Text

Summary of 970813 Meeting W/Duke Energy in Rockville,Md Re Preliminary Comments on Oconee Environ Rept Examples Provided at 970626 Meeting.List of Participants & List of Staff Comments Encl
	ML15217A172
Person / Time
Site:	Oconee
Issue date:	09/10/1997
From:	Craig C; NRC (Affiliation Not Assigned)
To:	Matthews D; NRC (Affiliation Not Assigned)
References
	NUDOCS 9709170346
	Download: ML15217A172 (22)
	v • d • e

A UNITED STATES 0

NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 September 10, 1997 MEMORANDUM TO: David B..Matthews, Chief Generic Issues and Environmental Projects Branch Division of Reactor Program Management Office of Nuclear Reactor Regulation FROM:

Claudia M. Craig, Senior Project Manager (jgtjO V

Generic Issues and Environmental Projects Branch Division of Reactor Program Management Office of Nuclear Reactor Regulation

SUBJECT:

SUMMARY

OF MEETING WITH DUKE ENERGY TO DISCUSS THE ENVIRONMENTAL REPORT (ER) FOR LICENSE RENEWAL The subject meeting was held at the Nuclear Regulatory Commission (NRC) offices in Rockville, Maryland on August 13, 1997, between representatives of Duke Energy (Duke) and the NRC staff. The purpose of the meeting was for the NRC staff to provide preliminary comments on the Oconee ER examples provided at the June 26, 1997, meeting. Attachment 1 is a list of meeting participants. Attachment 2 is a list of staff comments that are summarized below.

The staff reviewed the following ER examples: severe accident mitigation alternatives (SAMAs), groundwater use conflicts, microbiological organisms, electric shock from induced currents, environmental justice (EJ),,new and significant information, and alternatives to the proposed action. The staff comments on the examples were based on the information provided by Duke and the staff position as currently reflected in the draft regulatory guide (RG) and draft environmental standard review plan (ESRP). The staff's review was not performed for approval purposes, but for format and content, such that if Duke submitted an ER following the examples, it would have sufficient content to be accepted for review.

Several general comments were provided on the examples. The staff noted that the outline of the ER follows the issues as presented in 10 CFR Part 51.53(c)(3)(ii). The staff informed Duke the draft RG and draft ESRP follow the issues as presented in Table B-1 of 10 CFR Part 51.

The staff stated as long as all the Category 2 issues are addressed in the ER, the Duke format is acceptable. The staff also stated that if there are any Federal projects that might affect the plant, transmission line siting, or plant water supply, those should be mentioned in the ER.

In the ER examples, Duke stated that certain Category 2 issues were not applicable to Oconee and therefore, were considered Category 1 issues. The staff stated the category designation for issues is fixed in the rule and can not be changed without rulemaking. The staff suggested that if a Category 2 issue is not applicable to Oconee, the ER should include the basis for that conclusion and a statement that the environmental impact of the issue need not be assessed.

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September 10, 1997 The staff sought clarification on what was meant by the term "consideration of alternatives" and whether the term was equivalent to mitigative measures. Duke indicated that the terms were equivalent.

The staff asked general questions regarding the groundwater use conflicts example such as how often the groundwater quality was monitored, whether all the water used on site was from Lake Keowee, and whether that information would be found in the descriptive chapters of the ER (Chapters 2 and 3).

For the microbiological organism example, the staff asked for further clarification of what was meant by "based on Oconee experience" and did it entail testing, record review, and interaction with the health department. Duke indicated that the conclusions drawn in this section were based on discussions with the health department and those discussions indicated no microbiological organism problems had been identified. The staff also noted that some of the information needed to support the finding in this section would need to be described in the descriptive chapters of the ER (Chapters 2 and 3), including how large Lake Keowee is, the temperature of the discharge water, etc.

In the electric shock example, the staff stated that a description of the survey undertaken to demonstrate National Electric Safety Code (NESC) compliance should be included in the ER. If the survey was documented, that should also be referenced. Additionally, the staff asked for clarification on whether the 330 miles of transmission lines described in the original FES were the same lines on which the NESC survey was performed. Per 10 CFR Part 51, Duke is required to address the transmission lines that were originally constructed to connect the plant to the transmission system.

The staff indicated that Duke should use updated information in the EJ section of the ER.

There may have been additional housing developments built, or minority or low-income populations may now be located near the plant that were not addressed by the 1990 census data. The NMSS EJ procedure and the differences between an EJ review for siting a plant and an existing plant were discussed. The interim NRR procedure should be used as guidance.

The staff indicated EJ is an evolving issue because the final CEQ guidance has not yet be issued and the NRC guidance may change based on the final CEQ guidance. The staff also suggested Duke keep informed of activities regarding the LES court decision.

Duke indicated the section on new and significant information will be revised. Staff reiterated it believes that it would be beneficial for a potential applicant to have a process that would identify new and significant information that may impact the generic findings of the GEIS.

The Duke example regarding SAMA outlined the IPE/IPEEE process and the modifications made as a result of those efforts. The staff stated that an IPE/IPEEE review does not equal a SAMA review. The SAMA review is performed to evaluate potential improvements to preventive and mitigative capabilities. The staff stated that it would like to see more detail regarding the systematic process Duke used to identify leading contributors to dose consequence risk, specific plant modifications and procedural changes considered, the cost of each modification and procedural change, and the value-impact analysis consistent with the

D. Matthews 3

September 10, 1997 methodology in NUREG/BR-0184. The staff questioned the number of years of plant operation on which the 5 person-rem estimate is based. Duke stated the value is person-rem per year.

The staff noted that the example focused solely on core damage prevention. An evaluation of the potential improvements to mitigation capabilities should also be included for both internal and external events. This should address containment performance and failure modes, and potential accident management and containment design improvement. The staff stressed the methodology used to decide which improvements would be implemented and which would not is just as important in a SAMA review as the actual quantification of risk. Duke suggested the lessons learned from previous SAMA reviews be factored into ongoing reviews. Staff agreed and to some extent that is already being done. It was noted that although certain prevention and mitigation capabilities need to be considered, a lot of effort need not be spent on quantifying those capabilities that have been found to be impractical in other similar SAMA reviews. The bulk of the effort should be spent on a small number of SAMAs that may be able to meet the criteria and be implemented.

The staff indicated that it would be useful for Duke to include details in the alternatives section regarding the criteria used to select the alternatives included in the ER and dismiss other alternatives. Duke indicated it is very hard to predict energy needs for a time frame 15 to 25 years in the future. The staff agreed, however, NEPA only requires a consideration of the reasonable alternatives. Staff indicated that the alternative energy sources should be broken out separately from the no-action alternative, which Duke has done. Staff stated it is important that the ER and supporting documentation be clear as to the specific alternative technologies considered, or not considered, and why.

Attachments: As stated cc w/atts: See next page Docket Nos. 50-269, 50-270, 50-28

DUKE /NRC MEETING ENVIRONMENTAL REPORT FOR LICENSE RENEWAL AUGUST 13, 1997 MEETING PARTICIPANTS NAME ORGANIZATION Claudia Craig NRC/NRR/PGEB Kim Campbell NRC/NRR/PGEB Mike Case NRC/NRR/PGEB P.M. Abraham Duke-NGO-PRA Greg Robison Duke Energy Robert Gill Duke Energy Tom Yocum Duke Energy James M. Baughman, Jr.

Duke Energy Kathryn M. Sutton Winston & Strawn Jon Cudworth Halliburton NUS Bill Mackay Entergy-ANO Steve Hoffman NRC/NRR/PDLR Chris Grimes NRC/NRR/PDLR Bob Palla NRC /NRR/SCSB Catherine Marco NRC/OGC Don Cleary NRC/RES/DRA Jim Wilson NRC/NRR/PGEB D.B. Matthews NRC/NRR/PGEB

Duke-Oconee Environmental Report Comments Table of Contents Make sure all individual Category 2 issues are addressed. Although the draft RG follows the listing of Category 2 issues in Table B-1, it is acceptable for an ER to follow the sequence of issues from Part 51.53 (c)(3)(ii).

Table of Contents does not indicate if Duke intends to include a list of Federal Project activities that might affect plant, transmission line siting, or plant water supply. This information is needed to assess the interrelationships between the Federal and plant refurbishment activities and potentially cumulative environmental effects. It will also be listed in the NRC EIS.

5.4 Groundwater Use Conflicts General Comment for all examples: Duke need not change Category 2 issues from the rule to Category 1 issues for Oconee. The category designations are fixed in the rule.

Duke should simply provide basis for conclusion that the issues do not apply to Oconee and therefore need not be assessed.

"Analysis of Environmental Impact" nor "Consideration of Alternatives" is not an appropriate heading for discussion of an issue that is not applicable.

If the issues are treated in 51.53 (c)(3)(ii) (A)-(M) as they are now, it would seem appropriate to have one format for issues that are not applicable to Oconee and another for issues that are.

Information in the Background Section should be limited to material that is relevant to Oconee.

Section 5.4.4 - do alternatives equate to mitigation measures?

How often is groundwater quality monitoring performed?

5.8 Microbiological Organisms Section 5.8.3 - "based on Oconee experience" - what does this mean - was a test done on the receiving waters? Was there a review of any records associated with water borne disease outbreaks in the region as per draft ESRP 5.3.4-4? If so, note the fact.

Needs more supporting information. For ex.: How big is Lake Keowee? How close to the thermal discharge outfall are the nearest private boat docks or piers? Are there any low or minority populations living along the lake? If so, how close to the outfall are they?

What is the temperature of the discharge water? Would this temperature an increase in encourage organisms? Is this information in Chapter 2/3?

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5.9 Electric Shock from Induced Currents The FES is based on 330 miles of transmission lines - is this the same length surveyed?

Provide a brief description of the survey undertaken to demonstrate that all of the transmission lines that are attributable to Oconee meet the requirements of the 1997 Edition of the NESC. Was the survey documented? If so, the report should be referenced.

Last paragraph of 5.9.3 and 5.9.4 - Category 2 issues should not be changed to Category 1. See above.

5.13 SAMA An IPE/IPEEE review does not equal a SAMA review Discussion should include a breakdown of where the risk (person-rem) comes from, by sequence and containment failure mode/release class.

The number of years of plant operation on which the 5 person-rem estimate is based should be clarified.

The scope of the submittal is limited to core damage prevention. An evaluation of potential improvements to mitigation capabilities is needed, for both internal and external events. This should address containment performance and failure modes, and potential accident management and containment design improvement.

Potential design improvements identified from IPE and IPEEE should be presented, and the dispositioning of these improvements should be discussed, preferably from a value/impact viewpoint.

In 5.13.2 the first sentence should be consistent with part 51.53 (3) (c)(ii) (L) to read, "Consequently, severe accident mitigation alternatives will be reviewed if the NRC staff has not previously considered such alternatives for the applicant's plant in an environmental impact statement or related supplement or in an environmental assessment."

Need better discussion/organization that systematically explains leading contributors to dose consequence risk, specific plant modifications and procedural changes considered, the cost of each modification and procedural change, and a value-impact analysis consistent with the methodology in NUREG/BR -0184.

The dose consequence risk from each of the leading contributors from either the IPE (with and without interdiction) or the IPEEE (although the dose consequence risk was grouped for all the leading contributors from each evaluation).

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The cost of each modification and procedural change found to include the dose consequence risk of severe accidents should be discussed.

The value impact analysis to identify any plant modifications and procedural changes that may be cost effective should be included.

6 Environmental Justice If available, provide updated information from last census. Since 1990 census there may have been changes in the area.

Need to demonstrate why no impacts disproportionately affecting minority and low income populations is anticipated. Are there minority or low-in-come populations closer to Oconee than 10 miles? (Could use NRR Guidance on EJ as reference) If so, explain why refurbishment and continued operation will not adversely affect them. Explain why such populations in Clemson and Seneca Town will not be adversely affected.

Suggest that the last paragraph of introduction needs a concluding line statement similar to "Scoping did not identify any minority or low-income residents having special vulnerabilities due to customs, activities, location, or dependence on particular resources."

In Section 6.1, how does income in Oconee and Pickens counties compare with the State average? Income in long Creek is the lowest in Oconee County - discussion needed Last paragraph of Section 6.2 needs a bottom line that relates to the low income populations. It would probably help to say that there are no known environmental or socioeconomic pathways by which low-income and minority residents of Long Creek, Clemson and Seneca town would be disproportionately and adversely affected by renewal of the Oconee operation license.

Keep informed of ongoing LES decision 7 New and Significant Information Statement in box is incorrect - Duke is not required to describe a process by which the requirement will be satisfied. Staff believes it would be beneficial for a licensee to have a process.

New and significant clause was put in 10 CFR Part 51 so that if any of the Category 1 conclusions of the GEIS are no longer applicable to a plant - the plant would identify that in the ER and assess the environmental impacts.

Does Duke plan to incorporate by reference or adopt by reference the conclusions in the GEIS?

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Clarify that the ELQST charge covers the full scope of impacts in Table B-1 as well as identifying any impacts not considered in the rule.

More focus is needed on the details of how Duke Power and the ELQST assure that the emerging environmental issues are identified and given the appropriate priority, how environmental issues are addressed in an appropriate time frame, and how resources are appropriately assigned to environmental issues. Do they report new occurrences or monitoring results? The discussion needs to bridge the gap between management policy and technical implementation of the policy to be able to make the statement in the last paragraph with any credibility.

Duke should describe interaction with State and Federal agencies, academia, etc., that provides assurance that no changes have occurred.

8 Alternatives to the Proposed Action It is important that the ER and any supporting documentation be clear as to the specific alternative technologies and actions considered.

As discussed with BE - the alternative energy sources should be examined separate from the no-action alternative (CEQ comment on GEIS)

In Section 8.2, a discussion of why Duke believes the analyses in NUREG-1437 and NUREG-0586 are applicable to termination of operations and decommissioning of Oconee would be helpful to the review process. The discussion should identify the criteria used in evaluation the reasonable of alternative and explain which alternatives will not be considered further and why.

In Section 8.4.1, the first sentence, last paragraph. What does it mean by "at best"?

In the third sentence of the same paragraph, it is not clear what list is being referenced.

the last sentence "but, taxes transfer to the new site.." would imply that there is an offsetting benefit elsewhere.

Only feasible alternatives are coal and nuclear?

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September 10, 1997 D. Matthews 3

methodology in NUREG/BR-0184. The staff questioned the number of years of plant operation on which the 5 person-rem estimate is based. Duke stated the value is person-rem per year.

The staff noted that the example focused solely on core damage prevention. An evaluation of the potential improvements to mitigation capabilities should also be included for both internal and external events. This should address containment performance and failure modes, and potential accident management and containment design improvement. The staff stressed the methodology used to decide which improvements would be implemented and which would not is just as important in a SAMA review as the actual quantification of risk. Duke suggested the lessons learned from previous SAMA reviews be factored into ongoing reviews. Staff agreed and to some extent that is already being done. It was noted that although certain prevention and mitigation capabilities need to be considered, a lot of effort need not be spent on quantifying those capabilities that have been found to be impractical in other similar SAMA reviews. The bulk of the effort should be spent on a small number of SAMAs that may be able to meet the criteria and be implemented.

The staff indicated that it would be useful for Duke to include details in the alternatives section regarding the criteria used to select the alternatives included in the ER and dismiss other alternatives. Duke indicated it is very hard to predict energy needs for a time frame 15 to 25 years in the future. The staff agreed, however, NEPA only requires a consideration of the reasonable alternatives. Staff indicated that the alternative energy sources should be broken out separately from the no-action alternative, which Duke has done. Staff stated it is important that the ER and supporting documentation be clear as to the specific alternative technologies considered, or not considered, and why.

Attachments: As stated cc w/atts: See next page Docket Nos. 50-269, 50-270, 50-28 DOCUMENT NAME: 8_13_97.MIN DISTRIBUTION:

e attached page OFFICE PGEB PG PGEB:

NAME CCraig:

' MCasr Dpathe DATE I

/97 I

/97

/9 OFFICIAL RECORD COPY

Oconee Nuclear Station cc:

Mr. Paul R. Newton Mr. Ed Burchfield Duke Energy Corporation, PB05E Compliance 422 South Church Street Duke Energy Corporation Charlotte, North Carolina 28242 Oconee Nuclear Site P. 0. Box 1439 J. Michael McGarry, Ill, Esquire Seneca, South Carolina 29679 Winston and Strawn 1400 L Street, NW.

Ms. Karen E. Long Washington, DC 20005 Assistant Attorney General North Carolina Department of Mr. Robert B. Borsum Justice Framatome Technologies P. 0. Box 629 Suite 525 Raleigh, North Carolina 27602 1700 Rockville Pike Rockville, Maryland 20852 Mr. G. A. Copp Licensing - ECO50 Manager, LIS Duke Energy Corporation NUS Corporation 526 South Church Street 2650 McCormick Drive, 3rd Floor Charlotte, North Carolina 28242-0001 Clearwater, Florida 34619-1035 Mr. Richard M. Fry, Director Senior Resident Inspector Division of Radiation Protection U.S. Nuclear Regulatory Commission North Carolina Department of 7812B Rochester Highway Environment, Health, and Seneca, South Carolina 29672 Natural Resources 3825 Barrett Drive Regional Administrator, Region II Raleigh, North Carolina 27609-7721 U. S. Nuclear Regulatory Commission Atlanta Federal Center Mr. William R. McCollum 61 Forsyth Street, SW, Suite 23T85 Vice President, Oconee Site Atlanta, Georgia 30303 Duke Energy Corporation P. 0. Box 1439 Max Batavia, Chief Seneca, South Carolina 27679 Bureau of Radiological Health South Carolina Department of Health Mr. Robert Gill and Environmental Control Duke Energy Corporation 2600 Bull Street Oconee Site Columbia, South Carolina 29201 P. 0. Box 1439 Seneca, South Carolina 27679 County Supervisor of Oconee County Walhalla, South Carolina 29621 Mr. Doug Walters Nuclear Energy Institute 1776 I Street, NW Washington, DC 20006-3708

DISTRIBUTION wlatts: Summary of August 13, 1997, with Duke dated 9/10/97 PUBLIC DOCKET FILE PGEB R/F MCase CCraig E-Mail SCollins/FMiraglia RZimmerman HBerkow DLabarge CGrimes SHoffman DMatthews JWilson BZalcman DCleary LChandler, OGC JMoore, OGC CMarco, OGC BPalla JWilson IDLabarge

DISTRIBUTION wlatts: Summary of August 13, 1997, with Duke dated 9/10/97 Central File

,PUBLIC DOCKET FILE PGEB R/F MCase CCraig E-Mail SCollins/FMiraglia RZimmerman HBerkow DLabarge CGrimes SHoffman DMatthews JWilson BZalcman DCleary LChandler, OGC JMoore, OGC CMarco, OGC BPalla JWilson DLabarge

44.

UNITED STATES.

NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 September 10, 1997 MEMORANDUM TO: David B. Matthews, Chief Generic Issues and Environmental Projects Branch Division of Reactor Program Management Office of Nuclear Reactor Regulation FROM:

Claudia M. Craig, Senior Project ManagerC (J&

a Generic Issues and Environmental Projects Branch Division of Reactor Program Management Office of Nuclear Reactor Regulation

SUBJECT:

SUMMARY

OF MEETING WITH DUKE ENERGY TO DISCUSS THE ENVIRONMENTAL REPORT (ER) FOR LICENSE RENEWAL The subject meeting was held at the Nuclear Regulatory Commission (NRC) offices in Rockville, Maryland on August 13, 1997, between representatives of Duke Energy (Duke) and the NRC staff. The purpose of the meeting was for the NRC staff to provide preliminary comments on the Oconee ER examples provided at the June 26, 1997, meeting. Attachment 1 is a list of meeting participants. Attachment 2 is a list of staff comments that are summarized below.

The staff reviewed the following ER examples: severe accident mitigation alternatives (SAMAs), groundwater use conflicts, microbiological organisms, electric shock from induced currents, environmental justice (EJ), new and significant information, and alternatives to the proposed action. The staff comments on the examples were based on the information provided by Duke and the staff position as currently reflected in the draft regulatory guide (RG) and draft environmental standard review plan (ESRP). The staffs review was not performed for approval purposes, but for format and content, such that if Duke submitted an ER following the examples, it would have sufficient content to be accepted for review.