ML071690216

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03/21/2007, Summary of Meeting with Nuclear Energy Institute and Industry Representatives Regarding Environmental Report Content to Support License Renewal Application Reviews
ML071690216
Person / Time
Site: PROJ0690
Issue date: 07/09/2007
From: Jennifer Davis
NRC/NRR/ADRO/DLR/REBB
To:
Nuclear Energy Institute
Davis J, NRR/DLR/REBB, 415-3835
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Download: ML071690216 (10)


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July 9, 2007ORGANIZATION:Nuclear Energy Institute (NEI)

SUBJECT:

SUMMARY

OF MARCH 21, 2007 MEETING WITH NUCLEAR ENERGYINSTITUTE AND INDUSTRY REPRESENTATIVES TO DISCUSS ENVIRONMENTAL REPORT CONTENT TO SUPPORT LICENSE RENEWAL APPLICATION REVIEWSMembers of the U.S. Nuclear Regulatory Commission (NRC) staff hosted a meeting withrepresentatives of the Nuclear Energy Institute (NEI), license renewal applicants, and industry representatives and their contractors on March 21, 2007, at NRC Headquarters in Rockville, Maryland, to discuss the format and content of environmental reports submitted with applications for nuclear plant operating license renewal. A list of attendees is provided in . Copies of the meeting agenda and meeting handouts are provided in Enclosures 2 and 3, respectively. Bruce Boger, Associate Director for Operating Reactor Oversight and Licensing, Office ofNuclear Reactor Regulation, provided opening remarks. Mr. Boger highlighted the importance of applicants providing thorough environmental reports, focusing on the link between high-quality applications and an efficient and timely staff review. The staff presentations began with a general overview of the principal statutes affecting NRCenvironmental reviews. The purpose of this presentation was to highlight external influences on the NRC's environmental review process, including how changes in environmental protection regulations and other agencies' interpretations of environmental statutes can affect NRC's environmental reviews. The staff then made a series of presentations regarding specific review topics, including historicand archaeological resources, nonradiological waste and pollution prevention, and ecological resources. Each presentation included discussion of (1) the statutory and regulatory bases for NRC information requests; (2) specific regulatory requirements regarding application content; (3) information necessary for NRC staff to complete its environmental review; (4) useful resource materials for application preparation; (5) the advantages to applicants who engage relevant local, state, and Federal authorities and Native American tribes (e.g. State Historic Preservation Officer, U.S. Fish and Wildlife Service, etc.) early in the application process; and (6) suggestions of how applicants can provide support to NRC staff during environmental site audits to improve the efficiency of NRC staff reviews. Following each presentation, the staff engaged in dialog with industry participants on issuesrelated to the individual topic areas. During these discussions, the participants identified anumber of specific issues in need of further clarification. These issues included (1) assessing cultural resource protection during the current operating term versus during the renewal term; (2) information needed by the staff regarding storage and handling of mixed wastes; (3) cooling system intake "best technology available" determinations and their relationship to permits issued to facilities pursuant to several sections of the Clean Water Act; (4) evaluation of cumulative impacts, including such evaluation for a site with an active application for an earlysite permit or combined construction and operating license for a new nuclear unit; (5) how ISO 14000 programs may be considered in license renewal application reviews; and (6) how applicants should address the impacts of consumptive water use on riparian and aquatic systems. Resolution of these issues will be discussed in future meetings with NEI and industry representatives, as discussed below. During these discussions the NRC staff reiterated its position that the requested information isnecessary for the staff to satisfy its obligations under the National Environmental Policy Act of 1969, as amended, to describe the facility and its interactions with the environment. The staff indicated that, while much of the information can be obtained via site audits and/or requests for additional information, providing the information in environmental reports submitted with license renewal applications is expected to result in a more efficient and timely staff environmental review. NRC staff identified specific examples of thorough environmental reports, and described how coordination with related stakeholders provided benefit to applicants. Similarly, staff shared best practices and lessons learned from past license renewals, and referenced documents and contacts that an applicant may find beneficial when preparing environmental reports.Several industry representatives voiced concerns with the perception that the staff wasrequesting more information related to generically resolved Category 1 issues in recent license renewal reviews than has previously been the case. The staff indicated that some of these requests were made to be responsive to comments regarding the thoroughness of the staff's facility descriptions provided in previous environmental impact statements. The staff indicated that providing information in these areas supports the regulatory requirements related to describing the facility and its interactions with the environment and supports the staff's independent evaluation of whether any new and significant information exists for associated Category 1 issues. Industry representatives questioned whether this represented a change from past NRC reviews related to Category 1 issues. This was identified as another area where further dialog with industry would be beneficial.The meeting closed with the participants agreeing that a continuing dialog on the environmentalreview process would benefit both industry and the NRC staff. Several formats for this ongoing discussion were suggested, including participation by environmental counterparts in currently scheduled monthly conference calls and quarterly meetings with NEI on the license renewal process, as well as future workshops between industry and NRC environmental counterparts. It was agreed that NEI would coordinate with NRC staff regarding the appropriate venue for continued dialog. At a May 31, 2007, meeting with industry regarding the environmental review process, industryrepresentatives reiterated their concern regarding the perception that more information regarding Category 1 issues is being requested than in the past. The staff reiterated its position that the requested information is necessary to describe the facility, and that the information also supports the staff's independent evaluation regarding the applicability of thegeneric Category 1 conclusion to individual facilities. The meeting participants agreed that this issue will be a subject for further discussion in future meetings of staff and industry environmental counterparts. Prior to issuance, a draft version of this summary was reviewed by NEI./RA/Jennifer A. Davis, Project ManagerEnvironmental Branch B Division of License Renewal Office of Nuclear Reactor RegulationProject No. 690

Enclosures:

1. List of Attendees
2. Meeting Agenda
3. Meeting Handoutscc w/encls: See next page information also supports the staff's independent evaluation regarding the applicability of thegeneric Category 1 conclusion to individual facilities. The meeting participants agreed that this issue will be a subject for further discussion in future meetings of staff and industry environmental counterparts. Prior to issuance, a draft version of this summary was reviewed by NEI./RA/Jennifer A. Davis, Project ManagerEnvironmental Branch B Division of License Renewal Office of Nuclear Reactor RegulationProject No. 690

Enclosures:

1. List of Attendees
2. Meeting Agenda
3. Meeting Handoutscc w/encls: See next pageDISTRIBUTION: See next page Adam Accession Nos.: ML071690216OFFICEPM:DLR:REBBLA:DLRBC:DLR:REBBNAMEJ. DavisS. FigueroaR. Franovich (w/comment)DATE06/22/0706/20/0707/9/07OFFICIAL RECORD COPY Letter to Nuclear Energy Institute from Jennifer Davis Dated July 9, 2007DISTRIBUTION:

SUBJECT:

SUMMARY

OF MARCH 21, 2007 MEETING WITH NUCLEAR ENERGYINSTITUTE AND INDUSTRY REPRESENTATIVES TO DISCUSS ENVIRONMENTAL REPORT CONTENT TO SUPPORT LICENSE RENEWAL APPLICATION REVIEWSHARD COPY DLR RF E-MAIL:PUBLICSSmith (srs3)

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Nuclear Energy Institute Project No. 690

cc:Ms. Christine S. Salembier, CommissionerState Liaison Officer Department of Public Service 112 State St., Drawer 20 Montipelier, VT 05620-2601Mr. Gordon A. CleftonNuclear Energy Institute 1776 I St., N.W., Suite 400 Washington, DC 20006-3708Mr. Frederick W. PolaskiManager License Renewal Exelon Corporation 200 Exelon Way Kennett Square, PA 19348Mr. David LochbaumUnion of Concerned Scientists 1707 H St., NW, Suite 600 Washington, DC 20006-3919Mr. Clifford I. CusterProject Manager, License Renewal FirstEnergy Nuclear Operating Company P.O. Box 4 Route 168 (Mail Stop SIM-2)

Shippingport, PA 15077Mr. Paul Gunter, DirectorReactor Watchdog Project Nuclear Information & Resource Service 6930 Carroll Avenue, Suite 340 Takoma Park, MD 20912Mr. Hugh JacksonPublic Citizen's Critical Mass Energy &

Environment Program 215 Pennsylvania Ave., SE Washington, DC 20003Mary OlsonNuclear Information & Resource Service Southeast Office P.O. Box 7586 Asheville, NC 28802 Mr. Garry G. YoungManager, License Renewal Services 1448 SR 333, N-GSB-45 Russellville, AR 72802Robert A. VincentLicensing Lead - License Renewal Project Palisades Nuclear Plant 27780 Blue Star Memorial Highway Covert, MI 49043Lorrie Bell, Project ManagerWolf Creek Nuclear Operating Corporation P.O. Box 411 Burlington, KS 66839Roger StewartProgress Energy Carolinas, Inc.

3581 West Entrance Road RNP A9 Hartsville, SC 29550Michael H. Crowthers, Supervisor Nuclear Regulatory Affairs PPL Susquehanna, LLC Two North Ninth Street (GENPL4)

Allentown, PA 18101-1179 ENCLOSURE 1List of Attendees for March 21, 2007,Meeting of NEI, Industry, and NRC NAMEORGANIZATIONBruce BogerNuclear Regulatory Commission (NRC)Rani FranovichNRC Robert SchaafNRC Jennifer DavisNRC Harriet NashNRC Jessie MuirNRC Molly BarkmanNRC Eric BennerNRC Michael MasnikNRC Bo PhamNRC Alicia WilliamsonNRC Dennis LoganNRC Nathan GoodmanNRC Liz WexlerNRC Ekaterina LenningNRC Briana HarrisNRC Kendra KlumpNRC William KennedyNRC Tom AlexionNRC Butch BurtonNRC William SchusterNRC Laura QuinnNRC Jim RileyNuclear Energy Institute (NEI)

Henry DayAPS Palo Verde Gregory DeCampConstellation NAMEORGANIZATION-2-Rich GallagherDominionPaul AitkenDominion Abbas MostalaEnergy Northwest Joe FriscoEnergy Northwest Gary YoungEntergy Dara GrayEntergy Bob WestEntergy Rick BuckleyEntergy Chuck BarlowEntergy Alan CoxEntergy Mark GilesEntergy Fred PolaskiExelon Tom AbbatielloFPL Ken PutnamFPL Steve HaleFPL David KunsemillerFirst Energy Nuclear Operating Company (FENOC)

Mike BancoFENOC Cliff CosterFENOC Greg HalnonFENOC William VictorNebraska Public Power District (NPPD)

K. M. KrumlandNPPD James HolthausNuclear Management Company (NMC)

Gene EckholtNMC Terry GrabelPacific Gas & Electric Michael DetimorePPL Susquehanna Jerome FieldsPPL Susquehanna Jan KozyraProgress Energy Mike MacfarlaneSouthern Nuclear Company (SNC)

NAMEORGANIZATION-3-Dale FultonSNCTom MoorerSNC Chalmer MyerSNC Richard SchalleSTARS Alliance John SnooksAreva Massoud TafazzoliAreva Bill McCaugheyATL International (ATL)

Mark OrrATL Bobbie HurleyEarthTech Jim ThomasEnercon Jill BrochuLepson Consulting Alex PolonskyMorgan Lewis Mike HeathPGN Jim HolianSAIC Anne LovellTetraTech Jon CudworthTetraTech Deann RaleighUS Scientech Ashley Burtonself Mitch Holthausself ENCLOSURE 2AGENDA FOR NRC STAFF - INDUSTRY COUNTERPARTLICENSE RENEWAL ENVIRONMENTAL REPORT WORKSHOPWEDNESDAY, MARCH 21, 20078:00 a.m. to 12:00 p.m.I.Registration7:45 a.m. - 8:00 a.m.II.Welcome and Opening Remarks8:00 a.m. - 8:30 a.m.(NRC and NEI Staff)III.Environmental Statutes Overview8:30 a.m. - 9:00 a.m.(NRC Staff)IV.Topic Presentations & Discussions (NRC Staff & Industry)Historic and Archaeological Resources9:00 a.m. - 9:30 a.m.

Nonradiological Waste9:30 a.m. - 10:00 a.m.

Break10:00 a.m. - 10:15 a.m.

Ecological Resources10:15 a.m. - 11:00 a.m.V.Public Questions & Comments11:00 a.m. - 11: 40 a.m.

VI.Closing Remarks11:40 a.m. - 12:00 p.m.