Air and Radiation 19 Management Administration; the permit is scheduled to expire on April 30, 2008.

20 212.2.5Aquatic Resources 22 23 The NBSR is located within the Seneca Creek/Anacostia River sub-watershed of the Middle 24 Potomac-Catoctin watershed of the Potomac River. The major rivers in this watershed 25 generally flow in a southerly direction and eventua lly drain into the Chesapeake Bay. Tributary 26 A of the Muddy Branch is the closest natural water body to the NBSR and is approximately 27 305 m (1000 ft) west-northwest of the reactor building. This tributary flows through an onsite 28 stormwater retention pond and continues into Lake Varuna before entering the Muddy Branch.

29 There is another unnamed tributary (called Tributary B) to the Muddy Branch some 580 m 30 (1900 ft) southeast of the site. A topographic rise separates this tributary from the reactor site 31 (NIST 2005). The Muddy Branch supports a warm-water fish community including Bluntnose 32 minnow (Pimephales notatus

), swallowtail shiner (Notropis procne

), and redbreast sunfish 33 (Lepomis auritus) (Mongomery County Department of Environmental Protection 2006). The 34 Muddy Branch enters the Potomac River near Katie Island, approximately 10 km (6.2 mi) 35 southwest of the NBSR (NIST 2005; U.S. NRC 1982).

36 37 Surface water and groundwater are not used as process water in either the primary or 38 secondary coolant systems. Water lost thr ough evaporation from the secondary coolant system 39 Reactor and the Environment 2-27 is replenished by the WSSC via municipal water supply lines, and the blowdown from the 1 cooling towers is discharged into the sanitary sewer system. Process water is not discharged to 2 surface water or groundwater (NIST 2005).

3 4 Water samples are collected from streams and ponds from a minimum of four locations as part 5 of the Environmental Monitoring Program. Samples are collected all year, depending on 6 availability. These samples are analyzed for possible activation radionuclides and fission 7 products as well as assayed for tritium (NIST 2005).

8 9 There are no Federally listed aquatic species under the Endangered Species Act that occur in 10 Montgomery County (MDNR 2004).

11 122.2.6Terrestrial Resources 13 14 The NIST campus is located on the Maryland Piedmont Plateau about 48 km (30 mi) southeast 15 of the Blue Ridge Mountains (NIST 2005). Common species that occur on the campus include 16 Canada geese (Branta canadensis) and white-tail deer (Odocoileus virginianus

). To better 17 manage its deer population, NIST has partnered for the past decade with the Humane Society 18 of the United States in the use of an innovative scientific means of birth control for wildlife 19 (Newman 2005).

20 21 The NBSR is located in the Center for Neutron Research facility on the southern part of the 22 NIST campus. The portion of this facility directly under the NRC's license consists of several 23 buildings or parts of buildings, storage areas, and the cooling towers. There is also a parking 24 lot, small amount of lawn, and landscaped gardens (NIST 2005).

25 26 Grass and soil are routinely sampled as part of the Environmental Monitoring Program. Soil 27 samples are collected during the non-growing season (October through March), and grass 28 samples are collected during the normal growing season (April through September). The 29 collected samples are analyzed for possible neutron activation nuclides and fission product 30 nuclides (NIST 2005).

31 32 Two Federally listed endangered terrestrial animal species, the bald eagle (Haliaeetus 33 leucocephalus) and the small whorled pogonia (Isotria medeoloides

), are known to occur in 34 Montgomery County (MDNR 2004). Although there is suitable habitat for both the small whorled 35 pogonia and bald eagle on the NIST campus, there are no known records of these species 36 occurring on the NIST campus (U.S. NRC 2007).

37 38 Reactor and the Environment 2-282.2.7Radiological Impacts 1 2 NIST conducts a radiological environmental monitori ng program (REMP) in the vicinity of NBSR.

3 Through this program, radiological impacts to the public and the environment are monitored, 4 documented, and compared to the appropriate standards. The objectives of the REMP are as 5 follows: 6 7 Provide representative measurements of radiation and radioactive materials in the 8 exposure pathways and of the radionuclides that have the highest potential for radiation 9 exposures to members of the public.

10 11 Supplement the radiological effluent moni toring program by verifying that the 12 measurable concentrations of radioactive materials and levels of radiation are not higher 13 than expected on the basis of the effluent measurements and modeling of the 14 environmental exposure pathways.

15 16 Results of measurements of radiological releases and environmental monitoring are 17 summarized in annual operations reports to NRC (NIST 2002, 2003, 2004b, 2005, 2006). The 18 limits for all radiological releases are specified in the NBSR technical specifications 19 (NIST 2004c), and these limits are designed to meet Federal standards and requirements. The 20 REMP includes monitoring of the atmospheric environment (airborne radioiodine, gross beta, 21 and gamma), the terrestrial environment (crops, soil, and milk), and direct radiation.

22 23 2.2.7.1 Environmental Monitoring 24 25 The NBSR Environmental Monitoring Program is designed to verify that radiation doses to the 26 public remain within the limits set out in 10 CFR 20.1301. Through this program, the NIST 27 Center for Neutron Research staff perform effluent sampling and monitoring, environmental 28 surveys, and liquid waste release monitoring. Because operational releases normally represent 29 a negligible fraction of the regulatory limits, the real-time monitoring instruments displayed in the 30 reactor control room are capable of recognizing a potential elevated release. Reviews of the 31 recorded release data are also performed quarterly. Estimates of dose to members of the 32 public are based on measured emissions and are determined by computational models. The 33 U.S. Environmental Protection Agency (EPA) COMPLY code (U.S. EPA 1989) and other 34 models are used to estimate doses.

35 36 Environmental surveys include radiation survey s, sampling of grass and soil, and sampling of 37 water from local streams and ponds. Thermoluminescent dosimeters (TLDs) are used to detect 38 direct radiation at the NIST site boundary. The collected samples are analyzed for possible 39 activation and fission-product radionuclides. Water samples are also assayed for tritium.

40 Samples of water, soil, and grass are collected and analyzed at least quarterly from a minimum 41 Reactor and the Environment 2-29 of four locations for each type. Soil samples are collected during the non-growing season 1 (October through March), and grass samples are collected during the normal growing season 2 (April through September). Environmental analysis of soils and grasses typically has a 3 sensitivity of better than 1 pCi per sample; liquid scintillation analysis of water samples typically 4 has a sensitivity better than 10 pCi/mL.

5 6 Review of historical data on releases and the resultant dose calculations indicated the doses to 7 maximally exposed individuals in the vicinity of t he NBSR site were a small fraction of the limits 8 specified in the EPA environmental radiation standards 40 CFR Part 190 as required by 10 CFR 9 20.1301(e). Dose estimates are calculated for a hypothetical maximally exposed individual, 10 based on monitored liquid and gaseous effluent release data, onsite meteorological data, and 11 appropriate exposure pathways.

12 13 2.2.7.2 Impacts From Radiological Liquid Emissions 14 15 The maximum annual dose to a member of the public from liquid effluents was less than 16 0.01 mSv/yr (1 mrem/yr) based on effluent radionuclide concentrations and values in 17 10 CFR Part 20, Appendix B, Table 3. Tritium is the dominant radionuclide in liquid effluents at 18 NBSR, with annual releases from 2001 to 2005 on the order of 9.6 x 10 10 to 18.1 x 10 10 Bq 19 (2.6 to 4.9 Ci), which would comply with the limits specified in 10 CFR 20.2003(a)(2) and (3).

20 The NIST records for annual releases of other prominent beta-gamma emitters include Co-60, 21 Zn-65, and Ag-110m. Liquid releases to the sanitary sewer (under the NIST materials license 22 SNM-362) constitute a small fraction of the total NBSR liquid radioactive effluent. The annual 23 volume of radioactive effluent released is typically about 1,135,500 L (about 300,000 gal), which 24 is diluted by the NIST site sanitary sewe r volume of approximately 379-million L (100-million 25 gal). The major contributor to the liquid waste volume consists of air-conditioning condensate 26 from the confinement building, which has low-level tritium contamination from the building air.

27 28 2.2.7.3 Impacts From Radiological Air Emissions 29 30 The principal airborne sources of radioactivity associated with operation of the NBSR are Ar-41 31 and tritium. The only release path for air from the various confinement building ventilation 32 systems is via the building stack exhaust, which has a nominal flow rate of 30,000 cfm 33 (14.2 m 3/sec). Between 2001 and 2005, annual emissions of Ar-41 ranged from 2.96 x 10 13 to 34 4.4 x 10 13 Bq (800 to 1200 Ci), tritium ranged from 2.6 x 10 13 to 5.2 x 10 13 Bq (700 to 1400 Ci), 35 and other radionuclides contributed less than 7.4 x 10 9 Bq/yr (0.2 Ci/yr) on average.

36 37 The NRC ALARA dose constraint for radionuclides released to the atmosphere is 0.1 mSv/yr 38 (10 mrem/yr) to any member of the public (10 CFR 20.1101). The dose to a maximally exposed 39 individual from all air pathways during the period from 2001 to 2005 was less than 0.01 mSv/yr 40 (1 mrem/yr) to the whole body or any organ other than the thyroid. This represents less than 41 10 percent of the NRC public dose constraint for exposure via air pathways. The gaseous 42 Reactor and the Environment 2-30 exposure pathways included inhalation, ingestion of milk and crops, and direct radiation from 1 the airborne radioactive material. This analysis was performed with the EPA COMPLY 2 computer code (U.S. EPA 1989) using local meteorological data. The dose was estimated for 3 the closest resident in each sector, which constitutes conservative analytical boundary 4 conditions. These doses are typical of the annual dose for operation of the NBSR, and they are 5 expected to remain well below NRC and EPA limits during the license renewal term.

6 7 From a public dose perspective, tritium results in about one-tenth of the dose from Ar-41, 8 assuming release of equal activities. Conducting operations in a way that minimizes Ar-41 9 production, even if that results in some increased heavy water loss and minor increases in 10 tritium exposure, results in minimized collective dose because the increased occupational dose 11 to the limited number of operational staff is more than offset by the reduced collective dose to 12 the public. Therefore, ALARA efforts to reduce tritium losses, particularly through ventilation 13 system modifications, must consider possible related increases in Ar-41 emissions.

14 15 2.2.7.4 Dose to Workers 16 17 Ar-41 is produced at the NBSR primarily by neut ron activation of air in the cavity around the 18 reactor vessel. A secondary source is associated with experiments, which contribute less than 19 0.1 percent to the total. The external exposure rate from Ar-41 is minimal because the 20 concentrations of Ar-41 in the building are less than 1 DAC and the building volume represents 21 a small fraction of a "semi-infinite" cloud; actual dose rates to a person in the building from a 22 uniform cloud at 1 DAC would be less than 0.2 mrem/hr. Personnel dose rates from typical 23 Ar-41 levels measured inside the confinement building have been less than 4 x 10

-5 mSv/hr 24 (0.004 mrem/hr). Combined with typical occupancy times and reactor operating frequency, this 25 would result in personnel exposure less than 0.02 mSv/yr (2 mrem/yr). Direct measurements 26 have demonstrated that these calculated values are conservative.

27 28 Levels of tritium in the confinement building, at a nominal primary coolant concentration of 3.7 x 29 10 10 Bq/L (1 Ci/L), are typically less than 0.01 DAC. The operating staff is in the building fewer 30 than 1500 hr/yr, so this represents an individual dose commitment of less than 0.4 mSv/yr 31 (40 mrem/yr). Bioassay data for the operating staff confirm that most exposures are well below 32 0.4 mSv/yr (40 mrem/yr). Other personnel are in the confinement building a much smaller 33 fraction of the time, and their tritium exposures result in doses much less than 1 mrem/yr.

34 Although reactor operators can be exposed to airborne sources of tritium during activities such 35 as refueling, their doses would not normally exceed 1 mSv/yr (100 mrem/yr).

36 37 Airborne tritium levels can also be increased by abnormal or transient conditions. When the 38 ventilation system for the NBSR was shut down fo r remediation over a 5-day period, the tritium 39 levels slowly approached DAC values, and when an auxiliary cooling loop had excessive heavy 40 water leakage, the local airborne tritium levels increased to 5 percent of the DAC.

41 42 Reactor and the Environment 2-31 The average radiation dose to facility workers from external exposure to radiation fields during 1 2001 to 2005 was less than 0.5 mSv/yr (50 mrem/yr), and the maximum annual exposures 2 rarely exceed 5 mSv/yr (500 mrem/yr) during routine operations. Over that period, there were a 3 total of 21 individual exposures that exceeded 5 mSv/yr (500 mrem/yr), and the maximum dose 4 to an individual in any year ranged from 3.57 to 19.4 mSv (357 to 1940 mrem). Potential 5 exposures to special populations, such as embryos or declared pregnant women, are very 6 limited. Where such exposures could potentia lly exceed regulatory limits, added surveillance is 7 provided and work is managed to further limit exposure to radiation and to radioactive materials.

8 9 Total annual exposure for the staff at NBSR ov er the last 5 years has ranged from 0.1 to 10 0.25 person-Sv (10 to 25 person-rem) for 676 to 914 monitored workers. Of those workers the 11 number with measurable exposures (greater t han 0.01 mSv [1 mrem]) ranged from 414 to 685.

12 During a few earlier years that involved high-exposure maintenance and major upgrade 13 activities, the yearly collective exposure to wo rkers ranged from 0.18 to 0.22 person-Sv/yr (18 to 14 22 person-rem/yr).

15 162.2.8Socioeconomic Factors 17 18 The staff reviewed the ER submitted by NIST and information obtained from county and city 19 economic development staff. The following information describes the economy, population, and 20 communities near the NBSR.

21 22 2.2.8.1 Housing 23 24 The NBSR is a national resource used by up to 2000 engineers and scientists for some part of 25 their research every year. In 2002, the researchers came from 30 other Federal laboratories, 26 127 universities, 47 industrial laboratories, and 21 divisions and offices of NIST, and from all 27 areas of the U.S. According to a recent study by an interagency working group of the Office of 28 Science and Technology Policy (OSTP 2002), the NBSR is the highest performing and most 29 used neutron facility in the United States.

30 31 Typically, visiting scientists and engineers will stay for 40 days, which corresponds to a reactor-32 run cycle. Visiting scientists make their own housing arrangements while using the facility. No 33 housing facility is provided by NIST for visiting scientists; however, there are over 50 hotels 34 within 24 km (15 mi) of the site and many more in neighboring cities.

35 36 Although NIST is certainly a major employer in the Gaithersburg area, the local real estate 37 market appears to be primarily driven by economic activity in the District of Columbia 38 metropolitan center. The corridor connecting Washington, D.C., Baltimore, and Northern 39 Reactor and the Environment 2-32 Virginia is home to over 8 million people, and it grew over 7 percent between 2000 and 2005.

1 The existence of the NBSR within the NIST ca mpus would appear to have little impact on local 2 housing prices and rental rates.

3 4 Table 2-7 provides the number of housing units and housing unit vacancies for Gaithersburg 5 and neighboring metropolitan areas within Montgomery County for 1990 and 2000.

6 Gaithersburg, where the NBSR is located, had approximately 20,674 housing units in 2000, with 7 a vacancy rate around 5 percent. Germantown, located to the northwest of Gaithersburg, had 8 21,568 housing units and a vacancy rate of 2 percent. Rockville and Montgomery Village, with 9 a combined housing unit stock of just over 30,000 units, each has a vacancy rate of 3 percent.

10 11 In 1997, the Maryland legislature adopted legislation, commonly known as Smart Growth, aimed 12 at slowing sprawl development in Maryland. The Smart Growth law targets State spending on 13 roads, sewers, schools, and other public infrastructure in designated growth areas or priority 14 funding areas. These areas include the land within the Baltimore and Washington 15 16 Table 2-7. Total Occupied and Vacant (Available) Housing Units by County, 1990 and 2000 17 18 1919902000 Approximate Percentage Change Gaithersburg 20 Housing Units2116,05920,67429 Occupied Units2215,20219,6219 Vacant Units23857105323 Germantown 24 Housing Units2517,12121,56826 Occupied Units2615,78420,89332 Vacant Units271337375-71 Rockville 28 Housing Units2916,23817,78610 Occupied Units3015,66017,24721 Vacant Units31578539-7 Montgomery Village 32 Housing Units3313,12014,54811 Occupied Units3412,28414,14215 Vacant Units35836406-51 Sources: U.S. Census Bureau (USCB) 2000 and USCB 1990 36 37 Reactor and the Environment 2-33 beltways; established towns, cities, and rural villages; other existing and proposed communities 1 above a minimum density; and industrial and employment areas. Although growth is not 2 necessarily restricted in Montgomery County, the State funnels significant dollars into these 3 designated growth areas, while no State funding is provided to development occurring outside 4 of the designated growth areas. Given the land use and zoning designations in Montgomery 5 County, there is currently a potential for another 241,000 housing units, of which 84 percent is in 6 areas with existing or planned sewerage se rvice (Maryland Department of Housing and 7 Community Affairs 2001).

8 9 Table 2-8 contains data on population, estimated population, and annual population growth 10 rates for Montgomery County. The population of Montgomery County has grown significantly in 11 recent years and this level of growth is expected to continue throughout the next decade. This 12 growth pattern is similar to other suburban counties surrounding the District of Columbia and 13 also similar to overall growth rates for the State of Maryland.

14 15 Table 2-8. Population Growth in Montgomery County, Maryland - 1980 to 2020 16 17 18Montgomery CountyState of Maryland 19 Population Percent Change(each decade)Population Percent Change (each decade) 198020579,0535,296,486(a) 199021757,02710.84,781,46810.9 200022873,34115.45,296,48611.0 201023975,000 (estimated)11.65,907,575 (estimated)11.5 2020241,050,000 (estimated)7.76,326,975 (estimated)7.1 (a) No data available.

25Sources: NIST 2004a & MD Dept. of Planning Services & Mont. Cnty Planning Board 26 27 2.2.8.2 Public Services 28 29 Public services include water supply, education, and transportation.

30 31 Water Supply 32 33 The WSSC, a co-op utility, provides potable water to the City of Gaithersburg. The water is 34 drawn from the Potomac River (intake upstream from Great Falls) and the Patuxent River. This 35 water system operates with excess capacity with no expectations of problems in meeting future 36 water demands of Gaithersburg. The average daily water demand on the system is 167 MGD 37 (630,000 m 3/day) with a peak demand of 267 MGD (1 million m 3/day). The average demand is 38 less than half the treatment capacity of 355 MGD (1.3 million m 3/day) (WSSC 2005).

39 Reactor and the Environment 2-34 Transportation 1 2 As shown on Figure 2-3, I-270 forms the northeast boundary of the NIST campus and is a major 3 commuter artery for workers in the Washington, D.C., metropolitan area living in Montgomery 4 County, Frederick County, and other northern points. It is also a major truck route serving the 5 area. Three arterial and collector roads abut the NIST campus (Figure 2-1). West Diamond 6 Avenue, Quince Orchard Road, and Muddy Br anch Road all serve the Gaithersburg area 7 surrounding the NIST campus, providing truck routes serving the local economy (NIST 2004a).

8 9A CSX rail line (CSX Transportation Corp.) parallels the northeast boundary of the NIST 10 campus. At its closest point to the reactor, it is approximately 2 km (1.25 mi) away. It carries 11 goods through the region. This line also serves the MARC commuter train service that is used 12 by people in northern Montgomery County, Frederi ck County, and other points north traveling to 13 Washington, D.C. Shady Grove, the northernmos t station for the MetroRail system is located 14 approximately 5 km (3.0 mi) away from the reactor (NIST 2004a).

15 16 The I-270 Technology Corridor is a major research and development center in the State of 17 Maryland; while some manufacturing does occur here, there are no significant manufacturing 18 plants near the reactor, including no chemical plants or refineries. Mining and quarrying 19 operations are limited to those associated with constructing new office buildings. A natural-gas 20 pipeline lies 3.2 km (2 mi) to the south of the reactor, and a liquid petroleum/gas pipeline is 21 located 1.6 km (1 mi) to the north (NIST 2004a).

22 23 Andrews Air Force Base, the nearest military base, is approximately 52 km (32.5 mi) away. A 24 retired Nike missile site with its abandoned silos is located just to the south of the NIST campus.

25 The three commercial airports within the region are IAD in northern Virginia; DCA in Virginia just 26 across the Potomac River from Washington, D.C.; and BWI near Baltimore, Maryland. No 27 associated normal air routes, holding patterns, or approach patterns are known to exist above 28 the NIST campus. Montgomery Airpark is approxim ately 7 km (4.5 mi) to the northeast of the 29 reactor. Its runway is oriented 140°/320° relative to magnetic north, that is, it is nearly 30 perpendicular to the line between the reactor and the airfield. While the airfield can handle an 31 aircraft as large as the Gulfstream 4, the largest aircraft typically using the field is the Falcon 32 900. There are approximately 140,000 annual take-offs and landings at this field. The airport 33 has no known normal approach patterns. The typical air traffic in the general area is local air 34 traffic, news aircraft, and an occasional military helicopter traversing the area (NIST 2004a).

35 36 Search of the National Transportation Safety Board database (covering 1962 to January 2007) 37 revealed eight fatal accidents and 18 nonfatal accidents in the Gaithersburg area. One involved 38 a hot-air balloon, while the remainder involved either airplanes or helicopters within Montgomery 39 County. The following is a breakdown of the reported accidents:

40 41 Reactor and the Environment 2-35 Fatal 1-three occurred at the Montgomery County Airpark.

2-one occurred 1 km (0.6 mi) to the east of the Montogomery County Airpark.

3-one occurred 3.2 km (2.0 mi) to the northeast of the Montgomery County Airpark.

4-one occurred 8.1 km (5 mi) north of Montgomery County Airpark.

5-one occurred at an unspecified location within Montgomery County.

6-one involved a hot-air balloon.

7 8 Non-Fatal 9-18 non-fatal accidents occurred at the Montgomery County Airpark. The Airpark is 10 7 km (4.5 mi) to the northeast of the NBSR. It is unlikely that the small planes flying 11 into and out of this airpark pose any accident-related problems to the safe operation 12 of the reactor (NTSB 2007).

13 14 2.2.8.3 Offsite Land Use 15 16 The NIST campus and general area within the 8-km (5-mi) circle surrounding the NBSR have a 17 gently rolling topography (see Figure 2-5). There are a few buildings within the area over three 18 floors high, the closest being the NIST Administration Building (located approximately 1.25 km 19 (0.75 mi) to the north of the NBSR. Other tall structures include several buildings in the Rio 20 complex at the interchange of I-270 and I-370; these buildings are approximately 2.4 km 21 (1.5 mi) to the east of the reactor (NIST 2004a).

22 23 The NBSR is located within the I-270 Technology Corridor, which is sited in the center of 24 Montgomery County and constitutes the county's primary focus of economic and transportation 25 activity. By 2015, 62 percent of the county's job growth and 51 percent of its household growth 26 is expected to be within this area. The NBSR is surrounded by commercial buildings and 27 suburban housing developments (Montgomery County 2005).

28 29 Most of Montgomery County is made up of urban and suburban/residential areas. In 2002, 30 however, there were approximately 75,000 acres of land (of the 317,000 total county acres) 31 devoted to agricultural use. Just over 7400 acres of Montgomery County are covered with 32 water (USDA 2003).

33 34 2.2.8.4 Visual Aesthetics and Noise 35 36 The NBSR is situated in a suburban metropolitan area that is fairly densely populated. Most of 37 the immediate area surrounding the NBSR lies on the campus of NIST. This area has 38 laboratories and office buildings but no residential buildings. The closest permanent residences 39 are more than 400 meters (0.25 mi) directly to the east and directly to the west of the reactor 40 (NIST 2004a).

41 42 Reactor and the Environment 2-36 There are several parks and recreation sites in close proximity to the NIST campus. Seneca 1 Creek State Park is located to the northwest of the site and includes 2550 hectares 2 (6300 acres) along 22.5 km (14 mi) of Seneca Creek. East of the site are the Summit Hall Farm 3 Park, Maple Lake Park, and Kelly Park. Just a couple miles further east in Derwood along Rock 4 Creek is the much larger Agricultural History Farm Park, a 166-ha (410-ac) complex that 5 connects with Rock Creek Regional Park. To the south of the site is the Muddy Branch Park, 6 which includes an existing stream valley and network of trails beginning in Gaithersburg and 7 connecting to the Potomac River (MCPPC 2006).

8 9 2.2.8.5 Demography 10 11 Demographic factors considered in this review included resident population, workforce, transient 12 populations who stay temporarily to use NIST facilities, and the tax implications of the 13 demographics.

14 15 Resident Population 16 17 The city of Gaithersburg surrounds the NIST campus (Figure 2-2). All of the area within the 18 2-km (1.25-mi) circle about the reactor and most of that within the 4-km (2.5-mi) circle are 19 located in Gaithersburg. All of the town of Washington Grove and much of the city of Rockville 20 also lie within the 8-km (5-mi) circle. Other unincorporated areas situated within the 8-km (5-mi) 21 circle include Germantown, Montgomery Village, Darnestown, and North Potomac. According 22 to 2000 Census data, the Germantown area was the seventh most populous place in Maryland 23 with 55,419 residents, Gaithersburg was the tenth most populous with 52,613, Rockville the 24 fourteenth at 47,388, and Montgomery Village the twenty-first at 38,051. In terms of percentage 25 growth of their populations between 1990 and 2000, this represents an increase of 34.7, 33.1, 26 5.7, and 17.8 percent, respectively. Table 2-5 presents the 1990 and 2000 Census data for 27 these places.

28 29 Montgomery County is the most populous county in the State of Maryland. Much of this growth 30 has occurred in the southern half of the county. Table 2-3 gives the 2000 to 2025 Census 31 population and percentage change figures for the county. The populations within the 1-, 2-, 4-, 32 6-, and 8-km (0.6-, 1.2-, 2.5-, 3.7-, and 4.9 mi) radii about the reactor were estimated from the 33 2000 Census Population Counts by jurisdiction for the voting districts located within these 34 encircled areas. For districts that are sited in more than one of the zones about the reactor, the 35 percentage area located within each ring was estimated, and the population distribution within 36 any one district was assumed linear with area. Table 2-1 gives the population estimates for 37 each of the circles about the reactor for the years 2000, 2010, and 2025 based upon the voting 38 district data.

39 40 Reactor and the Environment 2-37 Workforce 1 2 The service sector is the largest category of employment in the county and exceeds Federal, 3 State and local government employment comb ined. This sector includes the following 4 industries: business and repair, personal services, entertainment and recreation, professional 5 health services, professional education services, and other miscellaneous services. Over 6 one-third of all jobs in Montgomery County are in the service industries. The second largest 7 sector is retail trade and nearly one in five jobs in the county is related to retail trade. The 8 Federal government is the third largest employment sector in the county as well as the largest 9 single employer in the county. The locations of Federal installations in the county are provided 10 in Figure 2-5 (Montgomery County 2005).

11 12 Major employers in lower Montgomery County include Marriott International, Lockheed Martin 13 (the country's largest defense contractor), the National Naval Medical Center, and Discovery 14 Communications, which is building a new headquarters in downtown Silver Spring.

15 16 An economic recession in the early 1990s resulted in the loss of 20,000 jobs in Montgomery 17 County. In 1992, a recovery began with employment growth continuing through 2003.

18 Employment projections for through 2010 are included in Table 2-9.

19 20 In general, the economic activities taking place at the NIST site, including employment, 21 contribute only a small share to the overall dynamics of the local economy.

22 23 Transient Populations 24 25 The NBSR is considered a national user facility, which means that scientists and engineers 26 come from a number of different research institutions throughout the United States to use the 27 facility on a temporary basis to complete their research. On average, approximately 1500 28 visiting scientists and engineers use the facility each year. Typically, visiting scientists and 29 engineers will stay for 40 days, which corresponds to a reactor-run cycle. These visiting 30 scientists are typically housed in local hotels (U.S. NRC 2007).

31 32 33 Reactor and the Environment 2-38 1 Figure 2-5. Major Federal Installations in Montgomery County, Maryland 2 3 4

Reactor and the Environment 2-39 Table 2-9. Number of Jobs in Montgomery County and the State of Maryland (2004 to 2010) 1 2County/State 32004200620082010Average Annual PercentChange 2004-2010(projected)PercentChange, 1990-2001 Montgomery 4505,000530,000549,000565,0000.4%(-1.1%)Maryland 52,764,1102,876,013------14%

Sources: MCPPC 2006; U.S.BLS 2004, 2006 6 7 Taxes 8 9 NIST is a non-regulatory Federal agency of the U.S. Commerce Department within the 10 Technology Administration. It is a tax-exempt research entity; therefore, there are no tax 11 implications associated with the operation of the NIST Center for Neutron Research.

12 132.2.9Historic and Cultural Resources 14 15 Although Maryland is rich in prehistoric and historic resources, according to the Maryland 16 Historical Trust, the Maryland Inventory of Historic Properties does not have any record of 17 known archeological sites or other historical properties within or immediately adjacent to the 18 entire NIST campus (MDP 2006). There are no historic cemeteries surrounding the site. There 19 are no Federally recognized tribes in Maryland, and the State of Maryland does not provide any 20 official designation for tribal members. There are, however, several communities of indigenous 21 people throughout the State who maintain an identity, including the Piscataway, the Nause-22 Waiwash, the Lenape, and the Lumbee. The closest historic district to the site is in 23 Germantown (Jefferson Patterson Park and Museum 2006).

24 252.2.10Related Federal Project Activities and Consultations 26 27 The staff reviewed the possibility that activities of other Federal agencies might impact the 28 issuance of a renewed operating license for the NBSR to NIST. Any such activities could result 29 in cumulative environmental impacts and the possible need for a Federal agency to become a 30 cooperating agency for preparation of this EIS (10 CFR 51.10(b)(2)).

31 32 Given the proximity of the NBSR to the District of Columbia, there are many Federal activities 33 within the region (80 km [50 mi] radius of the NBSR). After considering the Federal activities in 34 the vicinity of the NBSR, the staff determined there were no Federal project activities that would 35 make it desirable for another Federal agency to become a cooperating agency for preparation 36 of this environmental impact statement.

37 38 Reactor and the Environment 2-402.3References 1 2 10 CFR Part 20. Code of Federal Regulations, Title 10, Energy , Part 20, "Standards for 3 Protection Against Radiation."

4 5 10 CFR Part 51. Code of Federal Regulations, Title 10, Energy , Part 51, "Environmental 6 Protection Regulations for Domestic Licensing and Related Regulatory Functions."

7 8 10 CFR Part 61. Code of Federal Regulations, Title 10, Energy , Part 61, "Licensing 9 Requirements for Land Disposal of Radioactive Waste."

10 11 10 CFR Part 71. Code of Federal Regulations, Title 10, Energy , Part 71, "Packaging and 12 Transportation of Radioactive Material."

13 14 10 CFR Part 100. Code of Federal Regulations, Title 10, Energy , Part 100, "Reactor Site 15 Criteria."

16 17 40 CFR Part 58. Code of Federal Regulations, Title 40, Protection of the Environment , Part 58, 18"Ambient Air Quality Surveillance."

19 20 40 CFR Part 81. Code of Federal Regulations, Title 40, Protection of the Environment , Part 81, 21"Designations of Areas for Air Quality Planning Purposes."

22 23 40 CFR Part 190. Code of Federal Regulations, Title 40, Protection of the Environment

, 24 Part 190, "Environmental Radiation Protection Standards for Nuclear Power Operations."

25 26 Endangered Species Act. 16 USC 1531 et seq.

27 28 Jefferson Patterson Park and Museum. Accessed on the Internet 29 http://www.jefpat.org/diagnostic/Prehistoric_Ceramic_Web_Page/Prehistoric_Prehistory.htm on 30 January 4, 2006.

31 32 Maryland Department of Housing and Community A ffairs. 2001. "Technical Supplement to the 33 Montgomery County, Maryland Housing Policy: Montgomery County - The Place to Call Home."

34 Report available upon request at http://www.co.mo.md.us/hca, Rockville, Maryland.

35 36 Maryland Department of Natural Resources (MDNR). 2002. "Maryland's Coastal Program:

37 What is the Coastal Zone?" Accessed on the Internet at 38 http://www.dnr.state.md.us/bay/czm/coastal_zone.html on December 1, 2006.

39 40 Maryland Department of Natural Resources (MDNR). 2004. "Current and Historical Rare, 41 Reactor and the Environment 2-41 Threatened, and Endangered Species of Montgomery County, Maryland." Accessed on the 1 Internet at http://www.dnr.state.md.us/wildlife/index.asp on January 16, 2006.

2 3 Maryland Department of Planning (MDP) 2006. Letter, dated February 17, 2006, from Elizabeth 4 J. Cole, Administrator, Project Review and Compliance. ML070380446.

5 6 Montgomery County Department of Environm ental Protection 2006. "The Muddy Branch 7 Watershed." Accessed on the Internet at 8 http://www.montgomerycountymd.gov/deptmpl.asp?url=/content/dep/csps/watersheds/csps/html 9/muddy.asp on February 6, 2006.

10 11 Montgomery County Government website and information. 2005. Accessed on the Internet at 12 http://www.montgomerycountymd.gov in December 2005.

13 14 Montgomery County Parks & Planning Commission (MCPPC). 2006. Accessed on the Internet 15 at http://www.mc-mncppc.org/research/index.shtm in January 2006.

16 17 National Climatic Data Center (NCDC). 2005a. 2004 Local Climatological Data Annual 18Summary With Comparative Data - Washington, D.C., Ronald Regan National Airport (DCA). 19 Asheville, North Carolina.

20 21 National Climatic Data Center (NCDC). 2005b. 2004 Local Climatological Data Annual 22Summary With Comparative Data - Washington, D.C., Dulles International Airport (IAD). 23 Asheville, North Carolina.

24 25 National Environmental Policy Act of 1969 (NEPA). 42 USC 4321, et seq.

26 27 National Institute of Standards and Technology (NIST). 2002.

National Institute of Standards 28and Technology Reactor. Operations Report #54. January 1, 2001 to December 31, 2001. 29 NIST, Gaithersburg, Maryland.

30 31 National Institute of Standards and Technology (NIST). 2003.

National Institute of Standards 32and Technology Reactor. Operations Report #55. January 1, 2002 to December 31, 2002. 33 NIST, Gaithersburg, Maryland.

34 35 National Institute of Standards and Technology (NIST). 2004a. Environmental Report for 36 License Renewal for the National Institute of Standards and Technology Reactor-NBSR. 37 NBSR-16, NISTIR 7105, NIST, Gaithersburg, Maryland.

38 39 National Institute of Standards and Technology (NIST). 2004b.

National Institute of Standards 40and Technology Reactor. Operations Report #56. January 1, 2003 to December 31, 2003. 41 NIST, Gaithersburg, Maryland.

42 Reactor and the Environment 2-42 National Institute of Standards and Technology (NIST). 2004c.

Technical Specifications for 1 License Renewal for the National Institute of Standards and Technology Reactor-NBSR. 2 NBSR-15, NISTIR 7104, NIST, Gaithersburg, Maryland.

3 4 National Institute of Standards and Technology (NIST). 2005.

National Institute of Standards 5and Technology Reactor. Operations Report #57. January 1, 2004 to December 31, 2004. 6 NIST, Gaithersburg, Maryland.

7 8 National Institute of Standards and Technology (NIST). 2006.

National Institute of Standards 9and Technology Reactor. Operations Report #58. January 1, 2005 to December 31, 2005. 10 NIST, Gaithersburg, Maryland.

11 12 National Transportation and Safety Board (NTSB). 2007. Accessed on the Internet at 13 http://www.ntsb.gov/ntsb/query.asp on February 1, 2007.

14 15 Newman, M.E. 2005. "Deer Immunocontraception at NIST." Accessed on the Internet at 16 http://www.nist.gov/public_affairs/factsheet/deer.htm on November 3, 2007.

17 18 Office of Science and Technology Policy (OSTP). 2002.

Report on the Status and Needs of 19Major Neutron Scattering Facilities and Instruments in the United States. Washington, D.C.

20 21 Ramsdell, J.V. 2005. Tornado Climatology of the Contiguous United States. 22 NUREG/CR-4461, Rev. 1, U.S. Nuclear Regulatory Commission, Washington, D.C.

23 24 U.S. Bureau of Labor Statistics (USBLS). 2004. "Bureau of Labor Statistics Data." Accessed 25 on the Internet at http://data.bls.gov/labjava/outside.jsp?survey=1a on July 22, 2004.

26 27 U.S. Bureau of Labor Statistics (USBLS). 2006. "Site Source." Accessed on the Internet at 28 http://www.dllr.state.md.us/lmi/ on October 2006.

29 30 U.S. Census Bureau (USCB). 1990. "U.S. Bureau of Census, 1990 Census of Population and 31 Housing, Table DP-1." Accessed on the Internet at http://factfinder.census.gov on April 19, 32 2004.33 34 U.S. Census Bureau (USCB). 2000. "U.S. Bureau of Census, Census 2000, State and County 35 Quick Facts." Accessed on the Internet at http://quickfacts.census.gov/qfd/ on April 19, 2004.

36 37 U.S. Department of Agriculture (USDA). 2003. "NASS Fact Finders for Agriculture." Accessed 38 on the Internet at http://www.nass.usda.gov/md/Montgomery2003Profile.pdf in January 2006.

39 40 U.S. Environmental Protection Agency (U.S.EPA). 1989. User's Guide for the COMPLY Code. 41 EPA 520/1-89-003, EPA Office of Radiation and Indoor Air, Washington, D.C.

42 Reactor and the Environment 2-43 U.S. Environmental Protection Agency (U.S.EPA). 2005. "Air Quality Index Report." Accessed 1 on the Internet at http://www.epa.gov/air/data/repsst.html?st~MD~Maryland on January 20, 2 2006.3 4 U.S. Nuclear Regulatory Commission (U.S.NRC). 1982. Final Environmental Statement 5 Related to License Renewal and Power Increase for the National Bureau of Standards Reactor. 6 NUREG-0877. Washington, D.C.

7 8 U.S. Nuclear Regulatory Commission (U.S.NRC). 2007. Summary of Site Audit to Support the 9 License Renewal Review for the National Bureau of Standards Reactor (NBSR) at the National 10 Institute of Standards and Technology. ML070370061.

11 12 Washington Suburban Sanitary Commission (WSSC). 2005. Accessed on the Internet at 13 http://www.wsscwater.com/index.cfm in December 2005.

14 15 (a)The GEIS was originally issued in 1996. Addendum 1 to the GEIS was issued in 1999. Hereafter, all references to the "GEIS" include the GEIS and its Addendum 1.

3-1 3.0 Environmental Impacts of Operation 1 2 3 This chapter addresses the environmental impacts related to operation during the license 4 renewal term of the National Bureau of Standards Reactor (NBSR) located on the National 5 Institute of Standards and Technology (NIST) site in Montgomery County, Maryland.

6 7 There are substantial differences between the NBSR and commercial power reactors; however 8 the types of environmental issues addressed in this chapter are similar, and in many cases, the 9 environmental impacts from continued operati on of the NBSR can be informed by analyses 10 discussed in the Generic Environmental Impact Statement for License Renewal of Nuclear 11 Plants (GEIS), NUREG-1437, Volumes 1 and 2 (NRC 1996, 1999)(a). Therefore, where 12 appropriate, the GEIS analyses are used as a basis for evaluating the environmental impacts of 13 continued operation of the NBSR. The environmental impacts of operating the NBSR during the 14 license renewal term are presented in the following sections.

15 16 Unless otherwise indicated, information in the following sections was adapted from the 17 Environmental Report (ER) submitted by NIST for renewal of the NBSR operating license (OL) 18 (NIST 2004) and was independently verified by the staff. Additional information was obtained 19 by the staff during the site audit (U.S. NRC 2007); appropriate citations will be made for other 20 sources. Section 3.1 addresses issues applicable to the NBSR cooling system. Section 3.2 21 addresses the radiological impacts of normal operation, and Section 3.3 addresses issues 22 related to the socioeconomic impacts of normal operation during the license renewal term.

23 Section 3.4 addresses issues related to historic and archaeological resources, while Section 3.5 24 discusses the impacts of license renewal-term operations on terrestrial and aquatic resources, 25 including threatened and endangered species. Section 3.6 discusses cumulative impacts, and 26 Section 3.7 summarizes the results of the evaluation of environmental issues related to 27 operation during the license renewal term. References are listed in Section 3.8.

28 293.1Cooling System 30 31 The NBSR primary cooling is provided by a closed system containing heavy water (D 2 O). The 32 primary system is connected to a secondary cooling system containing light water (H 2 O) via a 33 plate-type heat exchanger. The secondary system c onsists of a plume abatement cooling tower 34 that uses make-up water from a municipal utility as needed and discharges blowdown to the 35 sanitary sewer system. The potential for l eakage between the primary and secondary systems 36 is carefully monitored, and if contaminants were transferred to the secondary system, they 37 would be removed and managed with other radiological liquid waste, as necessary.

38 Operation 3-2 The NBSR cooling system does not discharge water to an open body of water, and no impacts 1 on surface water quality or on biota that would normally inhabit rivers or lakes would be 2 expected.3 4 For all of the following environmental issues associated with cooling tower systems, the staff 5 concluded the impacts from operation of nuclear power reactors are SMALL, and additional 6 mitigation measures are not likely to be sufficiently beneficial to be warranted as described in 7 the GEIS (U.S. NRC 1996):

8 9*Discharge of sanitary wastes and minor chemical spills 10*Discharge of chlorine or other biocides 11*Discharge of other metals in wastewater 12*Cooling tower impacts on crops and ornamental vegetation 13*Cooling tower impacts on native plants 14*Bird collisions with cooling towers 15*Microbiological organisms (occupational health) 16*Noise.17 18 Other environmental issues associated with c ooling system operation evaluated in the GEIS 19 Section 4.3 are not considered to be applicable to the NBSR. By comparison to power reactors, 20 the NBSR operates at a substantially lower power level (from a factor of 75 to 150 or more).

21 The cooling tower technology employed at NBSR is si milar in principle to those at power reactor 22 facilities, but the scale is likewise reduced.

23 24 In its ER, NIST did not identify any information for cooling system operations indicating potential 25 for impacts greater than, or different in nature from, those discussed in the GEIS (NIST 2004).

26 The staff reviewed applicable information related to cooling system impacts during its 27 independent review of the ER, the staff's site visit, the scoping process, and its evaluation of 28 other available information. Based on the analysis and findings of the GEIS for similar cooling 29 system technology and the fact the NBSR operates at a substantially lower power level than 30 commercial power reactors, the staff concludes the impacts are bounded by the impacts for 31 commercial power reactors (i.e., SMALL), and no additional mitigation is warranted.

32 333.2Radiological Impacts 34 35 Radiological issues related to impacts at nuclear power plants applicable to the NBSR include 36 radiation exposures to the public and occupational radiation exposures. For these issues, the 37 staff concluded in the GEIS Section 4.6 (U.S. NRC 1996) that the impacts from commercial 38 power reactor operations are SMALL, and additional plant-specific mitigation measures are not 39 likely to be sufficiently beneficial to be warranted. The staff reviewed applicable information 40 related to radiological impacts on workers and members of the public during its independent 41 Operation 3-3 review of the ER, the scoping process, the staff's site visit, and its evaluation of other available 1 information. Because the NBSR operates at a substantially lower power level than a commercial 2 power reactor, there is no expectation that radiological impacts of operating the NBSR would 3 differ from, or exceed, those discussed in the GEIS in Section 4.6 (U.S. NRC 1996). Radiation 4 exposures to the public as a result of operating the NBSR during the license renewal term are 5 expected to continue at current levels associated with normal operations, as discussed in 6 Section 2.2.7 of this draft EIS. This includes exposures to radionuclides in airborne and liquid 7 effluents as well as direct radiation. Likewise, projected maximum occupational doses during 8 the license renewal term are within the range of doses experienced during normal operations or 9 normal maintenance outages, and would continue to be well below regulatory limits.

10 11 Radiological impacts from ongoing research projects at the NIST Center for Neutron Research 12 are the only unique activities associated with normal operation of the NBSR. Doses to 13 members of the public from research activities are included in the radiological impacts of reactor 14 operation based on monitoring of effluents and various environmental media, and they 15 represent a small fraction of the dose from reactor operations (NIST 2004). Radiological doses 16 to research staff working in the laboratories are monitored and are typically lower than those to 17 reactor operations staff, as discussed in Section 2.2.7 of this draft EIS. Therefore, they would 18 be well below regulatory standards and within the bounds of the GEIS Section 4.6 analysis 19 (U.S. NRC 1996). Consequently, the staff concludes the radiological impacts associated with 20 operation during a renewal term would be SMALL and no additional mitigation measures 21 beyond the existing control program are warranted.

22 233.3Socioeconomic Impacts 24 25 Socioeconomic impacts considered include those on housing availability, public services 26 (utilities and transportation), land use, and environmental justice.

27 283.3.1Housing Impacts 29 30 SMALL impacts result when no discernible change in housing availability occurs, changes in 31 rental rates and housing values are similar to those occurring statewide, and no housing 32 construction or conversion is required to meet new demand. Impacts are considered 33 MODERATE when there is discernible but short-lived reduction in available housing units 34 because of project-induced migration. Impacts are considered LARGE when project-related 35 housing demands result in very limited housing availability and would increase rental rates and 36 housing values well above normal inflation.

37 38 Appendix C of the GEIS (U.S. NRC 1996) presents a population characterization method based 39 on two factors, sparseness and proximity. Sparseness measures population density within 40 32 km (20 mi) of the site, and proximity measures population density and city size within 80 km 41 Operation 3-4 (50 mi). Each factor has categories of density and size (NRC 1996, Table C.1), and a matrix is 1 used to rank the population category as low, medium, or high (NRC 1996, Figure C.1).

2 3 In 2000, the population living in Montgomery County, where the NBSR is located, was estimated 4 to be approximately 873,341. This total converts to a population density of about 5 680 persons/km 2 (1775 persons/mi 2). This concentration falls into the GEIS sparseness 6 Category 4 (i.e., having greater than or equal to 46 persons/km 2 [120 persons/mi 2]). In addition, 7 the District of Columbia metropolitan area has a population of approximately 4.8 million and is 8 located about 32 km (20 mi) southeast of the site (NIST 2004). Applying the GEIS proximity 9 measures (U.S. NRC 1996), NBSR is classified as being located in a high-population area.

10 11 The NRC has concluded the impacts on housing availability are expected to be of SMALL 12 significance at commercial power reactors located in a high-population area where 13 growth-control measures are not in effect. The NBSR site is located in a high-population area.

14 In 1997, the Maryland legislature adopted legislation, commonly known as Smart Growth, aimed 15 at slowing sprawl development in Maryland. The Smart Growth law targets State spending on 16 roads, sewers, schools, and other public infrastructure in designated growth areas or priority 17 funding areas. Growth is not necessarily rest ricted in Montgomery County; however, the State 18 funnels significant resources into designated growth areas, while no State funding is provided 19 for development occurring outside of the designated growth areas. Given the land use and 20 zoning designations in Montgomery County, there is currently a potential for another 241,000 21 housing units, of which 84 percent is expected to be in areas with existing or planned sewerage 22 service (Maryland Department of Housing and Co mmunity Affairs 2001); therefore, the growth 23 control measures in place would not appear to significantly restrict future housing growth around 24 the site.25 26 The demand for housing units in the Montgomery County region could be met with the 27 construction of new housing. As a result, NRC staff concludes the impacts on housing would 28 be SMALL, and mitigation measures would not be nece ssary or effective. Based on this review, 29 including interviews with local real estate agents, the staff concludes the impact on housing 30 during the license renewal term would be SMALL and no mitigation is warranted.

31 323.3.2Public Services: Public Utilities 33 34 Impacts on public utility services are considered SMALL if there is little or no change in the 35 ability of the system to respond to the level of demand, and thus there is no need to add capital 36 facilities. Impacts are considered MODERATE if overtaxing of service capabilities occurs during 37 periods of peak demand. Impacts are consi dered LARGE if existing levels of service 38 (e.g., water or sewer services) are substantially degraded and additional capacity is needed to 39 meet ongoing demands for services. The staff believes the only potential significant impacts on 40 public utilities are impacts on public water supplies.

41 Operation(a)The NRC Guidance for performing environmental justice reviews defines "minority" as American Indian or Alaskan Native, Asian or Pacific Islander, Black not of Hispanic Origin, or Hispanic (U.S. NRC 2004).

3-5 Analysis of impacts on the public water supply system considered both plant demand and plant-1 related population growth. Section 2.2.8.2 describes the NBSR-permitted withdrawal rate and 2 actual use of water. NIST does not plan to undertake any major change in activities during the 3 license renewal term at the NBSR, and none of the activities would require staffing that would 4 exceed the NBSR's current level of staffing, so plant demand would not change beyond current 5 demands (NIST 2004). Thus, the staff concludes the impact of increased water use resulting 6 from the potential increase in employment is SMALL and no mitigation is warranted.

7 83.3.3Public Services: Transportation 9 10 As described in Section 2.2.8 of this document, the road network around the NIST campus is 11 well established and in heavy use by commuters within Montgomery County to and from the 12 District of Columbia and other surrounding large cities. Operations during the license renewal 13 term of the NBSR would be expected to have SMALL impacts on transportation and no 14 mitigation is warranted.

15 163.3.4Offsite Land Use 17 18 Consistent with the definitions from Section 4.7.4 of the GEIS to define the magnitude of land-19 use changes as a result of plant operation during the license renewal term, the following terms 20 are used to analyze land-use impacts:

21 22 SMALL - Little new development and minimal changes to an area's land-use pattern 23 24 MODERATE - Considerable new development and some changes to the land-use pattern 25 26 LARGE - Large-scale new development and major changes in the land-use pattern.

27 28 There would be no expected population growth as a result of renewing the OL for the NBSR 29 facility. Consequently, the staff concludes that population changes resulting from license 30 renewal are likely to result in SMALL offsite land-use impacts and no mitigation is warranted.

31 323.3.5Environmental Justice 33 34 Environmental justice refers to a Federal policy requiring Federal agencies to identify and 35 address, as appropriate, disproportionately high and adverse human health or environmental 36 effects of its actions on minority(a) or low-income populations. The memorandum accompanying 37 Operation(a)A census block group is a combination of census blocks, which are statistical subdivisions of a census tract. A census block is the smallest geographic entity for which the U.S. Census Bureau (USCB) collects and tabulates decennial census information. A census tract is a small, relatively

permanent statistical subdivision of counties deli neated by local committees of census data users in accordance with USCB guidelines for t he purpose of collecting and presenting decennial census data. Census block groups are subsets of census tracts (USCB 2001).

3-6 Executive Order 12898 (59 FR 7629) direct s Federal executive agencies to consider 1 environmental justice under the National Environmental Policy Act of 1969 (NEPA). The 2 Council on Environmental Quality (CEQ) has provided guidance for addressing environmental 3 justice (CEQ 1997). Although the Executive Order is not mandatory for independent agencies, 4 the Commission has voluntarily committed to undertake environmental justice reviews; the 5 Commission has finalized its approach for considering environmental justice reviews in its 6 Policy Statement (69 FR 52040). Specific guidance is provided in NRC Office of Nuclear 7 Reactor Regulation Office Instruction LIC-203, Revision 1, "Procedural Guidance for Preparing 8 Environmental Assessments and Considering Environmental Issues," issued in May 2004 9 (U.S. NRC 2004).

10 11 The staff examined the geographic distribution of minority and low-income populations within 12 Montgomery County and neighboring counties, employing the 2000 Census data (USCB 2000) 13 for low-income populations and minority populations. For the purpose of the staff's review, a 14 minority population is defined to exist if the percentage of each minority, or aggregated minority 15 category within the census tract or block group(a) potentially affected by the license renewal of 16 NBSR exceeds the corresponding percentage of minorities in the entire State of Maryland by 17 20 percent or if the corresponding percentage of minorities within the census tract or block 18 group is at least 50 percent. A low-income population is defined to exist if the percentage of 19 low-income population within a census tract or block group exceeds the corresponding 20 percentage of low-income population in the entire State of Maryland by 20 percent, or if the 21 corresponding percentage of low-income population within a census tract or block group is at 22 least 50 percent. The minority population in the State of Maryland makes up 35 percent of the 23 population, and the low-income population makes up 8.8 percent of the total population in the 24 State.25 26 Applying the LIC-203 (U.S. NRC 2004) criterion of "more than 20 percent greater," the census 27 block groups containing low-income populations appeared to be primarily in the urban centers 28 around the District of Columbia and Baltimore, Maryland, with only two block groups identified in 29 Montgomery County and two more identified in Frederick County to the north.

30 31 Minority population block groups are present in Montgomery County and all adjacent counties; 32 however, the concentrations of these minority populations are found in the urban centers within 33 and surrounding Baltimore and the District of Columbia.

34 Operation 3-7 With the locations of minority and low-income populations identified, the staff proceeded to 1 evaluate whether any of the environmental impac ts of the proposed action could affect these 2 populations in a disproportionately high and adverse manner. Based on staff guidance 3 (U.S. NRC 2004), air, land, and water resources within and around the NBSR site were 4 examined. The pathways through which the env ironmental impacts associated with NBSR 5 license renewal can affect human populations are discussed in each associated section. The 6 staff found no unusual resource dependencies or practices such as subsistence agriculture, 7 hunting, or fishing through which minority and/or low-income populations could be 8 disproportionately highly and adversely affected. In addition, the staff did not identify any 9 location-dependent, disproportionately high and adverse impacts affecting these minority and 10 low-income populations. The staff concludes offsite impacts from NBSR to minority and low-11 income populations would be SMALL, and no mitigation is warranted.

12 133.4Historic and Archaeological Resources 14 15 Section 106 of the National Historic Preservation Act requires Federal agencies to take into 16 account the effects of their undertakings on historic properties. The Section 106 historic 17 preservation review process is covered in regulations issued by the Advisory Council on Historic 18 Preservation at 36 CFR Part 800. As a starting point, renewal of the OL for the NBSR could 19 potentially affect historic properties that may be located at the site. However, the Maryland 20 Inventory of Historic Properties does not have any records of known archaeological sites or 21 other historic properties within or immediately adjacent to the NBSR or the entire NIST campus 22 (MDP 2006). NRC staff consulted the Maryland Historic Trust regarding the potential renewal of 23 the OL for the NBSR because the staff ultimately determined, in accordance with 36 CFR 24 800.3(a)(1), that renewal would be an activity that does not have the potential to cause effects 25 on historic properties. Operation of the NBSR, as planned under the application for license 26 renewal, would protect undiscovered historic or archaeological resources on the NIST site 27 because the undeveloped natural landscape and vegetation would remain undisturbed, and 28 access to the site would remain restricted. Therefore, the staff concludes the environmental 29 impacts on cultural resources associated with operation during a renewal term would be 30 SMALL, and no additional mitigation measures are warranted. As a Federal agency, activity 31 that could result in disturbing land on the NIST campus would conform with the requirements of 32 the National Historic Preservation Act.

33 34 Operation 3-83.5Ecology 1 2 Ecological impacts considered include those for aquatic and terrestrial resources, as well as 3 threatened and endangered species.

4 53.5.1Aquatic Ecology 6 7 The closed-cycle secondary cooling system has its intake via municipal-water supply lines, and 8 blowdown is discharged to the sanitary sewer system. Surface water and groundwater are not 9 used as process water and process water is not discharged to the surface or groundwater.

10 Therefore, no impacts on aquatic biota as a result of impingement, entrainment, heat, or 11 chlorination are expected to occur.

12 13 Overall impacts to the aquatic biota are expected to be SMALL and no mitigation is warranted.

14 153.5.2Terrestrial Ecology 16 17 The NBSR and associated facilities are located in an industrial complex on the NIST campus.

18 Because of the highly industrialized nature of the facility, it is not expected that terrestrial biota 19 will be impacted from continued operation. Fogging and icing as a result of cooling tower drift 20 and evaporation are not expected other than in the immediate vicinity of the cooling towers.

21 Bird collisions are not expected to occur on either the cooling towers or at the buildings housing 22 these facilities. There have been no visible impacts to vegetation from cooling tower drift 23 recorded in the last 20 years (U.S. NRC 2007). The average annual precipitation of 104 cm 24 (41 in.) is distributed more or less evenly throughout the year, and it is expected that it will wash 25 the deposited drift from vegetative surfaces and prevent accumulation of high salt levels in the 26 soil (NOAA 2006). Impact on surrounding terrestrial vegetation from the cooling tower drift is 27 expected to be small.

28 29 Overall impacts to the terrestrial biota are expected to be SMALL and no mitigation is 30 warranted.

31 323.5.3Threatened and Endangered Species 33 34 Section 7(a)(2) of the Endangered Species Act states that Federal agencies are to consult with 35 the U.S. Fish and Wildlife Service (FWS) to ensure any agency action is not likely to jeopardize 36 the continued existence of any endangered species or threatened species or result in the 37 destruction or adverse modification of habitat of such species. Although no threatened or 38 endangered species are known to occur on the NIST campus, official consultation has been 39 initiated with the FWS. Results of the consultation will be presented in the final EIS.

40 41 Operation 3-9 Aquatic 1 2 There are no known threatened and endangered aquatic species in the vicinity of the NIST 3 campus. No impacts to threatened and endangered aquatic species are expected; therefore, 4 the impacts on aquatic threatened and endangered species are expected to be SMALL, and no 5 mitigation is warranted.

6 7 Terrestrial 8

9 There is suitable habitat for the bald eagle (Haliaeetus leucocephalus) and the small whorled 10 pogonia (Isotria medeoloides) on the NIST campus. The bald eagle is a candidate for delisting 11 under the Endangered Species Act (USFWS 2007), but will continue to be Federally protected 12 under the Bald and Golden Eagle Protection Act. The NBSR and associated facilities are 13 located within an industrial complex on the campus. There are no planned construction 14 activities as part of license renewal requi ring any additional habitat removal (U.S. NRC 2007).

15 Because of the highly industrialized nature of the facility and the fact no construction is planned, 16 it is not expected the small whorled pogonia or the bald eagle would be impacted from 17 continued operation. Overall, impacts to terrestrial threatened and endangered species is 18 expected to be SMALL and no additional mitigation is warranted.

19 203.6Cumulative Impacts of Operations During the License 21 Renewal Term 22 23 The cumulative effects of impacts were considered for operation of the cooling system, 24 radiological doses, socioeconomics, historic and archaeological resources, and ecology.

25 263.6.1Cumulative Impacts Resulting from Operation of the Plant Cooling System 27 28 The geographic area affected by operation of the NBSR cooling system is confined largely to 29 the NIST site. The plume abatement cooling tower minimizes the potential for substantial offsite 30 impacts; therefore, the opportunity for cumulative impacts on nearby facilities is small. Effluents 31 released to the municipal sanitary sewer syst em from cooling tower operations represent a 32 small fraction of the site's total volume, and they are monitored to maintain concentrations of 33 radiological or hazardous materials well within regulatory limits for discharges to public 34 treatment facilities. NRC and EPA regulatory standards were established at levels that account 35 for contributions from multiple sources to releases of radiological or hazardous materials, 36 thereby minimizing the potential for cumulative adverse impacts to public facilities that process 37 the effluents. Therefore, the staff concludes the cumulative impacts resulting from continued 38 operation of the NBSR cooling system would be SMALL and no additional mitigation is 39 warranted.

40 41 Operation 3-103.6.2Cumulative Ra diological Impacts 1 2 The EPA and NRC established radiological dose limits for protection of the public and workers 3 from both near-term and cumulative impacts of exposure to radiation and radioactive materials.

4 Those dose limits are codified in 40 CFR Part 190 and 10 CFR Part 20. For the purpose of this 5 analysis, the area within an 80-km (50-mi) radius of the NIST site was considered. NIST 6 conducts a radiological environmental monitori ng program (REMP) around the NBSR site to 7 measure radiation and radioactive materials from all sources, including the reactor and 8 associated research facilities (NIST 2006). Hi storically, these measurements have remained at 9 relatively constant low levels and provide no indication of cumulative effects over time. Other 10 laboratories within the NIST campus may also use radioactive materials. Radiological 11 exposures to workers at NIST are monitored to ensure they do not exceed regulatory standards.

12 Additionally, the staff concluded that impacts of radiation exposure to the public and workers 13 (occupational) from operation of the NBSR during the license renewal term are small. The NRC 14 and the State of Maryland would regulate any future actions in the vicinity of the NIST site that 15 could contribute to cumulative radiological impacts; none are contemplated at this time.

16 17 Therefore, the staff concludes that cumulative radiological impacts of continued operations of 18 the NBSR would be SMALL, and no additional mitigation is warranted.

19 203.6.3Cumulative Socioeconomic Impacts 21 22 The analyses of socioeconomic impacts presented in Section 3.3 already incorporate 23 cumulative impact analysis. For instance, the impact of the total number of additional housing 24 units that may be needed can only be evaluated with respect to the total number that will be 25 available in the affected area. Given that a ll license renewal socioeconomic impacts associated 26 with NBSR are SMALL, the staff concluded these impacts would not result in significant 27 cumulative impacts on potentially affected socioeconomic resources and no mitigation is 28 warranted.

29 303.6.4Cumulative Impacts on Histor ic and Archaeological Resources 31 32 The Maryland Inventory of Historic Properties does not have any record of known 33 archaeological sites or other historic properties within or immediately adjacent to the NBSR or 34 the entire NIST campus. Given that all license renewal historical and archaeological impacts 35 associated with NBSR are deemed to be SMALL, the staff concluded these impacts would not 36 result in significant cumulative impacts on historic and archaeological resources and no 37 mitigation is warranted.

38 39 Operation 3-113.6.5Cumulative Impacts on Ecology Including Threatened and Endangered 1 Species 2 3 There are no known threatened and endangered aquatic species in the vicinity of the NIST 4 campus. There is suitable habitat for two Federally listed terrestrial species on the NIST 5 campus; the NBSR and associated facilities are located within an industrial complex on the 6 NIST campus and no new construction is planned as part of license renewal within the industrial 7 complex or elsewhere on the NIST campus. Therefore, the staff determined continued 8 operation at the plant site will not have a detectable contribution to the cumulative, regional 9 impacts on threatened or endangered aquatic and terrestrial species. The effects are SMALL 10 and no mitigation is warranted.

11 123.7Summary of Impacts of Operations During the License 13 Renewal Term 14 15 The NBSR is a small, non-power test reactor located in a wing of a building within the industrial 16 complex on the NIST campus. It uses municipal water for make-up water, and blowdown is 17 discharged directly to the sanitary sewer system. The number of employees is small in relation 18 to the population of the surrounding community. R adiological impacts are minimized by meeting 19 applicable regulations for releases, monitoring, and doses to workers and the public, including 20 implementing an ALARA program. Therefore, t he staff concludes the potential environmental 21 impact of renewal-term operations of the NBSR would be SMALL, and no additional mitigation is 22 warranted.

23 243.8References 25 26 10 CFR Part 20. Code of Federal Regulations, Title 10, Energy , Part 20, "Standards for 27 Protection Against Radiation."

28 29 10 CFR Part 51. Code of Federal Regulations, Title 10 , Energy, Part 51, "Environmental 30 Protection Regulations for Domestic Licensing and Related Regulatory Functions."

31 32 36 CFR Part 800. Code of Federal Regulations, Title 36, Parks, Forests, and Public Property

, 33 Part 800, "Protection of Historic Properties."

34 35 40 CFR Part 190. Code of Federal Regulations, Title 40, Protection of Environment , Part 190, 36"Environmental Protection Standards for Nuclear Power Operations."

37 38 59 FR 7629. Executive Order 12898, "Federal Actions to Address Environmental Justice in 39 Minority and Low-Income Populations."

Federal Register. Vol. 59, No. 32. February 16, 1994.

40 Operation 3-12 69 FR 52040. "Policy Statement on the Treatment of Environmental Justice Matters in the NRC 1 Regulatory and Licensing Actions."

Federal Register. Vol. 69, No. 163. August 24, 2004.

2 3 Council on Environmental Quality (CEQ). 1997. Environmental Justice: Guidance Under the 4National Environmental Policy Act. Executive Office of the President, Washington, D.C.

5 6 Endangered Species Act. 16 USC 1531 et seq.

7 8 Maryland Department of Housing and Community A ffairs. 2006. "Technical Supplement to the 9 Montgomery County, Maryland Housing Policy: Montgomery County - The Place to Call 10 Home," Report available upon request at www.co.mo.md.us/hca. July 2001. Rockville, 11 Maryland.12 13 Maryland Department of Planning (MDP) 2006. Letter, dated February 17, 2006, from Elizabeth 14 J. Cole, Administrator, Project Review and Compliance.

15 16 National Historic Preservation Act of 1966 (NHPA). 16 USC 470, et seq.

17 18 National Institute of Standards and Technology (NIST). 2004. Environmental Report for 19 License Renewal for the National Institute of Standards and Technology Reactor-NBSR. 20 NBSR-16, NISTIR 7105, NIST, Gaithersburg, Maryland.

21 22 National Institute of Standards and Technology (NIST). 2006.

National Institute of Standards 23and Technology Reactor. Operations Report #58. January 1, 2005 to December 31, 2005. 24 NIST, Gaithersburg, Maryland.

25 26 National Oceanic and Atmospheric Administration. 2006. "Climate at a Glance." Accessed on 27 the Internet at http://climvis.ncdc.noaa.gov/cgi-bin/cag3/hr-display3.pl on February 6, 2006.

28 29 U.S. Census Bureau (USCB). 2000. "Census 2000 Summary File I (SF-1) 100 Percent Data."

30 Accessed on the Internet at 31 http://factfinder.census.gov/servlet/DatasetMainPageServlet?_ds_name=DEC_2000_SF3_U&_

32 program=DEC&_lang=en in January 2003.

33 34 U.S. Census Bureau (USCB). 2001. "Glossary - Definition and Explanations - decennial 35 census terms." Accessed on the Internet at 36 http://landview.census.gov/dmd/www/advglossary.html in January 2003.

37 38 U.S. Fish and Wildlife Service (USFWS). 2007. "Division of Migratory Bird Management - Bald 39 Eagle." Accessed on the Internet at http://www.fws.gov/migratorybirds/BaldEagle.htm in 40 January 2007.

41 42 Operation 3-13 U.S. Nuclear Regulatory Commission (U.S.NRC). 1996. Generic Environmental Impact 1Statement for License Renewal of Nuclear Plants. NUREG-1437, Volumes 1 and 2, 2 Washington, D.C.

3 4 U.S. Nuclear Regulatory Commission (U.S.NRC). 1999. Generic Environmental Impact 5Statement for License Renewal of Nuclear Plants, Main Report , "Section 6.3 - Transportation, 6 Table 9.1, Summary of findings on NEPA issues for license renewal of nuclear power plants, 7 Final Report." NUREG-1437, Volume 1, Addendum 1, Washington, D.C.

8 9 U.S. Nuclear Regulatory Commission (U.S.NRC). 2004. "Procedural Guidance for Preparing 10 Environmental Assessments and Considering Environmental Issues." LIC-203, Revision 1, 11 May 24, 2004. ML033550003.

12 13 U.S. Nuclear Regulatory Commission (U.S.NRC). 2007. Summary of Site Audit to Support the 14 License Renewal Review for the National Bureau of Standards Reactor (NBSR) at the National 15 Institute of Standards and Technology. ML070370061.

16 (a)The GEIS was originally issued in 1996. Addendum 1 to the GEIS was issued in 1999. Hereafter, all references to the "GEIS" include the GEIS and Addendum 1.

4-1 4.0 Environmental Impacts of Postulated Accidents 1 2 3 The potential impacts of accidents at the National Bureau of Standards Reactor (NBSR) located 4 at the National Institute of Standards and Technology (NIST) during the license renewal term 5 are presented in the following sections. Environmental issues associated with postulated 6 accidents at nuclear power reactors are discussed in the Generic Environmental Impact 7Statement for License Renewal of Nuclear Plants (GEIS), NUREG-1437, Volumes 1 and 2 8 (U.S. NRC 1996, 1999).(a) There are substantial differences between the NBSR and 9 commercial power reactors; however, the types of environmental issues addressed in this 10 chapter are similar, and in many cases the environmental impacts from continued operation of 11 the NBSR can be informed by analysis discussed in the GEIS. Therefore, where appropriate, 12 the GEIS analyses are used as a basis for evaluating the environmental impacts of continued 13 operation of the NBSR. The GEIS includes a determination of whether the analysis of a 14 particular environmental issue could be applied to all commercial power reactors and whether 15 additional mitigation measures would be warranted.

16 17 This chapter describes the environmental impac ts from postulated accidents at the NBSR 18 considered for the license renewal term. Section 4.1 presents postulated accidents, Section 4.2 19 addresses severe accident mitigation alternatives, and references are listed in Section 4.3.

20 21 Unless otherwise indicated, information in the following sections was adapted from the 22 Environmental Report (ER) (NIST 2004a) and the Final Safety Analysis Report (SAR) 23 (NIST 2004b) submitted by NIST for renewal of the NBSR operating license (OL), and was 24 independently verified by the staff. Additional information was obtained by the staff during the 25 site audit (U.S. NRC 2007); appropriate citations will be made for other sources.

26 274.1Postulated Facility Accidents 28 29 Two classes of accidents are evaluated for commercial power plants in the GEIS. These are 30 referred to as design-basis accidents (DBAs) and severe accidents. Corresponding accidents 31 evaluated for the NBSR are discussed in the following sections.

32 334.1.1Design-Basis Accidents 34 35 To receive U.S. Nuclear Regulatory Commission (U.S.NRC) approval to operate a nuclear 36 reactor, an applicant must submit a SAR as part of the application. The SAR presents the 37 design criteria and design information for the proposed reactor and comprehensive data on the 38 Postulated Accidents 4-2 proposed site. The SAR also discusses hypothetical accident scenarios as well as the safety 1 features present in the facility to prevent and mitigate accidents. The NRC staff reviews the 2 application to determine whether the facility design meets the Commission's regulations and 3 requirements. The facility design includes, in part, the reactor design and its anticipated 4 response to an accident.

5 6 DBAs are postulated and evaluated to ensure the reactor can withstand normal and abnormal 7 transient conditions and a broad spectrum of postulated accidents, without undue hazard to the 8 health and safety of the public. A number of the postulated accidents are not expected to occur 9 during the life of the facility but are evaluated to establish the design basis for the preventive 10 and mitigative safety systems of the facility.

The acceptance criteria for DBAs are described in 11 Title 10 of the Code of Federal Regulations (CFR) Part 50 and 10 CFR Part 100.

12 13 The environmental impacts of DBAs were evaluated during the initial licensing process for the 14 NBSR, and the ability of the facility to withstand these accidents was demonstrated to be 15 acceptable before NRC issued the OL. The results of these evaluations are found in license 16 documentation such as the staff's Safety Evaluation Report (SER), the licensee's updated Final 17 SAR, and this environmental impact statement (EIS

). The licensee is required to maintain the 18 acceptable design and performance criteria throughout the life of the facility, including the 19 license renewal period. The consequences of accidents are evaluated for the hypothetical 20 maximally exposed individual, and as such, changes in the facility environment would not affect 21 these evaluations. Renewal of the operating license requires accident consequences remain 22 acceptable and aging management programs are in effect. Therefore, the environmental 23 impacts as calculated for DBAs over the life of the facility, including the license renewal period, 24 should not differ significantly from initial licensing assessments. Accordingly, the design of the 25 facility relative to DBAs during the license renewal period is considered to remain acceptable, 26 and the environmental impacts of those accident s were not examined further in the GEIS.

27 28 The NBSR includes many inherent, passive safety features, some of which would preclude the 29 types of reactor accidents commonly evaluated for nuclear power plants. The prompt neutron 30 lifetime is relatively long as a result of heavy water moderation, and the reactivity coefficients of 31 void and temperature are negative. The reactor operates in a low-temperature, unpressurized 32 condition and does not have a large stored energy content. The cooling system is designed to 33 retain coolant in the event of a loss of water from the reactor vessel and to supply emergency 34 coolant flow to the fuel elements and the reactor core without operator intervention. DBAs 35 evaluated in the NBSR Final SAR (NIST 2004b) included start-up, maximum reactivity insertion, 36 loss of flow, fuel-handling, and loss of coolant. The evaluations demonstrate that none of these 37 accidents would result in a safety hazard to the public or to the environment.

38 39 The NIST ER (NIST 2004a) did not identify any information relevant to accident impacts 40 associated with the renewal of the NBSR OL. In addition, the staff has not identified any 41 concerns during the staff's independent review of the ER, the scoping process, the staff's site 42 Postulated Accidents 4-3 visit, and its evaluation of other available information. With respect to nuclear power reactors, 1 the Commission determined the environmental impacts of DBAs are of SMALL significance for 2 all plants because the plants are designed to successfully withstand these accidents. The 3 power levels of commercial power reactors are of the order of 100 times greater than that of the 4 NBSR and are expected to bound the environmental impacts of the DBAs for the NBSR.

5 Therefore, the staff concludes there are no impacts of DBAs during the license renewal term 6 that exceed or differ substantially from those discussed in the GEIS and further mitigation is not 7 warranted.

8 94.1.2Severe Accidents 10 11 Severe nuclear accidents include events that could result in damage to the reactor core, 12 whether or not there are serious offsite consequences, and they are considered separately from 13 DBAs. The GEIS assessed the impacts of severe accidents at commercial power reactors 14 during the license renewal period, using the results of existing analyses and site-specific 15 information to conservatively predict the env ironmental impacts of severe accidents for each 16 plant during the license renewal period.

17 18 The only severe accident identified for the NBSR is discussed in the facility Final SAR 19 (NIST 2004b). That event, designated the maximum hypothetical accident (MHA), is one in 20 which all coolant flow through a single fuel element is blocked while the reactor is operating at 21 full power. Such an event is highly unlikely because the NBSR is a closed system with upward 22 flow. However, if the flow in an element is blocked during full power operation, it is possible 23 some melting of the cladding could occur with a resultant release of fission products into the 24 primary coolant. In evaluating the consequences of the MHA, it was conservatively assumed 25 the entire blocked element's cladding would melt and release fission products into the primary 26 cooling system. Analysis of consequences follo wing the MHA in the NBSR Final SAR estimated 27 the total whole body gamma dose to a person standing at the site boundary 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> a day for 28 30 days would be 7 mrem and the iodine dose to the thyroid would be negligible. Those 29 consequences would be well below limits specified for DBAs in 10 CFR Part 100.

30 31 The staff reviewed information concerning severe accidents during its independent review of the 32 ER, the scoping process, the site visit, and its evaluation of other available information and 33 concludes that the impacts of severe accidents at commercial power reactors as discussed in 34 the GEIS would bound any potential accidents at the NBSR.

35 36 As part of the GEIS analysis, the probability we ighted consequences of atmospheric releases, 37 fallout onto open bodies of water, releases to groundwater, and societal and economic impacts 38 from severe accidents were determined to be SMALL and further mitigation is not warranted.

39 The power levels of commercial power reactors are of the order of 100 times greater than that of 40 the NBSR and are expected to bound the environmental impacts of severe accidents for the 41 Postulated Accidents 4-4 NBSR. No design changes are proposed for the NBSR and no severe accident mitigation 1 analysis is required 2 34.2References 4 5 10 CFR Part 50. Code of Federal Regulations, Title 10, Energy , Part 50, "Domestic Licensing of 6 Production and Utilization Facilities."

7 8 10 CFR Part 51. Code of Federal Regulations, Title 10, Energy , Part 51, "Environmental 9 Protection Regulations for Domestic Licensing and Related Regulatory Functions."

10 11 10 CFR Part 100. Code of Federal Regulations, Title 10, Energy , Part 100, "Reactor Site 12 Criteria."

13 14 National Institute of Standards and Technology (NIST). 2004a. Environmental Report for 15 License Renewal for the National Institute of Standards and Technology Reactor-NBSR. 16 NBSR-16, NISTIR 7105, NIST, Gaithersburg, Maryland.

17 18 National Institute of Standards and Technology (NIST). 2004b.

Safety Analysis Report (SAR) 19 for License Renewal for the National Institute of Standards and Technology Reactor-NBSR. 20 NBSR-14, NISTIR 7102, NIST, Gaithersburg, Maryland.

21 22 U.S. Nuclear Regulatory Commission (U.S.NRC). 1996. Generic Environmental Impact 23Statement for License Renewal of Nuclear Plants. NUREG-1437, Vols. 1 and 2, Washington, 24 D.C.25 26 U.S. Nuclear Regulatory Commission (U.S.NRC). 1999. Generic Environmental Impact 27Statement for License Renewal of Nuclear Plants, Main Report , "Section 6.3 - Transportation, 28 Table 9.1, Summary of findings on NEPA issues for license renewal of nuclear power plants, 29 Final Report." NUREG-1437, Volume 1, Addendum 1, Washington, D.C.

30 (a)The GEIS was originally issued in 1996. Addendum 1 to the GEIS was issued in 1999. Hereafter, all references to the "GEIS" include the GEIS and its Addendum 1.

5-1 5.0 Environmental Impacts of the Uranium 1 Fuel Cycle and Solid Waste Management 2 3 4 This chapter addresses the environmental impacts related to the nuclear fuel cycle and solid 5 waste management related to operating the National Bureau of Standards Reactor (NBSR) at 6 the National Institute of Standards and Technology (NIST) site during the license renewal term.

7 In many cases, the impacts resulting from renewal of the NBSR operating license can be 8 extrapolated from previous analyses for commercial power reactors in the Generic 9Environmental Impact Statement for License Renewal of Nuclear Plants (GEIS), NUREG-1437, 10 Volumes 1 and 2 (U.S. NRC 1996, 1999).((a)) For power reactors, environmental impacts from 11 the supporting uranium fuel cycle were ev aluated based on a model 1000-MWe (megawatts of 12 electric power) light-water cooled reactor (LWR) operating at an annual capacity factor of 13 80 percent. Accounting for the efficiency of producing electric power from thermal power and 14 the capacity factor of 80 percent, the power level of a commercial reactor is on the order of 15 100 times greater than the NBSR. The results of the analyses are listed in 10 CFR 51.51(b), 16 Table S-3, "Table of Uranium Fuel Cycle Environmental Data," and in 10 CFR 51.52(c), 17 Table S-4, "Environmental Impact of Transporta tion of Fuel and Waste to and from One Light-18 Water-Cooled Nuclear Power Reactor." The staff's analysis of the radiological impact from 19 radon-222 and technetium-99 releases are addressed separately from those listed in the tables 20 (U.S. NRC 1996, 1999). The principal radon releases occur during uranium mining and milling 21 operations and as emissions from mill tailings, whereas the principal technetium-99 releases 22 occur from gaseous diffusion uranium enrichment facilities.

23 24 The NBSR differs from a commercial power reactor in several respects: 1) it uses highly 25 enriched uranium (HEU) fuel compared to the low enriched uranium (LEU) fuel used in 26 commercial power reactors, 2) the reactor core is cooled and moderated by heavy water (D 2 O)27 rather than light water (H 2 O), and 3) it operates at a much lower power level (20 MWt 28[megawatts of thermal power] compared to about 3000 MWt for a typical power reactor).

29 Therefore, the impacts from the uranium fuel cy cle for the NBSR could differ from those for a 30 commercial power reactor, particularly those resulting from use of HEU rather than LEU fuel.

31 However, the staff's conclusion for most types of environmental impacts would not be altered if 32 the analysis were to be based on the operation of the NBSR after applying appropriate scaling 33 factors for the power output (of the order of 100 times smaller) compared to a model LWR.

34 35 There are substantial differences between the NBSR and commercial power reactors; however, 36 the types of environmental issues addressed in this chapter are similar, and in many cases, the 37 environmental impacts from continued operati on of the NBSR can be informed by analyses 38 Uranium Fuel Cycle 5-2 discussed in the GEIS. Environmental impacts from the NBSR uranium fuel cycle are 1 discussed in the following section.

2 35.1The Uranium Fuel Cycle 4 5 The Environmental Report (ER) submitted by NI ST (NIST 2004) did not specifically address 6 environmental impacts from the ur anium fuel cycle related to the renewal of the NBSR operating 7 license. The staff performed an independent review of the ER, the scoping process, and 8 conducted a site visit.

9 10 A brief description of the staff's review, the conclusions, and a discussion of their applicability to 11 the NBSR for each of the issues follows:

12 13 Offsite radiological impacts (individual effects from other than the disposal of 14 spent fuel and high level waste) 15 16 Offsite impacts of the uranium f uel cycle have been considered by the 17 Commission in Table S-3 of 10 CFR 51.51(b). Accounting for the differences 18 between the model LWR and the NBSR, including the differences in power level 19 and fuel enrichment, radiological environmental impacts on individuals from 20 radioactive gaseous and liquid releases (including radon-222 and technetium-99) 21 are expected to be small.

22 23 Offsite radiological impacts (collective effects) 24 25 Offsite impacts (collective effects) of the uranium fuel cycle have been considered by the 26 Commission in Table S-3 of 10 CFR 51.51(b). Accounting for the differences between 27 the model LWR and the NBSR, including the differences in fuel power level and 28 enrichment, collective radiological env ironmental impacts on populations from 29 radioactive gaseous and liquid releases (including radon-222 and technetium-99) are 30 expected to be small.

31 32 Offsite radiological impacts (spent fuel and high level waste [HLW] disposal) 33 34 The fuel used for the NBSR is owned by the U.S. Department of Energy (DOE), 35 and DOE is responsible for its storage, processing, and disposal. The 36 radiological impacts from management of spent fuel and high level waste, 37 including interim storage and disposal of highly enriched test reactor fuel, have 38 also been evaluated separately (U.S.DOE 1995, 2002).

39 40 Despite the current uncertainty with respect to licensing of a HLW repository, some judgment as 41 to the implications of offsite radiological impacts of spent fuel and high-level waste disposal 42 Uranium Fuel Cycle 5-3 should be made. The staff concludes these impacts would be sufficiently small that the option 1 of extending the NBSR operating license should be preserved. Based on the volume of spent 2 fuel generated during the license renewal period at the NBSR and its total radionuclide content, 3 the impacts from disposal of NBSR spent fuel re lative to those from a commercial power reactor 4 are considered to be small.

5 6 At this time, there are no facilities for permanent disposal of high-level radioactive wastes 7 (HLW). The Nuclear Waste Policy Act of 1982 defined the goals and structure of a program for 8 permanent, deep geologic repositories for HLW and unreprocessed spent fuel. Under this Act, 9 the DOE is responsible for developing permanent disposal capacity for the spent fuel and other 10 high-level nuclear wastes. At the present time, DOE, as directed by Congress, is investigating a 11 site in Yucca Mountain, Nevada, for a possible disposal facility. A HLW repository would be 12 built and operated by DOE and licensed by the NRC. The Commission believes (10 CFR 13 51.23(a)) there is reasonable assurance at least one mined geological repository will be 14 available in the first quarter of the 21st Century and that, within 30 years beyond the licensed 15 life of operation for any reactor, sufficient repository capacity will be available to dispose of the 16 reactor's HLW and spent fuel generated up to that time.

17 18 The Commission has independently, in a separate proceeding (i.e., the Waste Confidence 19 Proceeding), made a finding that there is:

20 21...reasonable assurance that, if necessary, spent fuel generated in any 22 reactor can be stored safely and without significant environmental 23 impacts for at least 30 years beyond the licensed life for operation (which 24 may include the term of a revised license) of that reactor at its spent fuel 25 storage basin, or at either onsite or offsite independent spent fuel storage 26 installations (54 FR 39767).

27 28 The Commission has committed to review this finding at least every 10 years. In its most recent 29 review, the Commission concluded that experience and developments since 1990 were not 30 such that a comprehensive review of the Waste Confidence Decision was necessary at this time 31 (64 FR 68005). Accordingly, the Commission reaffirmed its findings of insignificant 32 environmental impacts cited above. This finding is codified in the Commission's regulations at 33 10 CFR 51.23(a). The staff relies on the Waste Confidence Rule, but for completeness has 34 elected to include in this draft EIS information related to the storage and maintenance of fuel in 35 a spent fuel pool.

36 37 As stated earlier, the spent fuel from the NBSR is stored at NIST and then shipped to the DOE 38 Savannah River Site for reprocessing or shipment to a permanent repository. By comparison to 39 power reactors, the NBSR operates at substantially lower power levels (by a factor of 75 to 150 40 Uranium Fuel Cycle 5-4 or more) and the quantity of fuel for the NBSR reactor is likely be to smaller by the same factor.

1 Therefore, the staff concludes the relatively small quantities involved in the extended period of 2 operation do not bring into question the Commission's Waste Confidence Decision.

3 4 Nonradiological impacts of the uranium fuel cycle 5 6 Based on the relative quantities of fuel and total fissile material required for the 7 NBSR relative to those for a model LWR, the nonradiological impacts of the 8 uranium fuel cycle resulting from the renewal of an operating license for NBSR 9 are considered to be small.

10 11 Low-level waste storage and disposal 12 13 The comprehensive regulatory controls in place and the low public doses being 14 achieved at reactors ensure the radiol ogical impacts to the environment will 15 remain small during the term of a renewed license. Because low-level waste is 16 transported regularly for treatment as necessary and disposal, the maximum 17 additional onsite land required for low-level waste storage during the term of a 18 renewed license and associated impacts w ill be small. Nonradiological impacts 19 on air and water will be negligible. The radiological and nonradiological 20 environmental impacts of long-term disposal of low-level waste from any reactor 21 are small. In addition, the staff concludes that there is reasonable assurance 22 sufficient low-level waste disposal capacity will be made available when needed 23 for facilities to be decommissioned consistent with U.S. Nuclear Regulatory 24 Commission decommissioning requirements.

25 26 Mixed waste storage and disposal 27 28 The comprehensive regulatory controls and the facilities and procedures in place 29 ensure proper handling and storage, as well as negligible doses and exposure to 30 toxic materials for the public and the environment for all reactors. License 31 renewal will not increase the small risk to human health and the environment 32 posed by mixed waste at all reactors. The radiological and nonradiological 33 environmental impacts of long-term disposal of mixed waste from any reactor are 34 small. In addition, the staff concludes there is reasonable assurance sufficient 35 mixed waste disposal capacity will be made available when needed for facilities 36 to be decommissioned consistent with NRC decommissioning requirements.

37 38 39 Uranium Fuel Cycle 5-5 Onsite spent fuel 1 2 The onsite radiological impacts from interim storage of NBSR spent fuel are considered 3 small. The fuel used for the NBSR is owned by the DOE, and DOE is responsible for its 4 storage, processing, and disposal. Because the NBSR regularly ships spent fuel offsite 5 for storage, the onsite impacts of managing it are expected to remain small.

6 7 Nonradiological waste 8 9 No changes to nonradiological waste generation are anticipated for NBSR during 10 the license renewal period. Facilities and procedures are in place to ensure 11 continued proper handling and disposal, and the impacts from managing the 12 wastes are considered to be small.

13 14 Transportation 15 16 The impacts of transporting spent fuel from the model LWR to a single repository, such 17 as Yucca Mountain, Nevada were found to be consistent with the impact values 18 contained in 10 CFR 51.52(c), Summary Table S-4. The fuel used for the NBSR is 19 owned by the DOE, and DOE is responsible for its processing and disposal. Spent fuel 20 from the NBSR is transported from the NIST site to the DOE Savannah River Site for 21 storage. The radiological impacts from management of spent fuel and HLW, including 22 transportation of highly enriched test reactor fuel, have also been evaluated separately 23 (U.S. DOE 1995, 2002). Based on the volume of spent fuel generated during the license 24 renewal period at the NBSR and its total radionuclide content, the impacts from 25 transporting NBSR spent fuel relative to those from a commercial power reactor are 26 considered to be small.

27 28 Based on the foregoing, the staff concludes there are no significant environmental impacts 29 related to the uranium fuel cycle; therefore, the impacts are SMALL and no mitigation is 30 warranted.

31 325.2References 33 34 10 CFR Part 51. Code of Federal Regulations, Title 10, Energy, Part 51, "Environmental 35 Protection Regulations for Domestic Licensing and Related Regulatory Functions."

36 37 54 FR 39767. "Proposed Waste Confidence Decision."

Federal Register , Vol. 54, pp. 39,767.

38 September 28, 1989.

39 40 64 FR 68005. "Waste Confidence Decision Review: Status."

Federal Register , Vol. 64, 41 No. 233, pp. 68,005-68,007. December 6, 1999.

42 Uranium Fuel Cycle 5-6 National Institute of Standards and Technology (NIST). 2004. Environmental Report for 1 License Renewal for the National Institute of Standards and Technology Reactor-NBSR. 2 NBSR-16, NISTIR 7105, NIST, Gaithersburg, Maryland.

3 4 U.S. Department of Energy (U.S.DOE). 1995. Department of Energy Programmatic Spent 5Nuclear Fuel Management and Idaho National Engineering Laboratory Environmental 6Restoration and Waste Management Programs Final Environmental Impact Statement. 7 DOE/EIS-0203-F, U.S. Department of Energy , Office of Environmental Management, Idaho 8 Operations Office, Idaho Falls, Idaho.

9 10 U.S. Department of Energy (U.S.DOE). 2002. Final Environmental Impact Statement for a 11 Geologic Repository for the Disposal of Spent Nuclear Fuel and High-Level Radioactive Waste 12 at Yucca Mountain, Nye County, Nevada. DOE/EIS-0250F, U.S. Department of Energy, 13 Washington, D.C.

14 15 U.S. Nuclear Regulatory Commission (U.S.NRC). 1996. Generic Environmental Impact 16Statement for License Renewal of Nuclear Plants. NUREG-1437, Vols. 1 and 2, Washington, 17 D.C.18 19 U.S. Nuclear Regulatory Commission (U.S.NRC). 1999. Generic Environmental Impact 20Statement for License Renewal of Nuclear Plants, Main Report , "Section 6.3 - Transportation, 21 Table 9.1, Summary of findings on NEPA issues for license renewal of nuclear power plants, 22 Final Report." NUREG-1437, Volume 1, Addendum 1, Washington, D.C.

23 (a)The GEIS was originally issued in 1996. Addendum 1 to the GEIS was issued in 1999. Hereafter, all references to the "GEIS" include the GEIS and its Addendum 1.

6-1 6.0 Environmental Impacts of Decommissioning 1 2 3 Environmental impacts from decommissioning research and test reactors are addressed in the 4Final Generic Environmental Impact Statement on Decommissioning of Nuclear Facilities

, 5 NUREG-0586, published in August 1988 (U.S. NRC 1988). A supplement to NUREG-0586 was 6 published to update information regarding commercial power reactors (U.S. NRC 2002).

7 Although information in the original NUREG would be most directly applicable to estimating 8 decommissioning impacts for the National Bureau of Standards Reactor (NBSR), updated 9 information in Supplement 1 to NUREG-0586 regarding waste management, transportation, or 10 other areas is useful for this analysis.

11 12 The incremental environmental impacts associated with decommissioning activities resulting 13 from continued operation of commercial power reactors during the license renewal term were 14 evaluated in the Generic Environmental Impact Statement for License Renewal of Nuclear 15 Plants (GEIS), NUREG-1437, Volumes 1 and 2 (U.S. NRC 1996, 1999).(a)16 17 There are substantial differences between the NBSR and commercial power reactors; however, 18 the types of environmental issues addressed in th is chapter are similar, and in many cases the 19 environmental impacts from continued operati on of the NBSR can be informed by analyses 20 discussions in the GEIS. Therefore, where appropriate, the GEIS analyses are used as a basis 21 for evaluating the environmental impacts of continued operation of the NBSR. The 22 environmental impacts related to decommissioni ng from operating the NBSR during the license 23 renewal term are presented in the following sections.

24 256.1Decommissioning 26 27 Decommissioning issues related to the NBSR following the renewal term are discussed in the 28 following sections. The Environmental Report (ER) submitted by the National Institute of 29 Standards and Technology (NIST 2004) did not identify information associated with impacts of 30 decommissioning of the NBSR. In addition, the staff has not identified any additional relevant 31 information concerning impacts during its independent review of the ER, the scoping process, 32 the staff's site visit, or its evaluation of other available information. Therefore, the staff 33 concludes there are no impacts related to these issues beyond those discussed in either the 34 GEIS for license renewal (U.S. NRC 1996, 1999) or NUREG-0586 and Supplement 1 (U.S.

35 NRC 1988, 2002).

36 37 Decommissioning 6-2 A brief description of the staff review, the GEIS conclusions, and a discussion of their 1 applicability to the NBSR for each of the issues follows:

2 3 Radiation doses. Based on information in the GEIS, the Commission found that 4 doses to the public will be well below applicable regulatory standards regardless 5 of which decommissioning method is used. Occupational doses would increase 6 no more than 1 person-rem (0.01 person-Sv) caused by buildup of long-lived 7 radionuclides during the license renewal term.

8 9 Waste management. Based on information in the GEIS, the Commission found 10 that decommissioning at the end of a 20-year license renewal period would 11 generate no more solid wastes than at the end of the current license term. No 12 increase in the quantities of Class C or greater than Class C wastes would be 13 expected.14 15 Air quality. Based on information in the GEIS, the Commission found that air 16 quality impacts of decommissioning are expected to be negligible either at the 17 end of the current operating term or at the end of the license renewal term.

18 19 Water quality. Based on information in the GEIS, the Commission found that the 20 potential for significant water quality impacts from erosion or spills is no greater 21 whether decommissioning occurs after a 20-year license renewal period or after 22 the original 40-year operation period, and m easures are readily available to avoid 23such impacts.

24 25 Ecological resources. Based on information in the GEIS, the Commission found 26 that decommissioning after either the initial operating period or after a 20-year 27 license renewal period is not expected to have any direct ecological impacts.

28 29 Socioeconomic Impacts. Based on information in the GEIS, the Commission 30 found that decommissioning would have some short-term socioeconomic 31 impacts. The impacts would not be increased by delaying decommissioning until 32 the end of a 20-year relicense period, but they might be decreased by population 33 and economic growth.

34 35 For all of these issues, the staff concluded that the impacts from decommissioning reactors are 36 SMALL, and additional mitigation measures are not likely to be sufficiently beneficial to be 37 warranted. Because the NBSR is expected to contain smaller quantities of radioactive and 38 hazardous materials than commercial power reactors at the end of its license renewal term, the 39 impacts from decommissioning the NBSR would be well within the range of those discussed for 40 commercial power reactors (U.S. NRC 1996, 1999, 2002).

41 42 Decommissioning 6-3 For the subjects discussed above, the staff has not identified any relevant information during its 1 independent review of the ER, the staff's site visit, the scoping process, or its evaluation of other 2 available information. Therefore, the staff concludes radiation dose, waste management, air 3 quality, water quality, ecological resource, and socioeconomic impacts associated with 4 decommissioning the NBSR following the license renewal term are bounded by those discussed 5 in the GEIS.

6 76.2References 8 9 10 CFR Part 51. Code of Federal Regulations, Title 10, Energy, Part 51, "Environmental 10 Protection Regulations for Domestic Licensing and Related Regulatory Functions."

11 12 National Institute of Standards and Technology (NIST). 2004. Environmental Report for 13 License Renewal for the National Institute of Standards and Technology Reactor-NBSR. 14 NBSR-16, NISTIR 7105, NIST, Gaithersburg, Maryland.

15 16 U.S. Nuclear Regulatory Commission (U.S.NRC). 1988. Final Generic Environmental Impact 17Statement on Decommissioning of Nuclear Facilities. NUREG-0586, Washington, D.C.

18 19 U.S. Nuclear Regulatory Commission (U.S.NRC). 1996. Generic Environmental Impact 20Statement for License Renewal of Nuclear Plants. NUREG-1437, Vols. 1 and 2, 21 Washington, D.C.

22 23 U.S. Nuclear Regulatory Commission (U.S.NRC). 1999. Generic Environmental Impact 24Statement for License Renewal of Nuclear Plants, Main Report , "Section 6.3 - Transportation, 25 Table 9.1, Summary of findings on NEPA issues for license renewal of nuclear power plants, 26 Final Report." NUREG-1437, Volume 1, Addendum 1, Washington, D.C.

27 28 U.S. Nuclear Regulatory Commission (U.S.NRC). 2002. Generic Environmental Impact 29Statement on Decommissioning of Nuclear Facilities. Supplement 1 Regarding the 30Decommissioning of Nuclear Power Reactors. Final Report. NUREG-0586, Supplement 1, 31 Vols. 1 and 2. Office of Nuclear Reactor Regulation, Washington, D.C.

32 (a)The GEIS was originally issued in 1996. Addendum 1 to the GEIS was issued in 1999. Hereafter, all references to the "GEIS" include the GEIS and its Addendum 1.

7-1 7.0 Environmental Impacts of the Alternatives 1 2 3 This chapter examines the potential environmental impacts associated with alternatives to the 4 proposed action. The alternatives considered are (1) denying the renewal of the operating 5 license (OL) (i.e., the no-action alternative) for the National Bureau of Standards Reactor 6 (NBSR) at the National Institute of Standards and Technology (NIST), (2) constructing a new 7 reactor and associated support facilities to replace the capabilities of the NBSR, and 8 (3) performing work currently conducted at the NBSR at alternative existing research facilities.

9 For the third alternative, the staff determined that comparable alternative facilities do not exist in 10 the United States. The NBSR is the nation's only cold neutron source with the range of 11 instrumentation that can meet the needs of the U.S. neutron-scattering science program.

12 Additionally, the NBSR has the only very high inelastic cold neutron spectrometer, spin echo, 13 and backscattering instruments in the United States. In addition, it is very difficult for U.S.

14 scientists to secure research time at potentially suitable foreign facilities, such as the Institut 15 Laue-Langevin facility in France; the Paul Scherrer Institut laboratory in Switzerland; or the 16 Forshungsreakter Munchen reactor in Germany. For these reasons, the staff did not consider 17 these foreign research facilities to be viable alternatives to the NBSR. Consequently, the third 18 alternative was not considered further.

19 20 Using the U.S. Nuclear Regulatory Commission's established license renewal evaluation 21 framework for commercial power reactors ensures a thorough evaluation of the impacts of 22 renewal of the OL for the NBSR. The Generic Environmental Impact Statement for License 23 Renewal of Nuclear Plants (GEIS), NUREG-1437, Volumes 1 and 2 (U.S. NRC 1996, 1999)(a)24 was written specifically for use in the renewal of operating licenses for commercial power 25 reactors. In conducting the staff review of the NIST application, the NRC was informed by 26 certain GEIS features including the use of the three-level standard of significance. In following 27 the precedent of the GEIS and site-specific s upplemental license renewal environmental impact 28 statements (EISs), environmental issues hav e been evaluated using a three-level standard of 29 significance - SMALL, MODERATE, or LARGE - developed using the Council on 30 Environmental Quality guidelines and set forth in the footnotes to Table B-1 of 10 CFR Part 51, 31 Subpart A, Appendix B:

32 33 SMALL - Environmental effects are not detectable or are so minor that they will neither 34 destabilize nor noticeably alter any important attribute of the resource.

35 36 MODERATE - Environmental effects are sufficient to alter noticeably, but not to 37 destabilize important attributes of the resource.

38 39 Alternatives 7-2 LARGE - Environmental effects are clearly noticeable and are sufficient to destabilize 1 important attributes of the resource.

2 37.1No-Action Alternative 4 5 NRC's regulations implementing National Environm ental Policy Act of 1969 (NEPA) specify the 6 no-action alternative be discussed in an NRC EIS (10 CFR Part 51, Subpart A, Appendix A(4)).

7 For license renewal, the no-action alternative refers to a scenario in which NRC would not 8 renew the OL for the NBSR. NIST would then decommission the NBSR and the associated 9 facilities covered under the OL at some future time.

10 11 NIST would be required to comply with NRC decommissioning requirements whether or not the 12 NBSR OL is renewed. If the OL is renewed, decommissioning activities could be postponed for 13 up to an additional 20 years. If the OL is not renewed, NIST would conduct decommissioning 14 activities according to the requirements in 10 CFR 50.82(b).

15 16 The environmental impacts of the no-action alternative are summarized in Table 7-1 and are 17 discussed in the following sections. Implementati on of the no-action alternative would also have 18 certain positive impacts in that adverse environm ental impacts associated with current operation 19 of the NBSR, however small they may be, would be eliminated.

20 217.1.1Land Use 22 23 Temporary changes in onsite land use could occur during decommissioning, including addition 24 or expansion of staging and laydown areas or construction of temporary buildings and parking 25 areas. No offsite land-use changes are expected as a result of decommissioning. Following 26 decommissioning, the land occupied by the NBSR would likely be retained by NIST for other 27 purposes. The staff concludes the impacts of the no-action alternative on land use would be 28 SMALL.29 307.1.2Aquatic and Terrestrial Resources 31 32 Land disturbance during decommissioning is expected to be minimal and would result in 33 relatively short-term ecological impacts that could be mitigated using best management 34 practices. The land is expected to recover naturally. No impacts to threatened or endangered 35 species as a result of decommissioning activities are anticipated. Overall, the staff concludes 36 the impacts to aquatic and terrestrial resources associated with the no-action alternative would 37 be SMALL.38 39 40 Alternatives 7-3 Table 7-1. Summary of Environmental Impacts of the No-Action Alternative 1 2 Impact Category 3ImpactComment Land Use4SMALLOnsite impacts expected to be temporary. No offsite impacts expected.Aquatic and Terrestrial 5 Resources 6SMALLImpacts are expected to be minimal, temporary, and largely mitigatable using best management practices.

Water Use and Quality7SMALLWater use will decrease. Water quality unlikely to be adversely affected during decommissioning.

Air Quality8SMALLGreatest impact is likely to be from fugitive dust; impact can be mitigated by good management practices.

Waste9SMALLLLW will be disposed of at DOE or licensed facilities. Apermanent disposal facility for HLW is not currently available.

Human Health10SMALLRadiological doses to workers and members of the public are expected to be within regulatory limits. Occupational

injuries are possible, but injury rates at nuclear reactors are

below the U.S. average industrial rate.

Socioeconomics11SMALLSlight decrease in employment.

Aesthetics12SMALLSmall positive impact from eventual removal of buildings and structures. Some noise impact during decommissioning

operations.

Historic and 13 Archaeological Resources 14SMALLMinimal impact on land utilized during reactor operations.

Land occupied by the NBSR would likely be retained by

NIST for other purposes.

Environmental Justice15SMALLMinimal impact.

167.1.3 Water Use and Quality 17 18 Cessation of plant operations would result in a reduction in water use because reactor cooling 19 would no longer be required. As plant staff size decreases, the demand for potable water would 20 be expected to decrease as well. Overall, the staff concludes that the water use and quality 21 impacts of decommissioning would be SMALL.

22 237.1.4Air Quality 24 25 Decommissioning activities that can adversely affect air quality include dismantlement of 26 systems and equipment, demolition of buildings and structures, and operation of internal 27 combustion engines. The most likely adverse impact would be the generation of fugitive dust.

28 Best management practices, such as seeding and wetting, can be used to minimize the 29 generation of fugitive dust. Overall, the staff concludes the air quality impacts associated with 30 decommissioning activities would be SMALL.

31 Alternatives 7-47.1.5Waste 1 2 Decommissioning activities would result in the generation of radioactive and nonradioactive 3 waste. Low-level radioactive waste (LLW) would be transferred to the U.S. Department of 4 Energy (DOE) or disposed of in a facility licensed by NRC or a state with authority delegated by 5 the NRC. Recent advances in volume reduction and waste processing have significantly 6 reduced waste volumes. A permanent repository for high-level radioactive waste (HLW) is not 7 currently available. The NRC has made a generic determination that, if necessary, spent fuel 8 generated in any reactor can be stored safely and without significant environmental impacts for 9 at least 30 years beyond the licensed life for operation (which may include the term of a revised 10 or renewed license) of that reactor at its spent fuel storage basin or at either onsite or offsite 11 independent spent fuel storage installations [10 CFR 51.23(a)]. Disposal of nonradioactive 12 waste would be at offsite disposal facilities with appropriate permits. Overall, the staff 13 concludes the waste impacts associated with the no-action alternative would be SMALL.

14 157.1.6Human Health 16 17 Radiological doses to occupational workers during decommissioning and collective doses to 18 members of the public and to the maximally exposed individual as a result of decommissioning 19 activities would be well below the limits in 10 CFR Part 20. Occupational injuries to workers 20 engaged in decommissioning activities are possible; however, historical injury and fatality rates 21 at nuclear reactors have been lower than the average U.S. industrial rates. Overall, the staff 22 concludes the human health impacts associated wi th the no-action alternative would be SMALL.

23 247.1.7Socioeconomics 25 26 If the NBSR ceases operation, there would be a decrease in employment. However, impacts 27 would be minimal because NBSR employment le vels are relatively small and numerous other 28 employers are in the Washington, D.C., metropolitan area. The no-action alternative would 29 result in the loss of NBSR payrolls approximatel y 20 years earlier than if the OL were renewed.

30 Overall, the staff concludes the socioeconomic impacts resulting from implementation of the 31 no-action alternative would be SMALL.

32 337.1.8Environmental Justice 34 35 Current operations at NBSR have no disproportionate impacts (adverse or otherwise) on the 36 minority and low-income populations of Montgomery County and the surrounding counties, and 37 no environmental pathways have been identified t hat would cause disproportionate impacts.

38 Closure of the NBSR could result in a small dec rease in employment opportunities with possible 39 slight negative and disproportionate impacts on minority or low-income populations that would 40 be temporarily offset by the labor needed to support decommissioning activities. However, the 41 small number of employees working at the NBSR is negligible when compared to the number of 42 Alternatives 7-5 employment opportunities in the surrounding area. Overall, the staff concludes the 1 environmental justice impacts under the no-action alternative would be SMALL.

2 37.1.9Aesthetics and Noise 4 5 Decommissioning would result in the eventual dismantlement of buildings and structures at the 6 NIST site, resulting in a positive aesthetic impact. Noise that may be detectable offsite from the 7 NIST campus would be generated during decommissioning operations; however, the impact is 8 not likely to destabilize or alter any important attribute of the resource. Overall, the staff 9 concludes the aesthetic and noise impacts associated with the no-action alternative would be 10 SMALL.11 127.1.10 Historic and Archaeological Resources 13 14 The amount of undisturbed land needed to support the decommissioning process would be 15 relatively small. Decommissioning activities conducted on the NIST campus would not be 16 expected to have a detectable effect on important cultural resources. The Maryland Inventory 17 of Historic Properties does not have any records of known archaeological sites or other historic 18 properties within or immediately adjacent at the NBSR or the entire NIST campus (MDP 2006).

19 Nevertheless, in the event that any historic and archaeological resources on the NIST campus 20 were discovered, these resources would not be expected to be adversely affected during 21 decommissioning. It is likely that the NBSR wing of the 235 Building would be retained by NIST 22 following decommissioning. The staff concludes the impacts of the no-action alternative on 23 historic and archaeological resources would be SMALL.

24 257.2Construction of a Replacement Reactor and Associated 26 Facilities 27 28 The alternative of constructing a replacement reactor and associated support facilities for the 29 NBSR is discussed in this section. Under this alternative, it is assumed the OL for the NBSR 30 would not be renewed and a new replacement reactor and associated support facilities would 31 be constructed, perhaps, at another site. The support facilities are assumed to include a 32 cooling tower, fuel storage area, a ventilation and exhaust stack, a facility comparable to the 33 existing Cold Neutron Guide Hall, an office building, and a building for service equipment. The 34 analysis is based on construction of a replacement reactor and associated facilities at some 35 alternate location east of the Mississippi River; no specific site for new construction is assumed.

36 37 Some of the estimated impact information in Section 7.2 is adapted from a DOE EIS (U.S.

38 DOE 2000). Section 4.6 of the DOE EIS evaluated the construction of a new research reactor 39 at a generic DOE site for the production of plutonium-238, isotopes for medical and industrial 40 uses, and materials testing for civilian nuclear energy research and development.

41 Alternatives 7-6 DOE currently supplies the uranium fuel used by the NBSR (NIST 2004). It is assumed DOE 1 would also supply the fuel for a new replacement reactor.

2 3 The staff's characterizations of the impacts associated with construction and operation of a 4 replacement reactor at an alternate location are shown in Table 7-2.

5 6 Table 7-2.Characterization of Impacts Associated with Construction and Operation of a 7 Replacement Reactor and Associated Support Facilities 8 9 Impact Category 10ConstructionOperation Land Use11SMALLSMALL Aquatic and Terrestrial Resources12SMALLSMALL Water Use and Quality13SMALLSMALL Air Quality14SMALLSMALL Waste15SMALLSMALL Human Health16SMALLSMALL Socioeconomics17SMALLSMALL Aesthetics and Noise18SMALLSMALL Historic and Archaeological Resources19SMALLSMALL Environmental Justice20SMALLSMALL 217.2.1Land Use 22 23 The construction of a new reactor and support facilities would disturb as much as approximately 24 4 ha (10 ac). It is assumed siting would be conducted so construction would be compatible with 25 local zoning and the Coastal Zone Management Program if such a program is applicable in the 26 hosting state. Clearing and grading operations could result in the loss of wetlands, although 27 proper placement of the reactor and support facilities would eliminate or reduce the potential for 28 such loss. Potential impacts on wetlands would be mitigated by the implementation of best 29 management practices.

30 31 Overall, the staff concludes impacts on land use from constructing and operating a replacement 32 reactor and associated support facilities would be SMALL.

33 34 Alternatives 7-77.2.2Aquatic and Terrestrial Resources 1 2 During construction, impacts on aquatic resources could result from stormwater runoff. Runoff 3 could alter flow rates, increase turbidity, and lead to sedimentation of streambeds. These 4 impacts could, in turn, cause temporary and permanent changes in species composition and 5 density and alter breeding habitats. Implementation of erosion and sediment control procedures 6 would lessen construction impacts. Operational impacts on aquatic resources could occur as a 7 result of water withdrawal and discharge. Water withdrawal could lead to the loss of aquatic 8 organisms through impingement or entrainment. Discharge of cooling water could result in 9 alterations in aquatic communities. Alterations could include changes in aquatic vegetation and 10 the loss of fish and benthic macroinvertebrates. Additionally, radionuclides and chemicals in the 11 discharge water have the potential to impact aquatic organisms. The extent of potential impacts 12 on the aquatic environment would depend upon site- and facility-specific design information.

13 14 Construction of a replacement reactor and support facilities would likely result in the loss of 15 woodland habitat at the alternate location. Land-clearing activities would affect animal 16 populations. Less mobile animals within the project area, such as reptiles and small mammals, 17 might not be expected to survive. Construction activities and noise would cause larger 18 mammals and birds in the construction and adjacent areas to move to similar habitat nearby. If 19 the area to which they moved was below its carrying capacity, these animals would be expected 20 to survive. However, if the area were already supporting the maximum number of individuals, 21 the additional animals would compete for limited resources that could lead to habitat 22 degradation and eventual loss of the excess population. Nests and young animals living within 23 the disturbed area might not survive. Activities associated with operations could affect wildlife 24 living adjacent to the research reactor and support facilities. Emissions to the air and water, 25 both nonradiological and radiological, could impact both plants and animals. Plants and 26 animals could be exposed to pollutants via a number of pathways, including direct exposure, 27 contact with contaminated soil, ingestion, and inhalation. Bioaccumulation could affect species 28 that consume exposed plants or animals.

29 30 Construction and operation of a replacement reactor and support facilities could have the 31 potential to impact threatened and endangered species. Consultations with the Fish and 32 Wildlife Service, the Fisheries Service, and appropriate State agencies would be conducted at 33 the site-specific level, as appropriate, to minimize adverse impacts.

34 35 Although the impacts on aquatic and terrestrial resources cannot be known with certainty given 36 the assumption of siting at some alternate location, the staff estimates the aquatic and terrestrial 37 resource impacts of constructing and operating a replacement reactor and associated support 38 facilities at some alternate location east of the Mississippi River would be SMALL.

39 40 Alternatives 7-87.2.3Water Use and Quality 1 2 During construction of a replacement reactor and support facilities, water is expected to be 3 required for such uses as concrete mixing, dust control, washing activities, and potable and 4 sanitary needs. The impact of these withdrawals on the resource would depend on the water 5 source (surface water or groundwater) and its relative abundance. Impacts would be expected 6 to be small because of the relatively small volumes of water required for construction compared 7 to expected water availability. Nearby wastew ater treatment facilities would be used to the 8 extent possible and would be supplemented by portable or temporary facilities during 9 construction as necessary. All wastewater would be disposed of in accordance with applicable 10 regulatory requirements with discharges to surface waters in accordance with National Pollutant 11 Discharge Elimination System (NPDES) effluent requirements. Ground disturbance and runoff 12 from cleared areas could potentially impact surface water quality near construction areas.

13 However, appropriate spill prevention practices and soil erosion and sediment control measures 14 (e.g., use of silt fences and mulching and seeding disturbed areas) would be employed during 15 construction to minimize water quality impacts.

16 17 During operation, water would be required to support such uses as process cooling and potable 18 and sanitary needs. The single largest system use would be for cooling tower operation and 19 associated evaporative losses. The impact of these withdrawals on the resource would depend 20 on the water source (i.e., surface water or groundwater) and its relative abundance. For surface 21 water, a dedicated surface water intake might have to be constructed if the site's existing 22 distribution system is inadequate to meet the increased demands of the facilities. For 23 groundwater, additional wells might have to be developed to supply the facilities directly or to 24 provide increased production capacity for the site's existing supply system. It is expected that 25 process effluent would mainly consist of cooling tower blowdown. There would be no 26 radiological liquid effluent discharge to the environment under normal operations. Wastewater 27 would be generated as a result of staff use of lavatories, showers, kitchens, and experimental 28 facilities, and from miscellaneous potable and sanitary uses. Process and sanitary wastewater 29 would be discharged to either existing site wastew ater treatment facilities or to new facilities 30 constructed specifically to serve the new reac tor and support operations. All wastewater would 31 be disposed of in accordance with applicable regulatory requirements with discharges to 32 surface waters in accordance with NPDES effluent limitations.

33 34 Although the impacts on water use and quality cannot be known with certainty, assuming some 35 alternate location east of the Mississippi River, the staff estimates the water use and quality 36 impacts of constructing and operating a replacement reactor and associated support facilities 37 would be SMALL.

38 39 Alternatives 7-97.2.4Air Quality 1 2 Construction of a new reactor and support facilities would result in an increase in vehicle traffic 3 with associated emissions. Some construction equipment would have emissions, and fugitive 4 dust emissions from the construction process would also occur. During operation, emissions 5 from the stack exhaust would be comparable to those for the NBSR and associated facilities.

6 All construction and operation activities would be conducted in compliance with applicable 7 regulatory requirements for air emissions.

8 9 Although the impacts on air quality cannot be known with certainty, assuming some alternate 10 location east of the Mississippi River, the staff estimates the air quality impacts of constructing 11 and operating a replacement reactor and associated support facilities would be SMALL 12 provided the region is in attainment for National Ambient Air Quality Standards.

13 147.2.5 Waste 15 16 During construction, nonhazardous waste and debris would be generated. These materials 17 would be disposed of offsite in disposal facilities with appropriate permits.

18 19 During operation, waste impacts would be comparable to those for the NBSR and associated 20 facilities, as discussed in Chapter 5 of this EIS.

21 22 Overall, the staff estimates the waste impacts from constructing and operating a replacement 23 reactor and associated facilities at a generic eastern site would be SMALL, but could be larger 24 than continuing use of the current facility.

25 267.2.6Human Health 27 28 During construction of a replacement reactor and associated facilities, it is anticipated there 29 would be no radiological health impacts beyond exposure to natural background levels in the 30 construction area. Construction workers could experience industrial accidents that are possible 31 at any construction activity.

32 33 During operation, human health impacts would be comparable to those for the NBSR, as 34 discussed in Chapters 3, 4, and 5 of this draft EIS.

35 36 Overall, the staff estimates the human health impacts from constructing and operating a 37 replacement reactor and associated facilities, assuming some alternate location east of the 38 Mississippi River, would be SMALL, but could be larger than continuing operation of the current 39 facility due to construction impacts.

40 41 Alternatives 7-107.2.7Socioeconomics 1 2 It is estimated that on the order of 100 workers would be needed for a time period of 2 to 3 3 years to construct a replacement reactor and associated support facilities. The 4 socioeconomic impacts of this workforce would be limited unless the site selected was in a 5 remote, rural area.

6 7 During operation, socioeconomic impacts would be comparable to those of the NBSR, 8 assuming location of the replacement reactor in an urban area. For location in a rural area, 9 socioeconomic impacts could be somewhat greater although they would still be small given the 10 limited workforce required to operate the reactor.

11 12 Although impacts cannot be known with certainty, assuming some alternate location east of the 13 Mississippi River, the staff estimates the socioeconomic impacts of construction and operation 14 of a replacement reactor and associated support facilities would be SMALL.

15 167.2.8Environmental Justice 17 18 Construction and operation of a replacement reactor and associated support facilities would be 19 unlikely to have disproportionately high and adv erse health or environmental impacts on 20 minority or low-income populations because radiological and nonradiological risks to persons 21 residing in potentially affected areas would not be significant.

22 23 Overall, the staff estimates the environmental justice impacts from constructing and operating a 24 replacement reactor and associated facilities at some alternate location east of the Mississippi 25 River would be SMALL.

26 277.2.9Aesthetics and Noise 28 29 Construction and operation of a replacement reactor and associated support facilities would 30 have an aesthetic impact. The extent of the impact would depend on the location chosen and 31 the surrounding land and land uses. The NBSR facility is housed in a building that is low to the 32 ground; the staff assumes a replacement reactor would be similarly unobtrusive. The staff also 33 assumed the cooling system for a replacement reactor would have a plume suppression cooling 34 tower similar to that used for the NBSR (NIST 2004).

35 36 Construction of a replacement reactor and support facilities would result in some increase in 37 noise levels from the use of earthmoving, materials-handling and impact equipment, employee 38 vehicles, and truck traffic. Noise from cons truction activities, especially impulsive noise 39 (e.g., jack hammers) would be temporary but could disturb wildlife in the immediate area of the 40 construction site. The change in noise levels in areas outside the site would depend on the 41 location selected and the exact nature of the construction location and activities required.

42 Alternatives 7-11 Operation of a replacement reactor and support facilities would result in some increase in noise 1 levels from equipment (e.g., cooling systems, vents, motors, generators, compressors, pumps, 2 and material-handling equipment), employee vehicles , and truck traffic. Noise from operation 3 activities could disturb wildlife outside the facility fence line. The change in noise levels in areas 4 outside the site would depend on the location selected, the size of the site, and the equipment 5 used.6 7 Overall, the staff estimates the aesthetic and noise impacts from constructing and operating a 8 replacement reactor and associated facilities at some alternate location east of the Mississippi 9 River would be SMALL.

10 117.2.10Historic and Ar chaeological Resources 12 13 Because the exact nature of the site for a replacement reactor and associated support facilities 14 is not known, potential effects of construction and operation on cultural resources cannot be 15 determined. In general, if the alternate location had been previously developed, impacts on 16 cultural resources might not occur. However, if an undisturbed location were chosen, cultural 17 resources could be impacted. Historic and archaeological resources, including those that are or 18 may be eligible for listing on the National Register of Historic Places, would be identified through 19 site surveys and consultation with the State Historic Preservation Officer. Specific concerns 20 about the presence, type, and location of Native American resources would be addressed 21 through consultation with the potentially affected tribes in accordance with the National Historic 22 Preservation Act, the Native American Graves Protection and Repatriation Act, and the 23 American Indian Religious Freedom Act.

24 25 Although the impacts of construction and operation of a replacement reactor and associated 26 support facilities on historic and archaeological resources cannot be known with certainty, 27 assuming some alternate location east of the Mississippi River, the staff estimates the impacts 28 would be SMALL.

29 307.3Summary of Alternatives Considered 31 32 The adverse environmental impacts resulting from ei ther of the alternatives considered by the 33 staff if the NBSR ceases operation upon final determination of the license renewal application 34 will not be smaller than those associated with continued operation, and they may be greater for 35 some environmental issues in some locations.

36 37 Alternatives 7-127.4References 1 2 10 CFR Part 20. Code of Federal Regulations, Title 10, Energy , Part 20, "Standards for 3 Protection Against Radiation."

4 5 10 CFR Part 50. Code of Federal Regulations, Title 10, Energy, Part 50, "Domestic Licensing of 6 Production and Utilization Facilities."

7 8 10 CFR Part 51. Code of Federal Regulations, Title 10, Energy , Part 51, "Environmental 9 Protection Regulations for Domestic Licensing and Related Regulatory Functions."

10 11 American Indian Religious Freedom Act. 42 USC 1996, et seq.

12 13 Maryland Department of Planning (MDP). 2006. Letter dated February 17, 2006 from Elizabeth 14 J. Cole, Administrator, Project Review and Compliance. ML070380446.

15 16 National Environmental Policy Act of 1969 (NEPA). 42 USC 4321, et seq.

17 18 National Institute of Standards and Technology (NIST). 2004. Environmental Report for 19 License Renewal for the National Institute of Standards and Technology Reactor. NISTIR 7105, 20 NIST, Gaithersburg, Maryland.

21 22 National Historic Preservation Act of 1966 (NHPA). 16 USC 470, et seq.

23 24 Native American Graves Protection and Repatriation Act. 25 USC 3001, et seq.

25 26 U.S. Department of Energy (U.S.DOE). 2000. Final Programmatic Environmental Impact 27Statement for Accomplishing Expanded Civilian Nuclear Energy Research and Development 28 and Isotope Production Missions in the United States, Including the Role of the Fast Flux Test 29 Facility. DOE/EIS-0310, Washington, D.C. Online at:

30 http://www.eh.doe.gov/nepa/eis/eis0310/eis0310.html.

31 32 U.S. Nuclear Regulatory Commission (U.S.NRC). 1996. Generic Environmental Impact 33Statement for License Renewal of Nuclear Plants. NUREG-1437, Volumes 1 and 2, 34 Washington, D.C.

35 36 U.S. Nuclear Regulatory Commission (U.S.NRC). 1999. Generic Environmental Impact 37Statement for License Renewal of Nuclear Plants, Main Report , "Section 6.3 - Transportation, 38 Table 9.1, Summary of findings on NEPA issues for license renewal of nuclear power plants, 39 Final Report." NUREG-1437, Volume 1, Addendum 1, Washington, D.C.

40 8-1 8.0 Summary and Conclusions 1 2 3 By letter dated April 9, 2004, the National Institute of Standards and Technology (NIST) 4 submitted an application to the U.S. Nuclear Regulatory Commission (NRC) to renew the 5 operating license (OL) for the National Bureau of Standards Reactor (NBSR) for an additional 6 20-year period (NIST 2004). If the OL is renewed, NIST and other decisionmakers will 7 ultimately decide whether the reactor will continue to operate. If the OL is not renewed, then the 8 reactor must be shut down upon NRC's determination of the application. The current OL for the 9 NBSR was scheduled to expire on May 16, 2004. However, in accordance with 10 10 CFR 2.109(a), NIST's application for renewal was received at least 30 days prior to the 11 expiration of the current license, and therefore, the existing OL will not be considered expired 12 until the application has been finally determined.

13 14 Section 102 of the National Environmental Policy Act of 1969 (NEPA) (42 USC 4321, et seq.)

15 directs that an environmental impact statement (E IS) is required for major Federal actions that 16 significantly affect the quality of t he human environment. The NRC has implemented 17 Section 102 of NEPA in Title 10 of the Code of Federal Regulations (CFR) Part 51. Part 51 18 identifies licensing and regulatory actions that require an EIS. In 10 CFR 51.20(b)(2), the 19 Commission requires preparation of an EIS for renewal of a testing facility (test reactor) OL.

20 21 Upon acceptance of the NIST application, the NRC began the environmental review process 22 described in 10 CFR Part 51 by publishing a notice of intent to prepare an EIS and conduct 23 scoping (70 FR 56935) on September 29, 2005. The staff visited the NIST site in 24 September 2006. The staff reviewed the Environmental Report (ER) submitted by NIST 25 (NIST 2004), consulted with other agencies, and conducted an independent analysis of the 26 issues. No comments were received from the public during the scoping process in advance of 27 the preparation of this draft EIS.

28 29 This draft EIS includes the NRC staff's analysis that considers and weighs the environmental 30 effects of the proposed action, the environmental impacts of alternatives to the proposed action, 31 and mitigation measures available for reducing or avoiding adverse effects. It also includes the 32 staff's preliminary recommendation regarding the proposed action.

33 34 With the issuance of this draft EIS, a 75-day comment period will commence. When the 35 comment period ends, the staff will consider any comments received. These comments will be 36 addressed in Appendix B, Part II, of the final EIS.

37 38 For this license renewal review, the NRC considers the purpose and need for the proposed 39 action (renewal of the NBSR OL) is to provide an option allowing for neutron research 40 capabilities beyond the term of the current reactor operating license to meet future national 41 research and test facility needs, as such needs may be determined by NIST.

42 Summary and Conclusions 8-2 There may be factors, in addition to NRC's license renewal determination, that will ultimately 1 determine whether the NIST test reactor continues to operate beyond the determination of this 2 license renewal action.

3 4 For the evaluation of the NBSR license renewal action, the staff has applied the NRC's three-5 level standard of significance - SMALL, MODE RATE, or LARGE - developed using the Council 6 on Environmental Quality guidelines. The following definitions of the three significance levels 7 are set forth in the footnotes to Table B-1 of 10 CFR Part 51, Subpart A, Appendix B:

8 9 SMALL - Environmental effects are not detectable or are so minor that they will 10 neither destabilize nor noticeably alter any important attribute of the resource.

11 12 MODERATE - Environmental effects are sufficient to alter noticeably, but not to 13 destabilize, important attributes of the resource.

14 15 LARGE - Environmental effects are clearly noticeable and are sufficient to 16 destabilize important attributes of the resource.

17 18 The staff considered the environmental impacts a ssociated with alternatives to license renewal 19 and compared the environmental impacts of license renewal and the alternatives. The 20 alternatives to license renewal that were considered include the no-action alternative (not 21 renewing the OL for the NBSR) and replacement of the capabilities of the NBSR.

22 238.1Environmental Impacts of the Proposed Action -

24 License Renewal 25 26 The staff has established an independent process for identifying and evaluating the 27 environmental impacts associated with license renewal. Neither the scoping process, NIST 28 staff, nor the NRC staff has identified any issue applicable to the NBSR that would have a 29 significant environmental impact. Measures were considered for mitigation of the environmental 30 impacts of plant operation. The existing mitigation measures were found to be adequate, and 31 no additional mitigation measures were deemed sufficiently beneficial to be warranted.

32 33 The following sections discuss unavoidable adverse impacts, irreversible or irretrievable 34 commitments of resources, and the relationship between local short-term use of the 35 environment and long-term productivity.

36 37 38 Summary and Conclusions 8-38.1.1Unavoidable Adverse Impacts 1 2 An environmental review conducted at the license-renewal stage differs from the review 3 conducted in support of a construction permit or initial OL because the plant is in existence at 4 the license-renewal stage and has operated for a number of years. As a result, adverse 5 impacts associated with the initial construction have been avoided, have been mitigated, or 6 have already occurred. The environmental impac ts to be evaluated for license renewal are 7 those associated with continued operation during the renewal term; NIST did not consider that 8 major refurbishment activities would be necessary for the continued operation of the NBSR.

9 10 The adverse impacts of continued operation identified are considered to be of SMALL 11 significance, and none warrants implementation of additional mitigation measures. The staff 12 concludes adverse impacts of likely alternat ives if the NBSR ceases operation upon final 13 determination of the licence renewal application will not be smaller than those associated with 14 continued operation, and they may be greater for some environmental issues in some locations.

15 168.1.2Irreversible or Irretrievable Resource Commitments 17 18 The commitment of resources related to construction and operation of the NBSR during the 19 current license period was made when the plant was built. The resource commitments to be 20 considered in this draft EIS are associated with continued operation of the plant for an additional 21 20 years. These resources include materials and equipment required for plant maintenance 22 and operation, the nuclear fuel used by the reactor and, ultimately, disposition of the spent fuel 23assemblies.

24 25 The most significant resource commitments related to operation during the renewal term are the 26 fuel and the permanent spent fuel disposition. NIST replaces 4 of the 30 fuel elements every 27 refueling outage, which occurs at 5- to 6-week intervals.

28 29 If the NBSR ceases operation upon final determination of the current application, the likely 30 alternative would require a commitment of resources for construction of a replacement reactor 31 and test facility as well as for fuel to operate such a reactor.

32 338.1.3Short-Term Use Versus Long-Term Productivity 34 35 An initial balance between short-term use and long-term productivity of the environment at the 36 NIST site was set when construction of the NBSR was approved and construction began. That 37 balance is now well established. Renewal of the OL for NBSR and continued operation of the 38 reactor will not alter the existing balance, but may postpone the availability of that portion of the 39 Summary and Conclusions 8-4 building complex housing the reactor for other uses. Denial of the application to renew the OL 1 would lead to shutdown of the reactor and would alter the balance in a manner that would 2 depend on subsequent uses of the building or the site.

3 48.2Relative Significance of the Environmental Impacts of 5 License Renewal and Alternatives 6 7 The proposed action is renewal of the OL for the NBSR. Chapter 2 describes the site, reactor, 8 and interactions of the reactor with the environment. As noted in Chapter 3, no refurbishment 9 and no refurbishment impacts are expected at the NBSR. Chapters 3 through 6 discuss 10 environmental issues associated with renewal of the OL. Environmental issues associated with 11 the no-action alternative and alternatives invo lving construction and operation of a replacement 12 facility are discussed in Chapter 7.

13 14 The significance of the environmental impacts from the proposed action (approval of the 15 application for renewal of the OL), the no-action alternative (denial of the application), and 16 construction of new research capabilities at some alternate eastern location are listed in 17 Table 8-1. Construction of facilities similar to the NBSR is assumed for the alternate location.

18 19 Table 8-1 shows the significance of the environmental effects of the proposed action are 20 SMALL for all impact categories. The alternat ive actions, including the no-action alternative, 21 may have environmental effects in at least some impact categories that, although considered 22 SMALL, could be larger than the impacts of license renewal of the existing NBSR.

23 24 Table 8-1.Summary of Environmental Significance of License Renewal, the No-Action 25 Alternative, and Construction and Operation of Alternative Research Facilities 26 27Impact Category 28Proposed ActionNo-Action Alternative Replacement FacilityLicense RenewalDenial of Renewal Land Use 29SMALLSMALLSMALL Ecology 30SMALLSMALLSMALLWater Use and Quality-Surface Water 31SMALLSMALLSMALLWater Use and Quality-Groundwater 32SMALLSMALLSMALL Air Quality 33SMALLSMALLSMALL Waste 34SMALLSMALLSMALL Human Health 35SMALLSMALLSMALL Socioeconomics 36SMALLSMALLSMALL Aesthetics 37SMALLSMALLSMALL Historic and Archaeological Resources 38SMALLSMALLSMALL Environmental Justice 39SMALLSMALLSMALL Summary and Conclusions 8-58.3Staff Conclusions and Recommendations 1 2 Based on the ER submitted by NIST (NIST 2004); consultation with Federal, State, and local 3 agencies; the staff's independent analysis; and the opportunity to consider public comments 4 during the scoping process, the preliminary recommendation of the staff is that the Commission 5 determine the adverse environmental impacts of lic ense renewal for NBSR are not so great that 6 preserving the option of license renewal for Federal decision-makers would be unreasonable.

7 88.4References 9 10 10 CFR Part 51. Code of Federal Regulations, Title 10, Energy, Part 51, "Environmental 11 Protection Regulations for Domestic licensing and Related Regulatory Functions."

12 13 70 FR 56935. "National Institute of Standards and Technology, National Bureau of Standards 14 Reactor; Notice of Intent to Prepare an Environmental Impact Statement and Conduct Scoping 15 Process."

Federal Register

Vol. 70, No. 188, pp. 56,935-56,936. September 29, 2005.

16 17 National Environmental Policy Act of 1969 (NEPA). 42 USC 4321, et seq.

18 19 National Institute of Standards and Technology (NIST). 2004. Environmental Report for 20 License Renewal for the National Institute of Standards and Technology Reactor. NISTIR 7105, 21 NIST, Gaithersburg, Maryland.

22 Appendix A Contributors to the Document Summary and Conclusions A-1 Appendix A 1 2 Contributors to the Document 3 4 5 The overall responsibility for the preparation of this environmental impact statement was 6 assigned to the Office of Nuclear Reactor Regulation, U.S. Nuclear Regulatory Commission 7 (NRC). The statement was prepared by members of the Office of Nuclear Reactor Regulation 8 with assistance from other NRC organizations and the Pacific Northwest National Laboratory.

9 10 Name 11AffiliationFunction or ExpertiseNuclear Regulatory Commission 12 James Wilson13Nuclear Reactor RegulationProject Management Dennis Beissel14Nuclear Reactor RegulationProject Management Barry Zalcman15Nuclear Reactor RegulationProject ManagementPacific Northwest National Laboratory (a)16Beverly Miller 17 Task Leader Eva Eckert Hickey 18 Deputy Task Leader Jeremy Rishel 19 Air Quality Katherine Cort 20 Socioeconomics and Cultural Resources Amanda Stegen 21 Aquatic and Terrestrial Ecology Kathleen Rhoads 22 Radiation Protection Paul Hendrickson 23 Land Use, Related Federal Programs, Alternatives Lance Vail 24 Water Use, Hydrology James Weber 25 Technical Editor Cary Counts 26 Technical Editor Lila Andor 27 Document Production Susan Tackett 28 Document Production(a)Pacific Northwest National Laboratory is operated for the U.S. Department of Energy by Battelle Memorial 29 Institute.

30 31 Appendix B Comments Received on the Environmental Review B-1 Appendix B 1 2 Comments Received on the Environmental Review 3 4 5 Part I - Comments Received During Scoping 6 7 On September 29, 2005, the U.S. Nuclear Regulatory Commission (NRC) published a Notice of 8 Intent in the Federal Register (70 FR 56935) to notify the public of the staff's intent to prepare a 9 plant-specific environmental impact statement (EIS) to consider the renewal application for the 10 National Institute of Standards and Technology National Bureau of Standards Reactor operating 11 license and to conduct scoping. This draft EIS has been prepared in accordance with the 12 National Environmental Policy Act of 1969, and Title 10 of the Code of Federal Regulations 13 (CFR) Part 51. As outlined by 10 CFR Part 51, the NRC initiated the scoping process with the 14 issuance of the Federal Register Notice. The NRC invited the applicant; Federal, State, Native 15 American Tribal, and local government agencies; local organizations; and individuals to 16 participate in the scoping process by submitting written suggestions and comments no later 17 than November 28, 2005.

18 19 No comments were received during the scoping period.

20 Appendix C 1 2 3 4Chronology of NRC Staff Environmental Review Correspondence 5Related to National Institute of Standards and Technology's 6 Application for License Renewal for the 7 National Bureau of Standards Reactor 8

Appendix C C-1 Appendix C 1 2Chronology of NRC Staff Environmental Review Correspondence 3Related to National Institute of Standards and Technology's 4 Application for License Renewal for the 5 National Bureau of Standards Reactor 6 7 8 This appendix contains a chronological listing of correspondence between the U.S. Nuclear 9 Regulatory Commission (NRC) and the National Institute of Standards and Technology (NIST), 10 and other correspondence related to the NRC staff's environmental review, under Title 10 of the 11 Code of Federal Regulations (CFR) Part 51, of NIST's application for a renewed operating 12 license for the National Bureau of Standards Reactor (NBSR) on the NIST campus near 13 Gaithersburg, Maryland. All documents, with the exception of those containing proprietary 14 information, have been placed in the Commission's Public Document Room, at One White Flint 15 North, 11555 Rockville Pike (first floor), Rockville, Maryland, and are available electronically 16 from the Public Electronic Reading Room found on the Internet at the following web address:

17 http://www.nrc.gov/reading-rm.html. From this site, the public can gain access to the NRC's 18 Agencywide Documents Access and Management Syst em (ADAMS), which provides text and 19 image files of NRC's public documents in the Pub licly Available Records component of ADAMS.

20 The ADAMS accession numbers or Federal Register citation for each document are included 21 below.22 23April 9, 2004Letter from the National Institute of Standards and Technology (NIST) 24 to NRC, regarding license renewal application for the National Bureau 25 of Standards Reactor (NBSR) (Accession No. ML041120167), and 26 Environmental Report (ML041120176).

27 28September 2, 2004Letter from NRC to S. Weiss, NIST, regarding determination of 29 acceptability and sufficiency for docketing, proposed review schedule, 30 and opportunity for a hearing regarding the application from NIST for 31 the NBSR. (Accession No. ML041390017) 32 33September 21, 2004NRC Federal Register Notice: National Institute of Standards and 34 Technology, National Bureau of Standards (NIST); Notice of 35 acceptance for docketing of the application and Notice of opportunity 36 for hearing regarding renewal of the National Bureau of Standards 37 reactor (NBSR) facility operating license No. TR-5 for an additional 38 20-year period. (69 FR 56462) 39 40 Appendix C C-2September 23, 2005Letter from NRC to S. Weiss, NIST, transmitting notice of intent to 1 prepare an environmental impact statement and conduct scoping.

2 (Accession No. ML052660195) 3 4September 29, 2005NRC Federal Register Notice: National Institute of Standards and 5 Technology, National Bureau of Standards Reactor; Notice of Intent to 6 Prepare an Environmental Impact Statement and Conduct Scoping 7 Process. (70 FR 56935) 8 9February 17, 2006Letter from NRC to W. Richards, NIST, regarding issuance of 10 environmental scoping summary report associated with the staff's 11 review of the application by the National Institute of Standards and 12 Technology for renewal of the operating license for the National 13 Bureau of Standards Reactor. (Accession No. ML032731680) 14 15February 13, 2007Letter from NRC to W. Richards, NIST, regarding summary of site 16 audit to support the license renewal review for the NBSR at NIST.

17 (Accession No. ML070370061) 18 19April 3, 2007Letter from NRC to Fish and Wildlife Service regarding consultation for 20 protected species.(Accession No. ML07050245) 21 22 Appendix D Organizations Contacted D-1 Appendix D 1 2 Organizations Contacted 3 4 5 During the course of the staff's independent analysis of environmental impacts from operations 6 during the renewal term, the following Federal, State, regional, and local agencies were 7 contacted:

8 9 Maryland Department of Natural Resources, Annapolis, Maryland 10 11 Maryland Historical Trust, Crownsville, Maryland 12 13 U.S. Fish and Wildlife Service, Annapolis, Maryland 14