ML092870361
| ML092870361 | |
| Person / Time | |
|---|---|
| Site: | Indian Point  |
| Issue date: | 10/13/2009 |
| From: | Office of Nuclear Reactor Regulation |
| To: | Atomic Safety and Licensing Board Panel |
| DS07 | |
| Shared Package | |
| ML092870100 | List: |
| References | |
| 50-247-LR, 50-286-LR NUREG-1555, S1, R1 | |
| Download: ML092870361 (22) | |
Text
Indian Point Nuclear Generating Units 2 and 3 Docket Nos. 50-247/ 50-286-LR NRC Staff's Response in Opposition to State of New York's Motion for Partial Summary Disposition of NYS Contention 16116A Exhibit D
NUREG-1555, Supplement 1 Revision 1 Unircd Sratcs Nuclcar Regulatory Coml?lission Protecting People and the Environment Standard Review Plans for Environmental Reviews of Nuclear Power Plants Supplement 1: Operating License Renewal Draft Report for Comment Office of Nuclear Reactor Regulation
NUREG-1555, Supplement 1 c,Ltb* R E Q ~ .
U.S. NUCLEAR REGULATORY COMMISSION ENVIRONMENTAL STANDARD REVIEW PLAN OFFICE OF NUCLEAR REACTOR REGULATION 5.0 ENVIRONMENTAL IMPACTS OF POSTULATED ACCIDENTS I. AREAS OF REVIEW This environmental standard review plan (ESRP) provides guidance for the preparation of introductory paragraphs for the portion of the supplemental environmental impact statement (SEIS) that describes environ~nentalimpacts of postulated plant accidents during the license renewal term.
The scope of this plan is the development of paragraphs that introduce the material from the reviews conducted under ESRPs 5.1 and 5.2. It includes the description of the environmental issues associated with postulated accidents discussed in the Generic Env~ronmenlolIlnpcrcl Slaremeni (GE1S)jur License Rene~~crl nf~Vz,cleurPlrnls (NUREG- 1437, Volumes I and 2, Revision 1).
- 11. ACCEPTANCE CRITERIA The reviewer should ensure that the introductory paragraphs prepared under this ESRP are consistent with the intent of the followiilg regulations:
I0 CFR 5 1.53(c) concerning the content of environinental reports (ERs) and required analyses 10 CFR 5 1.70(b) concerning preparation of a draft environmental impact statement (DEIS) that is concise, clear, analytic, and written in plain language 10 CFR 5 1.71 concerning preparation of a DEIS at the license renewal stage 10 CFR 5 1.95(c) concerning preparation of a final environmental impact statement (EIS) at the license renewal stage July 2009 5.0- 1 NUREG- 1555, Supplement I , Revision l USNRC ENVIRONMENTAL STANDARD REVIEW PLAN Environmental standard revlew plans are prepared for the guldance of the Offlce of Nuclear Reactor Regulation staff responsible for environmental revlews for nuclear power plants. These documents are made available to the public as part of the Commission's pollcy to inform the nuclear industry and the general publlc of regulatory procedures and policies.
Environmental standard review plans are not substitutes for regulatory guldes or the Commission's regulations and compliance with them Is not requlred. These supplemental envlronmental standard revlew plans are keyed to Regulatory Gulde 4.2, Supplement 1, "Preparation of Envlronmental Reports for Nuclear Power Plant License Renewal Applicatlons. "
Published envlronmental standard revlew plans wlll be revlsed periodlcally, as approprlate, to accommodate comments and to reflect new informatlon and experience.
Comments and suggestions for Improvement wlll be consldered and should be sent to the U.S. Nuclear Regulatory Commlssion, Office of Nuclear Reactor Regulation, Washington, DC 20555-0001.
I0 CFR 5 1 , Subpart A, Appendix B, concerning Commission's findings on the scope and magnitude of environmental impacts renewing the operating license for a nuclear power plant.
Technical Rationale The technical rationale for evaluating the applicant's description of thc potential enviroi~mentaliinpacts of postulated accidents during the renewal term is discussed in the following paragraph:
The NRC staff is required by I0 CFR 51,95(c)(4) to integrate conclusions, as amplified by the supporting information in the GEIS, for issues that are designated as Category I or resolved Category 2, information devcloped for those open Category 2 issues applicable to the plant, and any significant new infor~llationin an EIS prepared at the license renewal stage. The review conducted under this ESRP leads to preparation of introductory paragraphs that orient the reader concerning the relevance of the material to the overall organization and goals of the SEIS and add clarity to the presentation.
111. REVIEW PROCEDURES The material to be prepared is informational in nature, and no specific analysis of data is required.
The environmental issue associated with operation during the renewal term that was considered in the GEIS and determined to be a Category 1 issue is listed in the following table:
Table B-1.--Summary of Findings on NEPA Issues for License Renewal of Nuclear Power Plants Issue Category Finding Postulated Accidents Design-hasis accidents I SMAI,L,. The NRC' staff has concluded that the environmental impacts of design-hasis accidents are of small significance for all plantb.
Generic co~~clusions relative to impacts were reached for those issues that are appropriate for all plants, or for some issues for specific classes of plants. These conclusions were that ( I ) a single Icvel of significance could be assigned to the impact and (2) plant-specific mitigation measures are not likely to be sufficiently beneficial to warrant implementation. The generic analysis of severe accidents analysis described in the GEIS applies to all plants. It concludes that the probability-weighted consequences of atmospheric releases, fallout onto open bodies of water, releases to groundwater, and societal and economic impacts of severe accidents are of small significance. In the absence of new and significant information, these issues may be addressed in the SEIS without additional plant-specific analysis.
E~~vironinental issues considered in the GEIS for which these conclusions could not be reached for all plants, or for specific classes of plants, are Category 2 issues. The Category 2 issue related to postulated accidents is listed in the following table:
NUREG- 1555, Supplement 1. Revision 1 5.0-2 July 2009
Table B-1.--Summary of Findings on NEPA Issues for License Renewal of Nuclear Power Plants Issue Category Finding Postulated Accidents Severe accidents 2 SMALL. The probability-weigllted consequences of atmospheric releases, fallout onto open bodies of water, releases to gri)undwater, and societal and economic impacts from scvere accidents are small for all plants. However, alternatives to mitigate severe accidents must be considered for all plants that have not considered such alternatives.
Not all plants have performed analyses of the measurcs that could mitigate the consequenccs of severe accidents. Consequently, alternatives to mitigatc severe accidents are a Category 2 issuc for plants that have not performcd a plant-specific evaluation of severe accident mitigation alternatives and submitted that c\.aluation to the Com~nissionfor review. A plant-specific analysis is required for this issuc.
If there is ncw and significant information related to the environmental impacts associated with postulated accidcnts identified by the applicant, members of thc public, or the staff, during the environme~ital review, the revicwcr for this ESRP should prepare a table that directs readers to the SEIS sections dealing with the issues.
IV. EVALUATION FINDINGS The reviewer of infonnation covered by this ESRP should prepare introductory paragraphs for the SEIS The paragraph(s) should introduce the nature of the material to be presented by the revicwers of information covered by ESRPiS I s 5. I, 5.1. I , and 5.2. The paragraph(s) should list the types of information to be presented and describe their relationships to information presented earlier and to be prescnted later in the SEIS.
V. IMPLEMENTATION The method described in this ESRP would be used by the staff in evaluating conformance with the Commission's regulations, except in those cases in whicli the applicant for license renewal proposes an acceptable alternative for complying with specified portions of the regulations.
VI. REFERENCE I0 CFR 5 1.53. "Postconstnlction environii~cntalreports."
10 CFR 5 1.70, "Draft environmental inipact statement-general."
I O CFR 5 1.7 1, "Draft eiivironinental inipact statement-contents."
I0 CFR 5 1.95,"Postconstruction enviro~lnieiitalimpact staten~ents."
I O CFR 5 1 Subpart A, Appendix B, "Environmental Effect of Renewing the Operating License of a Nuclear Power Plant."
July 2009 5.0-3 NUREG-1555, Supplement I . Revisioii 1
NUREG-1555, Supplement 1 U.S. NUCLEAR REGULATORY COMMISSION ENVIRONMENTAL STANDARD REVIEW PLAN OFFICE OF NUCLEAR REACTOR REGULATION 5.1 POSTULATED PLANT ACCIDENTS
- 1. AREAS OF REVIEW This environmental standard review plan (ESRP) provides guidance for the review of environmental impacts of postulated plant accidents during the licensc rcnewal term and preparation of input to the supple~llentalenviron~neiitalimpact state~neiit(SEIS). These issues are discussed in Chapter 5 of the Generic Ern~ironmenrnlhnpacf Slatement (GEIS),for Licen.se Kene~~rrl of Nz~clecrrI"1nnts (NUREG- 1437, Volumes I and 2, Revision 1).
The scope includes ( I ) review of the GEIS discussion of postulated accidents, (2) identification and evaluation of new information related to eiivironlnental impacts of postulated accidents during the renewal term for significance, (3) preparation of input to the SEIS that dispositions the Category 1 issues, and (4) preparation of input to the SEIS that introduces the discussion of the Category 2 issue.
Impacts of design basis accidents (DBAs) during the renewal term is a Category 1 issue. Severe accidents is listed as a Category 2 issue in the GEIS and Table B-l Appendix B, Subpart A to 10 CFR 5 1. The probability weighted consequences of atmospheric releases to groundwater and societal and economic impacts from severe accidents are small for all plants. However, alternatives to mitigate severe accidents must be considered for all plants that have not considered s ~ ~ alternatives.
ch A plant-specific review of alternatives to mitigate severe accidents is required by I0 CFR 5 1.53(c)(3)(ii)(L)if the NRC staff has not previo~~sly considered severe accident mitigation alternatibes for the applicant's plant in an environmental impact statement (EIS), SEIS, or environmental assessment. If a SAMA rcvicw has been conducted. then only new and significant information should be e\.aluatcd in accordance with ESRP 5.2.
July 2009 5.1-1 NUREG-I 555, Supplen~entI, Revisio~i1 USNRC ENVIRONMENTAL STANDARD REVIEW PLAN Environmental standard review plans are prepared for the guidance of the Office of Nuclear Reactor Regulation staff responsible for envlronmental reviews for nuclear power plants. These documents are made avallable to the public as part of the Commisslon's policy to inform the nuclear industry and the general public of regulatory procedures and policies.
Environmental standard review plans are not substitutes for regulatory guides or the Commlsslon's regulatlons and compliance with them is not required. These supplemental environmental standard review plans are keyed to Regulatory Gulde 4.2, Supplement I,"Preparation of Environmental Reports for Nuclear Power Plant Llcense Renewal Applications."
Publlshed environmental standard review plans will be revised perlodically, as approprlate, to accommodate comments and to reflect new information and experience.
Comments and suggestions for improvement will be consldered and should be sent to the U.S. Nuclear Regulatory Commission, Office of Nuclear Reactor Regulatlon, Washington, DC 20555-0001.
Data and Information Needs The types of data and information needed would be affected by nuclear power plant site- and plant-specific factors; the level of detail should be scaled according to the anticipated magnitude of the potential impacts. The following data or information may be needed:
a description of the applicant's process for identifying new and potentially significant information on environmental issues related to postulated accidents during the renewal term new informiti011 on environmental impacts of postulated plant accidents during the renewal term known to the applicant new and potentially significant information on environmental impacts of postulated plant accidents during the license renewal term identified by the public.
- 11. ACCEPTANCE CRITERIA Acceptance criteria for the evaluation of postulated plant accidents during the renewal term are bascd on the relevant requirements of the following regulations:
10 CFR 5 1,45(b) concerning environmental considerations in the applicant's ER I0 CFR 5 1.45(d) concerning discussion of co~npliancewith applicable environmental quality standards and requirements in the applicant's ER I0 CFR 5 1.53(c)(3)(ii) concerning analyses required in ERs submitted at the license renewal stage 10 CFR 5 1.70(b) conceniing an independent eval~~ation of the assessment and the reliability of information used in the assessment 10 CFR 5 1.71(d) concerning content requirements that apply to analyses in draft environmental impact statements (DEISs) at the license renewal stage I0 CFR 5 1.95(c)(4) concerning contents of SEIS and consideration of significant ncw information 10 CFR 5 1 Subpart A, Appendix B, conceniing findings on environ~nentalissues for license renewal of nuclear power plants.
Technical Rationale The technical rationale for evaluating the applicant's description of postulated plant accidents during the renewal term is discussed in the following paragraph:
NUREG- 1555, Supplement I , Rcvision I 5.1-2 July 2009
Thc NRC staff is required by I0 CFR 5 I .95(c)(4) to integrate conclusions, as a~npllfiedby the supporting information in the GEIS, for issues designated as Category I or resolved Category 2, information devcloped for those open Category 2 issues applicable to the plant, and any significant new information in an EIS prepared at the license renewal stage. The rebiew conducted under this ESRP leads to preparation of sections of the SElS that incorporate the conclusions from the GEIS related to postulated plant accidents during the renewal tenn, as appropriate, and address significant new information. if any.
111. REVIEW PROCEDURES Suggested steps for the review process are as follows:
( I ) Review thc discussion of the issue in the GEIS to identify the information considered and the concl~~sions reached. This step establishes the base for evaluation of information identified by the applicant, the public, and the staff. The following table lists the postulated plant accidents issue that was addressed in the GEIS for which generic conclusions were reached.
Table B-1.--Summary of Findings on NEPA Issues for License Renewal of Nuclear Power Plants Issue Category Finding Postulated Accidents Design-basis accidents 1 SMALL. The NRC' staff has concluded that the eavironniental impacts of design-basis accidents are of small significance for all plants.
Severe accidents 2 SMALL. The probability-weighted consequences of atmospher~c releases, fnllo~rtonto open bodies of water, releases to groundwater, and societal and economic irnpacts from severe accidents are small Ihr all plants. tIowever, alternatives to mitigate severe accidents must be considered for all plants that have not considered such alternatives.
(2) Determine if there is new information on this issue that should be evaluated. Tlle following sources of information should be included in the search for new information:
the applicant's ER. All applicant is required by I0 CFR 5 1.53(c)(3)(iv) to d~sclosenew and sign~ficantinformation of environmental impacts of license renewal of which it is aware. In reviewing the applicant's ER, consider the applicant's process for discovering new information related to environ~nentalimpacts of postulated accidents and evaluating the significance of any new infonilation discovered.
records of public meetings and correspondence related to the application. Coinpare information presented by the public with information considered in the GEIS.
cnvironmental standards and regulations. Have the applicable environmental quality standards and regulations changed since the analysis leading to the GEIS? If so, do the changes affect the NRC evaluation of applications for license renewal?
July 2009 3.1-3 NUREG-1555, Supplement 1 , Revision 1
If the search conducted in this step reveals new information, then continue with Step (3).
Otherwise, prepare the section for SEIS describing the search for new infol.riiation, stating the conclusion that there is nolie, and adopting conclusions frorn the GEIS.
(3) Evaluate the significance of new information.
If new inforination is significant, then contiuue with Steps (4) and (5) of the review. Otherwise, prepare a section for thc SEIS describing the search for new infonnation, summnrixing the new information foui~d,presenting results of the evaluation of significance, and adopting a concli~sioi~
from the GEIS.
(4) Prepare concise statement(s) of the issues raised by significant new information and providc these statements to the Environmental Prqject Manager (EPM) for review and disposition. The EPM should assign a reviewer for each issue and ensure that the issues are addressed in subsections of the SEIS.
(5) Prepare a section for the SEIS describing the search for new information, summari~ingthe new infonnation found, presenting the results of evaluation of significance, and adopting conclusions from thc GEIS modified as necessary to account for significant new information. Refer the reader to the appropriatc subsection(s) in the SEIS for detailed evaluation(s) of the significant new information.
IV. EVALUATlON FINDINGS The depth and extent of the input to the SEIS would be governed by the extent of the analysis required to reach a conclusion related to the environmental impacts of postulated accidents during the renewal term.
Tlle information that should be included in the SEIS is described in the review procedures.
V. IMPLEMENTATION The method describcd in this ESRP would be used by the staff in evaluating conformance with the Commission's regulations, except in those cases in which the applicant for license renewal proposes an acceptable alternative for complying with specified portions of the regulations.
V1. BIBLIOGRAPHY 10 CFR 50, "Domestic Licensing of Production and Utilization Facilities."
I0 CFR 5 1.45, "Environmental report."
10 CFR 5 1.53, "Postconsti-uction environmental reports."
I 0 CFR 5 1.70, "Draft environmental impact statement-gcncral."
NUREG- 1555, Supplement I , Revision 1 5.1-4 July 2009
I0 CFR 5 1.71, "Draft environmental impact statement-contents."
10 CFR 5 1.95, "Postconstruction environmental impact statements."
10 CFR 5 1 Subpart A, Appendix B, "Environmental Effect of Renewing the Operating License of a Nuclear Power Plant."
July 2009 5.1-5 NUREG- 1555, Supple~nent1 , Revision 1
NUREG-7555, Supplement 7 c,Lc~pR E ~ ~ t q , U.S. NUCLEAR REGULATORY COMMISSION ENVIRONMENTAL STANDARD
' ****+ '
REVIEW PLAN OFFICE OF NUCLEAR REACTOR REGULATION 5.2 SEVERE ACCIDENT MITIGATION ALTERNATIVES I. AREAS OF REVIEW This environmental standard review plan (ESRP) provides guidance for the analysis and assessment of the severe accident mitigation alternatives (SAMAs). This issue was identified as a Category 2 issue in the (ieneric En1~ironmcr7lnlSl~llemer~/ (GEIS),fi)rLicense Rcnclial oj'N~~clcllr Plnnl,~(NUREG- 1437, Volumes 1 and 2, Revision I ) , and in Table B- 1 of Appendix B, Subpart A to I0 CFR 5 1 . An applicant for license renewal is required by 10 CFR 5 1,53(~)(3)(ii)(L) to consider alternatives to mitigate severe accidcnts at the plant if the staff has not previously considered severe accident mitigation alternatives for the applicant's plant in an environmental impact statement (EIS) or related supplement or in an environmental assessment for the plant.
The scope includes an analysis of SAMAs and the preparation of m appropriate statement for the supplemental environmental impact statement (SEIS). The analysis of SAMAs includes the identification and evaluation of alternatives that reduce the radiological risk from a severe accident by preventing substantial core damage (i.e., preventing a severe accident) or by limiting releases from containment in the event that substantial core damage occi~rs(i.e., mitigating the impacts o f a severe accident). The purpose of the revicw is to ensure that plant and procedure changes with the potential for improved scvere accident safety performance are identified and evaluated.
July 2009 5.2- 1 NUREG-1555, Supple~nentI , Revision 1 USNRC ENVIRONMENTAL STANDARD REVIEW PLAN Environmental standard review plans are prepared for the guldance of the Offlce of Nuclear Reactor Regulation staff responsible for envlronmental reviews for nuclear power plants. These documents are made available to the public as part of the Commission's policy to inform the nuclear industry and the general public of regulatory procedures and policies.
Environmental standard revlew plans are not substitutes for regulatory guides or the Commission's regulations and compliance with them is not required. These supplemental environmental standard review plans are keyed to Regulatory Guide 4.2, Supplement 1, "Preparation of Envlronmental Reports for Nuclear Power Plant License Renewal Applications. "
Publlshed environmental standard review plans wlll be revised periodlcally, as approprlate, to accommodate comments and to reflect new information and experience.
Comments and suggestions for improvement will be considered and should be sent to the U.S. Nuclear Regulatory Commisslon, Office of Nuclear Reactor Regulation, Washington, DC 20555-0007.
Data and Information Needs Thc type of data and information needed \vould bc affccted by nuclear powcr plant s ~ t c and - plant-spccific factors. The following data or information should be oblaincd:
a list of leading contributors to (1) core-damage frequcncy (e.g., from dominant severe accidcnt sequences or initiating events), and (2) dose consequences (e.g., from each relcase class and associated source term) (from the enviro~lmentalreport [ER])
the methodology, process, and rationale used by the applicant to identify, screen, and select alternatives (from the ER) the estinlated cost, risk reduction, and dollar benefits for tlie selected SAMAs and the assumptions uscd to make these estimates (from the ER) a descriplion and list of any alternat~vesthat ha\ c been or would be implemented to rcduce thc risk of a severe accident, or that would be further evaluated by thc applicant for possible f u m e
~mplementation(from the ER).
- 11. ACCEPTANCE CRITERIA Acceptance criteria for the analysis and evaluation of SAMAs are based on the relevant requirements ol' the following regulations:
10 CFR 5 1.53(c)(3)(ii)(L)conccrning the necd to consider alternatives to mitigate sevcre acc~dcntsfor tlie applicant's pla~itif SAMAs were not previously considered I0 CFR 5 1.70(b) concerning permitting an independcnt cvaliration of tlie assessment and thc reliability of information used in the assessment 10 CFR 5 1, Subpart A, Appendix B. Table B- I , concerning the definition of the issue to be addressed.
Additional regulatory positions and spec~ficcriteria in support of the regulations identified above are as follows:
Interm Policy Statement, "Power Plants-Nuclear Power Plant Accident Considerat~onsunder NEPA" (NRC 1980) provides guidance co~icer~iing the early considerat1011of cither additional features or other actions that would prevent or mitigate the consequences of ser~ousaccidents.
"Policy Statement on Severe Reactor Accidents Regarding Future Designs and Existing Plants" (NRC 1985) provides guidance for dealing with severe accident issues and \ulncrabilities for operating reactors.
Policy Statement, "Safety Goals for the Operations of Nuclear Power Plants" (NRC 1986) provides safety goals for nuclear power plants.
NUREG-1 555, Supple~iientI . Revision I 5.2-2 July 2009
NUREGIBR-0 184, Regr11~7toq~ Hc~nU'hook(NRC 1997b) pro\ ides Ann(v.\is 7i'chnicciI F:~~aIz~nt~on guidance concerning the value impact methodology.
NUREGIBR-0058, Rev. 4, Reguler~oiyAnalyvi.~Chiicle1ine.r ofthe I1.S. Nzrcletrr Regrrlirto17.
I'ommi.~.rior~ (NRC 2004) states the policy for thc prcparation and the contents of regulatory analyses, including estimation of ~raluesand impacts for alternatives and the "dollars per person-rcm" conversion factors.
NUREGICR-6349 (Mubayi et al. 1995) provides infonnatio~lon dollars per person-rem conversion factor for offsite damage costs.
Generic Letter 88-20 (NRC 1988) provides guidance on the performance of an IPE at operating plants for severe accident vulnerabilities.
Generic Letter 88-20, Supplement 3 (NRC l99Oa) provides guidance on accident prevention and mitigation features identified in the Containincnt Perfor~nanceImpro\leme~~t Program that may be valid for consideration in the review of SAMAs.
Generic Letter 88-20, Supplement 4 (NRC 199 1) provides guidancc on conducting an individual plant examination for externally initiated events.
Regulatory Guide 4.2, Supplement 1, Revision I , Pref)aration c ~ f E n ~ ~ i r o n m eReport.v,fi~r n~c~I Nzrclear P o ~ - cPlant r License Renewal application,^ provides guidance on preparation of ERs associated with license renewal.
Regulatory Guides 1.174 (NRC 2002b) and 1.200 (NRC 2007) provides guidance on g e ~ ~ c r a l concepts in use and evaluation of probabilistic risk assessments for risk-informed decisions.
In addition to the above. the reviewer should be familiar with the ~ndustrySAMA analysis document that provides guidance on the SAMA analysis and describes the information that should be included in the SAMA portion of the ER.
The following acceptance criterion is used:
Completeness and reasonableness concerning ( I) the identification of SAMAs applicable to the plant under consideration, (2) the estimation of core damage frequency reduction and a1,erted person-rem for each SAMA. (3) the estimation of cost for each SAMA, (4) the screening critcria to identify SAMAs for hrther consideration. and (5) thc final disposition of promising SAMAs.
Technical Rationale The technical rationale for evaluati~lgthe appIicantls SAMAs is discussed in the following paragraphs:
The SEIS should include an analysis of the SAMAs for the applicant's plant if they have not previously been considered in an EIS or related s~ipplementor in an environmental assessment. The purpose of SAMAs is to review and evaluate plant design alternatives and procedural changes that could sig~lificantlyreduce the radiological risk from a severe accident by preventing substantial core July 2009 5.2-3 NUREG- 1555, Supplen~ent1 , Revision I
damage (i.e., preventing a severe accident) or by limiting releases from containment in the event that substantial core damage occurs (i.e., mitigating the impacts of a scvere accidcnt).
In 1980, the NRC published an interim policy statement (Interim Policy Statcment, "Nuclear Power Plant Accident Considerations Under the National Environme~italPolicy Act of 1969" [NRC 19801) that stated that it was the intent of the Commission for the staff to take steps to identify additional cases that might warrant early consideration of either additional features or other actions that would prevent or mitigate tlie consequences of serious accidents.
In 1985, the NRC published a policy statement ("Policy Statement on Severe Reactor Accidcnts Regarding Future Dcsigns and Existing Plants," August 9. 1985 [NRC 1985 1). It concluded that existing plants posed no undue risk to public health and safety and that there is no present basis for immediate aclion on generic rulcmaking or other regulatory changes for these plants becausc of severe-accident risk. However, the policy statement indicated that "the Co~n~nission plans to formulate an approach for a systematic safety examination of existing plants lo determine ~ f h c t h e r particular accident vulnerabilities are present and what cost-effective changes are desirable to ensure that therc is no undue risk to public health and safcty."
A 1989 court decision (Limerick Eco/o,g~Acfioil l l s . NRC', 869 F.2d 71 9 [3rd Cir. 19891 stated that the "Action of NRC in addressing SAMDAs (prior tei-m for SAMAs) through policy statemenls, not n ~ l e making, did not satisfy NEPA, where policy statements did no1 represent requisite careful considera-tion of environmental consequences, cxcluded consideration of design alternatives without making any conclusions about effectiveness of any particular alternative. and issues were not generic in that impact of SAMDAs on environment would differ with a particular plant's design, construction and locations." NRC considers the evaluation of SAMAs in the environmental impact review h a t is performed as part of every application for a license renewal if SAMAs have not been considered for the plant.
111. REVIEW PROCEDLTRES Suggested steps for conducting the review are as follows:
( I ) Detcrm~~ic if tlie staff previously considered SAMAs for the applicant's plan1 in an EIS or related supplement or in an environmental assessment. If not, then continue the analysis at Step (2).
Otherwise, preparc a statement for the SElS that describes the SAMA analysis and identifies the location of the analysis.
(2) Become familiar with analyses, the process, and design alternatives considcrcd in previous studies, including the following:
Li~ilerick(NRC 1989a).
Watts Bar (NRC 1995).
System 80+ (NRC 1 9 9 7 ~ ) .
NUREG- 1555, Supplement I , Revision 1 5.2-4 July 2009
ABWR (NRC 1997d).
NRC Containment Performance Iinprovemcnt Program (NRC 19X9b and l99Ob)
GEIS for License Renewal and plant-specific supplements.
(3) Evaluate the applicant's methods for establishing the risk profile for the plant, including the corc damage frequency, population dose risk, and offsite economic cost risk for both internal and external events. This review should consider the evolution and peer reviews of the Level 1 (core dainagc ficquency) and Level 2 (containment performance) PRA models, and the process uscd to extend thc analysis to an assessment of offsitc consequences. The scope of the review includes thc malor inputs to the MACCSZ offsite conscqucnce code (NRC 199X), including plant-specific inputs related to meteorology, population, evacuation, and economic impacts.
(4) Evaluate the applicant's methods for identifying the potential initigation alternatives. If the applicant used an alternative inethodology to a probabilistic risk asscssinent approach to assess potential SAMAs, for example, a margins-based approach to evaluate external events initiatcd by fires or seismic activity), the staff evaluation should be appropriately modificd. For cxan~ple,the synergistic effects of mitigation alternatives that reduce risks for internally initiated events that also provide a benefit for mitigation of externally initiated events should be considered. Alternative benelit-cost approaches are appropriate when a margins method has been used to scrcen cxterilal events.
(a) Determine if this set of potential alternatives represents a reasonable rangc of preventive and mitigati\>e alternatives.
(b) Verify that the applicant's list of potential SAMAs includes a reasonable range of applicable SAMAs derived froin consideration of previous analyses and based on insights from the Level I and Level 2 portions of the applicant's probabilistic risk assessment (PRA) or IPEIIPEEE.
(5) Evaluate the applicant's basis for estimating the dcgrec to which various alternatives would reducc r ~ s k(cxprcssed as a reduction in core-damage frequency or in t e m ~ of s person-rem avcned). NRC staff may make bounding assumptions or ad,justments to the applicant's analysis to dctcrm~nethe magn~tudeof thc potential risk reduction for each SAMA.
(5) Evaluate whether the applicant's cost estimates for each SAMA are reasonable, and compare the cost estimates with esti~natesdeveloped elsewhere (e.g., using previous SAMA evaluations or using accepted cost-estimation tools).
(7) Evaluate the cost-benefit comparison to determine if it is consistent with the cost-benefit balance criteria and methodology given in NUREGBR-0184 (NRC 1997b) and NUREGBR-0058, Rev. 4, (NRC 2004), and further analyze any SAMAs with estimated imple~nentationcosts within a factor of 2 to 5 of thc cstiinated dollar benefits to ensure that a sufficient margin is prcsent to account Tor uncertaintics in assilmptions used to detenninc thc cost and benefit estimates.
July 2009 5.2-5 NUREG- 1555, Supplement I , Revision 1
(8) Sub-iect any SAMAs that remain following the screening given above to further probabilistic and deterministic considerations, iiicludiiig a qualitative assessinent of the following:
the impact of additional benefits that could accrue for the SAMA if it would be effective in reducing risk from certain external events, as well as internal events the effects of improvements already made at the plant any operational disadvantage associated with the potential SAMA.
(9) Prepare a statement for the SEIS that describes the applicant's analysis and details the staffs review process. Any mitigation should be described along with the estimated costs and benefits. The risk reduction for the facility should be provided. The statement for the SEIS should identify and describe the mitigative measures considered and cominitted to by the applicant.
IV. EVALUATION FINDINGS The depth and extent of thc input to the SEIS would be governed by the extent of the analysis rcq~iiredto reach a conclusion related to the applicant's SAMA analysis. The infomatioil that should be included in the SEIS is describcd in the review procedures.
V. IMPLEMENTATION The method described in this ESRP would be used by the staff in evaluating conforn~ancewith the Commission's regulations, except in those cases in which the applicant for license renewal proposes an acceptable alternative for coinplying with specified portions of the regulations.
V1. BIBLIOGRAPHY 10 CFR 50, "Domestic Licensing of Production and Utilization Facilities."
10 CFR 50.34, "Contents of application; technical information."
10 CFR 5 1.53, "Postconstruction environmental reports."
I 0 CFR 3 I Subpart A, Appendix B, "Environmental Efl'ect ol'Renewing the Operating Licensc ol'a Nuclear Power Plant."
I0 CFR 5 1.70, "Draft envirolunental impact stateinelit-gcncral."
Limerick Ecology Action vs. NRC 869 F. 2D 7 19 [3rdCir. 19891 Mubayi, V., V. Sailor, and G. Anandalingam. 1995. C'osf-Ben@ C'onszdercilion.~in Keglilator?~Ancrlj~sh.
NUREGICR-6349, U.S. Nuclear Regulatory Commission, Washington, D.C.
Nuclear Eiiergy Institute (NEI). 2002. Severe Accident Mitigation Alternatives (SAMA) Analysis Guidance Document, NEI 05-01, Rev. A. Washington, D.C.
U.S. Nuclear Regulatory Com~nission(NRC). 1980. "Nuclear Power Plant Accident Considerations Under the National Environmental Policy Act of 1969." 45 FR 40 101, Washington, D.C.
NUREG- 1555, Supplement 1 , Revision 1 5.2-6 July 2009
U.S. Nuclear Regulatory Commission (NRC). 1985. "Policy Statement on Severe Reactor Accidents Regarding Future Designs and Existing Plants." 50 FR 32 138, Washington, D.C.
U.S. Nuclear Regulatory Commission (NRC). 1986. "Safety Goals Tor the Operations of Nuclcar Power Plants: Policy Statemcnt; Republication." 5 1 FR 30028, Washington, D.C.
U.S. Nuclear Regulatory Commission (NRC). 1088. Generic Letter 88-20," Individual Plant Examination Tor Severe Accident Vulnerabilities." November 23, 1988. Washington, D.C.
U.S. Nuclear Regulatory Conlmission (NRC). I989a. Letter from U.S. NRC to G. A. Hungcr, Jr.
Philadelphia Electric Company. Sub.ject: Supplement to the Final Environmental Statement-Limerick Generating Station, Units 1 and 2. Supplement to NUREG-0974.
U.S. Nuclear Regulatory Co~nmission(NRC). 1989b. "Mark 1 Containment Performance Improvement Program." SECY-89-017, Washington, D.C.
U.S. Nuclcar Regulatory Comnlission (NRC). 1990a. Generic Letter 88-20, Suppleinent 3, "Completion of Containment Performance Improvement Program and Forwarding Insights for Use in the Individual Plant Examination for Severe Accident Vulnerabilities." July 6, 1990, Washington, D.C.
U.S. Nuclear Regulatory Commission (NRC). 1990b. "Recommendations of Contai~ln~ent Perfornlancc I ~ n p r o v c ~ n Progranl c ~ ~ t for Plants with Mark 11, Mark 111, [ce Condenser, and Dry Containments." SECY-90-120, Washington, D.C.
U.S. Nuclear Regulatory Co~ninission(NRC). 1991. Generic Letter 88-20, Suppleme~lt4, "Individual Plant Examination of External Eve~its(IPEEE) for Severe Accident Vulnerabilities - 10 CFR 50.54(f)."
June 28, 199 I , Washington, D.C.
U.S. Nuclear Regulatory Commission (NRC). 1995. Final Envir.onmen/nl ,S/oremm/ Relcired lo /lie Opern~ionqf Wn//sBar. Nt~clenrPlnnl, IInils I nnd 2. NUREG-0498, Suppl. 1, Washington, D.C.
U.S. Nuclear Regulatory Commission (NRC). 2009. Generic Enl!ironmen/nl Iinpncl S/crtcmcn~ji,r I,icensc R c n e ~ ' nof / Nticlenr Plcrn/,s. NUREG- 1437, Vols. 1 and 2, Revision I . Washington, D.C.
U.S. Nuclear Regulatory Commission (NRC). 1997a. Indi~~ielual Plant Exnminat1oi7 Program:
Per.spec/ii~e.,on Renclor .Sc~fet.vnncl Plcr171Pel;fOrrnc/nce. NUREG- 1560, Washington, D.C.
U.S. Nuclear Regulatory Commission (NRC). I997b. Reg~ilcr~oyv Anah-sis 7i.chniccrl f!~vrl~~cr/ion Hnndhook. " NUREGiBR-0 184, Washington, D.C.
U.S. Nuclear Regulatory Commission (NRC). 1 9 9 7 ~ Finn1 . Environmcn~olAssessmcnr hj! /he Ofice o f N?iclear Renclor Reg1r1~71ion. " Relating to the Certification of the System 80+ Standard Nuclear Plant Design. NUREG- 1462, Washington, D.C.
U.S. Nuclear Regulatory Com~nissioll(NRC). 1997d. Finn1 Enl~ironmen~al A.sses.~men/by /he Qtfice uf Nr~cleurReaclor Regtllc71ion." Rclating to the Certification of the U.S. Advanced Boiling Water Reactor Dcsign. NUREG- 1503, Washington, D . C U.S. Nuclcar Regulatory Coininission (NRC). 1998. ('oele Mnnrm1,for MAC(S2, I l x r :s Gzlrde. "
NUREGiCR-66 13, Washington, D.C.
July 2009 5.2-7 NUREG- 1555, Suppleinent I , Revision 1
U.S. Nuclear Reg~~latory Commission (NRC). 2002a. Perspeclr~zs(;a~nedk'rom /he Individzial /'/on/
Exanrrnalion ofExlemcrl Elvents (IPEEE) Program. " NUREG- 1742, Washington, D.C.
U.S. Nuclear Regulatory Co~n~nission (NRC). 2002b. "An Approach for Using Probabilistic Risk Assesslnent in Risk-Informed Decisions on Plant-Specific Changes to the Licensing Basis." Regulatory Guide 1.173, Rev. I . Washington, D.C.
U.S. Nuclear Regulatory Commission (NRC ). 2004. Regzilatog~Analj'si,~(kiclel~nesoj'rhe l!S. Nuclear Reprluiory Commi.rsior7." NUREGIBR-0058, Rev. 4, Washington, D.C.
U.S. Nuclear Regulatory Comalission (NRC). 2007. "An Approach for Determining thc Technical Adequacy of Probabilistic Risk Assessment Results for Risk-Informed Decisions 011 Plant-Specific Changcs to the Licensing Basis." Regulatory Guide 1.200, Rev. I . Washington, D.C.
NUREG- 1555, Supplclnent I , Rcvision 1 4.2-8 July 2009
NUREG-7555, Supplement 7 U.S. NUCLEAR REGULATORY COMMISSION ENVIRONMENTAL STANDARD REVIEW PLAN OFFICE OF NUCLEAR REACTOR REGULATION
5.3 REFERENCES
- 1. AREAS OF REVIEW This environmental standard review plan (ESRP) provides guidance for listing references in this chapter of the supplemental environmental impact stateinent (SEIS).
- 11. ACCEPTANCE CRITERIA Acceptance criteria for the preparation of the reference list are based on the relevant requirements of the following regulation:
10 CFR 5 1.70(b) concerning preparation of a draft environmental itnpact statement (EIS) that is concise, clear, analytic, and written in plain language.
111. REVIEW PROCEDURES The reviewcr should contact reviewers for ESRP/SI 5 . 0 through 5.2 and compile a list of references cited in die SEIS sections that the reviewers have prepared. The citations should be checked for compleleness and prepared for inclusion in the SEIS.
July 2009 5.3-1 NUREG-1 5 5 5 , Supple~nenlI , Revision 1 USNRC ENVIRONMENTAL STANDARD REVIEW PLAN Environmental standard review plans are prepared for the guidance of the Office of Nuclear Reactor Regulation staff responsible for environmental reviews for nuclear powerplants. These documents are made available to the public as part of the Commission's policy to inform the nuclear industry and the general public of regulatory procedures and policies.
Environmental standard review plans are not substitutes for regulatory guides or the Commission's regulations and compliance with them is not required. These supplemental environmental standard review plans are keyed to Regulatory Guide 4.2, Supplement 1, "Preparation of Environmental Reports for Nuclear Power Plant License Renewal Applications."
Published environmental standard review plans will be revlsed perlodically, as appropriate, to accommodate comments and to reflect new information and experience.
Comments and suggestions for improvement will be considered and should be sent to the U.S.Nuclear Regulatory Commission, Office of Nuclear Reactor Regulation, Washington, DC 20555-0001.
IV. EVALUATION FINDINGS The reviewer of infonnation covered by this ESRP should prepare the SEIS section that lists references cited in the SEIS sections covering changes in the environmental impacts of postulated accidents during the license renewal term. The completed reference list constitutes the findings for this ESRP.
The method described in this ESRP would be used by the staff in evaluating conformance with the Commission's regulations, except in those cases in which the applicant for license renewal proposes an acceptable alternative for complying with specified portions of the regulations.
VI. BIBLIOGRAPHY 10 CFR 51.70, "Draft environinental impact statement-general."
U.S. Nuclear Regulatory Commission (NRC). 2000. Generic Ln~~ironmental Imnpucl .S'totement,fi~r Plants. NUREG- 1437, Voluines I and 2, Revision 1, Office of Nuclear Licc.n,ve R e n c ~ u c?j'Nl~clear l
Reactor Regulation, Washington, D.C.
NUREG- 1555, Supplement 1, Revision 1 5.3-2 July 2009