ML19311C734
| ML19311C734 | |
| Person / Time | |
|---|---|
| Site: | San Onofre  |
| Issue date: | 09/23/2014 |
| From: | Public Watchdogs |
| To: | Division of Decommissioning, Uranium Recovery and Waste Programs |
| Cruz Z | |
| Shared Package | |
| ML19311C699 | List:
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| References | |
| Download: ML19311C734 (50) | |
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Appendix 0 operation of a spent fuel pool oran ISFSl is not uniquely linked to decommissioning. All operating nuclearpowver facilities have spent fuel pools and some (with the number anticipated to increase)have ISFSIs generallylocatedadjacent ornear to the power reactorfacility. The comment did not provide new informationrelevant to this Supplement and will not be evaluated. I further. The comment did not result in a change to the Supplement.
Comment: Our organizations have a fundamental dispute with the Commission's definition of I decommissioning. Decommissioning should not permit the release of radioactive contamination I from regulatory control and the control of some identified responsible party. At public meetings I (in 1993 and in 2001) 'across the country on the issue of "clean-up," the public consistently called for continued regulatory control over any and all wastes, materials, properties and sites with contamination from nuclear power and weapons fuel chain activities. Rather than requiring I the identification, capture and isolation of the remains of nuclear power operations, NRC is ,
legalizing'the release of contaminated sites, properties, materials and natural resources.. By segmenting the portions of the decommissioning process into separate Environmental Impact Statements and supplements, the public is prevented from addressing the amount and method I of identifying residual contamination of the environment, natural resources, the community and I downstream and downwind ecosystems. The public is prevented from addressing and preventing the concept of allowable doses to the public from nuclear power operation, wastes and decommissioning activities. We protest the designation of issues related to allowable contamination levels and doses being deemed "out of the scope" of this document. (CL-48/11) 1 Response: Various activities that are performed during decommissioning may seem intuitively I to be part of the decommissioningprocess. However, they are not considered within the scope I of this Supplement because these activities have alreadyreceived a thorough environmental review during the promulgationof the NRC regulationsgoverning such activities. They are reviewed and regulatedby the NRC under other regulations. The public has had the opportunity to comment on the regulationsand the environmentalassessment during the rulemaking process. The radiologicalcriteriafor license termination are given in 10 CFR Part 20, Subpart E, and further addressedin NUREG-1496, "GenericEnvironmentalImpact, Statement in Support of Rulemaking on RadiologicalCriteriafor License Termination of NRC Licensed Nuclear Facilities." For a site to be releasedas unrestricted,the total effective dose,- I equivalent to an average member of the criticalgroup is 0.25 mSv/yr (25mrem/yr). The NRC staff believes that these criteriaare adequate to protectpublic health andsafety. The comment I did not provide new information relevant to this Supplement and will not be evaluatedfurther. , I The comment did not result in a change to the Supplement.
¶ I Comment: CAN believes it is essential for NRC to continue to define decommissioning as a major federal action. As the Appellate Court opined"....., it is undisputed that decommissioning I is an action which, even under the Commission's new policy, requires NEPA compliance I 10 CFR 51.95(b.)" (CL-5014)
November 2002 0-251 NUREG-0586 Supplement 1
Appendix 0 I Response: Decommissioning of power reactorswas never considereda major Federalaction.
I The staff agrees with the commenter that NEPA compliance is required. The comment did not I provide new informationrelevant to this Supplement and will not be evaluatedfurther. The I comment did not result in a change to the Supplement.
I Comment: Exclusion of licensee decisions and actions prior to certification that plant I operations have permanently ceased means that the Supplement fails to consider factors that I may have negative impacts on the quality of the decommissioning activities and on minimization I of the quantity and condition of the wastes resultant from the handling and removal of I radioactive materials from plant structures, systems, and components. (CL-52/9)
I Response: 10 CFR 50.75(g)(1) requiresthat reactorlicensees maintain records of spills or I other unusual occurrencesinvolving the spreadof contaminationin or aroundthe facility, I equipment, or site during operations.. The staff chose to consider the environmental effect of I those actions or decisionsmade priorto certification of permanentcessation of operations I because those activities would be covered by the environmentalassessmentmade at the time I the facility was licensed to operate. Additionally, these records are availableand referred to I during decommissioning. The comment did not provide new information relevant to this I Supplement and will not be evaluatedfurther. The comment did not result in a change to the I Supplement.
I Comment: Exclusion from consideration of the fate of contaminants post-license termination I also renders this Supplement insufficient and not acceptable to account for the environmental I impacts of decommissioning. (CL-52/10)
I Response: Any potentialradiologicalimpacts following license termination that are relatedto I activitiesperformed during decommissioning are not consideredin this Supplement. Such I impacts are covered by the "GenericEnvironmentalImpact Statement in Support of I Rulemaking on RadiologicalCriteriafor License Termination of NRC-Licensed Nuclear I Facilities,"NUREG-1496. However, any potentialnon-radiologicalimpacts resulting from I decommissioning and occurringafter terminationof the license are consideredwithin the scope I of this Supplement. The comment did not provide new information relevant to this Supplement I and will not be evaluated further. The comment did not result in a change to the Supplement.
I 0.5.5 Definition and Discussion of SMALL, MODERATE and LARGE Impacts I Comment: As I understand your slides, they're not saying that all--that all sites, the water--the I water use and quality and air quality and ecology'are small. You're just saying the sites--those I issues that are dealt with in the generic sense-are small issues. And then, there can be site I specific issues that could be SMALL, MEDIUM or LARGE? (BO-A/6)
NUREG-0586 Supplement 1 0-252 November 2002
Appendix 0 Response: Section 4.1.2 of this GElS Supplement provides a definition of generic andsite specific. Foreach issue, a generic conclusion can be made if the potentialimpacts of all sites or subsets of sites are SMALL, MODERATE, or LARGE. Site-specific issues can be SMALL, MODERATE, or LARGE. The comment did not provide new information relevant to the GElS Supplement and will not be evaluated further. This comment did not result in a change to the Supplement.
Comment: Executive Summary, page xiv, line 20 - references 10 CFR 50.82(a)(6)(ii) which states that the licensee must not perform any decommissioning activity that causes any significant environmental impact not previously reviewed. The supplement at page 1-8 beginning on line 23 defines three levels of significance SMALL, MODERATE, and LARGE. At which of these significance levels does the requirement of 10 CFR 50.82 (a)(6)(ii) come into affect. This needs to be defined as several Environmental Issues, e.g. threatened and endangered species are listed as site-specific. (CL-05/3)
Response: -The definition of "significance"in 10 CFR 50.82(a)(6)(ii)is not related to the SMALL, MODERATE, and LARGE levels of significance used to evaluate impacts in the Supplement. The determination of significance for 10 CFR(a)(6)(ii)is basedon comparison of the potentialenvironmental impact of a specific activity with the bounds of impacts previously reviewed. If the impact of the activity is within the bounds of previously reviewed impacts, the activity may proceed as long as the other criteriaof 10 CFR 50.82(a)(6) are met. If the impact is not within the bounds, then the licensee may not undertake the activity without a license amendmenhtand environmentalreview. The SMALL, MODERATE, and LARGE significance levels refer to whether an impact is noticeable ornot and whether the impact will destabilize the impacted resource. The Executive Summary was revised.
Comment: After the explanation by the NRC staff at the public meeting in Atlanta, we further disagree with the process of using the significance levels of SMALL, MODERATE, and LARGE for a variety of issues at a variety of locations to come up with a generic, one-word answer.
The classifications are generic in form, hard to understand, and it is difficult to figure out how the NRC came to those characterizations even after NRC staff attempted to explain it at the public meeting in Atlanta. Ifthe NRC unwisely chooses to continue using this classification system, Georgians for Clean Energy urges that, ata minimum, layman's terms be used to define the levels and the methods used to categorize the issues. (CL-08/5)
Comment: The Supplement should distinguish better among certain of the small, moderate and large impact levels and better explain certain assumptions used in'setting these levels.
(CL-1 6/3) .
November 2002 0-253 NUREG-0586 Supplement 1
Appendix 0 I Comment: I am opposed to the following proposal(s) in the EIS: NRC sets arbitrary and I unsubstantiated (low, medium and high) environmental impact categories for each of the steps I in decommissioning, to give the appearance that they have minimal effects, to justify not fully I addressing them now and to prevent their inclusion in site-specific analysis. (CL-26112)
I Comment: ...the vague and arbitrary use of Small, Moderate, and Large significance levels and I the intent for use of these designations, which echoes previous attempted bogus designations I such as below regulatory concern; (CL-38/4)
I Comment: I am opposed to the following change to NUREG-0586: In Supplement 1 to the I Generic Environmental Impact Statement on Decommissioning: NRC sets arbitrary and I unsubstantiated (low, medium, and high) environmental impact categories for each of the steps I in decommissioning, to give the appearance that they have minimal effects, to justify not fully I addressing them now and to prevent their inclusion in site-specific analysis. (CL-43/10)
I Comment: NRC's "Levels of Significance and Accountability of Environmental Impacts" assign I values of risk to affected communities as "small," "moderate" and "large" as determinants for I the denial or approval of a public site-specific review and, potentially, a public adjudication for I environmental mitigation. Public Citizen maintains that these categories are excessively I arbitrary and broad, and largely groundless for the following reasons: 1. The biological effects I of ionizing radiation are destructive. No safe "threshold level" for exposure to ionizing radiation I exists for the general population (including the fetus). 2. There is a long history of unresolved I regulatory conflict over radiation protection standards that are utilized to determine NRC risk I assessments. Federal regulators, including the NRC and the Environmental Protection Agency, I have not reached a consensus on residual radiation criteria for decommissioning, with EPA I standards being significantly lower (more protective) than NRC criteria. To our knowledge, this I conflict has not been resolved and, therefore, it appears that the NRC has unilaterally and I arbitrarily concluded what standards would apply in determining whether a risk is "small,"
"I "moderate" or "large." 3. The NRC risk assessment inappropriately ignores the population of I children in its "critical group" evaluation as the population most vulnerable to residual I radioactivity exposure from decommissioning operations. This runs counter to NRC's I Organizational Value to a "Commitment ... to protecting the public health and safety." 4. The I NRC has a documented history of significant lapses in effective oversight of decommissioning I operations as reported by the General Accounting Office in a May 1989 report, "NRC's I Decommissioning Procedures and Criteria Need to be Strengthened" (GAO/RCED-89-119).
I The GAO not only found that complete information does not exist for all licensed activities or I buried wastes, but that NRC was found to have terminated a license with radioactive I contamination in excess of its own guidelines. Further, the report noted that NRC regulations NUREG-0586 Supplement 1 0-254 November 2002
Appendix 0 lacked a time requirement for document retention. NRC's questionable past performance does not support the agency's move toward generic treatment of decommissioning nuclear facilities where affected communities are denied public review and full disclosure of contamination, the decommissioning plan and license termination plan. (CL-47/13)
Comment: NRCs "Levels of Significance and Accountability of Environmental Impacts" assign values of risk to affected communities as "small," "moderate" and "large" as thresholds for denying or conducting a public site-specific review and potentially a public adjudication for, environmental mitigation.- Our organizations argue that these broad categories established by NRC are largely baseless for the following reasons: 1. The biological effects of radiation are deleterious. No safe threshold for radiation exposure for the general population (including the, developing fetus) has been established. 2. There is a long history of unresolved regulatory_ ,
conflict over radiation protection standards assumed to determine NRC risk assessments. Both federal and state agencies have sought to provide greater protection than NRC requires. 3.
The NRC risk assessment inappropriately ignores the population of children in its "critical group" evaluation as the population most vulnerable to residual radioactivity exposure from decommissioning operations. 4. There is a documented history of significant lapses in effective NRC oversight of decommissioning operations as reported by The General Accounting Off ice in I May 1989 'NRC's Decommissioning Procedures and Criteria Need to Be Strengthened" (GAO/RCED-89-119). The GAO not only found that complete information does not exist for all I licensed activities or buried wastes, but additionally that NRC was found to have terminated a license with contamination in excess of its guidelines and NRC regulations lacked a time ,r, requirement for document retention. NRC's checkered history does not provide justification for I the agency to move forward with generic treatment of decommissioning nuclear facilities where I affected communities are denied public review and full disclosure of contamination. (CL-48126) I Comment: NRC sets arbitrary and unsubstantiated (low, medium and high) environmental impact categories for each of the steps in decommissioning, to give the appearance that they I have minimal effects, to justify not fully addressing them now and to prevent their inclusion in site-specific analysis. (CL-48/45)
Comment: I would like to have you expand somewhat on your definition of "small," "moderate," I and "large" at this moment. (SF-CI1) I Comment: It seems a bit strange to me that the majority of the things are defined as "small."
With my experience with radiation I would not think that most of them would end up being small, I but that often comes down to a matter of scientific debate and opinions. (SF-C/2)
Comment: We disagree with the process-and it happened during the Hatch relicensing,I too-the process of using the significance levels of small, moderate and large for a variety of issues at a variety of locations, to come up with a generic one-word answer. The classifications I November 2002 0-255 NUREG-0586 Supplement 1
Appendix 0 I are generic in form, hard to understand and even though it's small, moderate and large which I sounds easy, I fundamentally have a hard time explaining that. (AT-N18)
I Comment: I also utterly oppose setting "low, medium, and high" environmental impact I categories for each of the steps in decommissioning, to give the appearance that some things I have negligible effects that don't warrant further consideration. (CL-33/16)
I Comment: I am opposed to NRC regulations pertaining to Decommissioning which would I allow NRC to set arbitrary and unsubstantiated (low, medium and high) environmental impact I categories for each of the steps in decommissioning, to give the appearance that they have I minimal effects, to justify not fully addressing them now, and to prevent their inclusion in site I specific analysis. This use of this piecemealing approach in unacceptable. (CL-44/10)
I Response: The SMALL, MODERATE, and LARGE significance levels provide a method of I describing the severity of impacts. These impact levels were establishedusing the Council on I Environmental Quality (CEQ) terminology for determiningsignificance (40 CFR 1508.27), which I requires considerationof both "cntext"and "intensity." Impacts that are of SMALL significance I are eithernot detectable or are so minor that they neitherdestabilize nor noticeably alterany I importantaspectof a resource. MODERATE impacts may noticeably alter an importantaspect I of a resource,but do not'destabilize the resource. And LARGE impacts are clearly noticeable I and destabilize importantasfiects of ,the resource. The discussionof decommissioning impacts I in Chapter4 was changed to more clearly relate the impacts in terms of detectability and effect I on resource stability.
I Comment: Page 1-8, Section 1.4. EPA encourages NRC wherever possible to make the I Levels of Significance (small, moderate and large) used in the Supplement more definitive by I including risk ranges, referencing the appropriate NRC regulations or providing examples of I impacts. We note that in several cases the qualitative analysis is given in units of person-rem I with no regulatory limit provided. (CL-16/15) 1 Response: The discussion of decommissioningimpacts in Chapter4 was changedwhere I needed to more clearly relate the impacts in terms of detectabilityand effect on resource I stability.
I Comment: NRC has absolutely no basis to say whether impacts will be small etc. based on I that sort of garbage. (CL-20/6)
I Response: Use of the levels of significanceof SMALL, MODERATE, or LARGE is recognized I as an acceptable andcommonly used approach to ascribea measure of significance to NUREG-0586 Supplement 1 0-256 November 2002
Appendix 0 decommissioningimpacts. These levels of significance are basedon CEO guidelines. The comment did not provide new information relevant to this Supplement and will not be evaluated further. The comment did not result in a change to the Supplement.
Comment: (4.1.1) Terms of Significance of Impacts The Nuclear Regulatory Commission employed a "standard of significance" developed by the Council of Environmental Quality (CEQ). Context means that the significance of an action must be analyzed in several contexts, such as a society as a whole (human, national), the affected region, the affected interests, and the locality. However, no "electric utility" constructs, operates, or decommissions a nuclear station without economics being the paramount consideration. Yet, the NRC and CEQ have created a nuclear Potamkin [sic] Village where economic imperatives are subordinated to the behavioral science flavor-of-the-day. In the NRC's world, an "electric utility" can apply for a loan I using NEPA as collateral., I hope that at the end of the GElS process, the Commission, can provide me with an address so that I can relocate my family to a neighborhood-without economic considerations., (CL-02/44)
Response: The comment can not be evaluated because it does not provide specific information. The comment did not provide new information relevant to this Supplement and Will I not be evaluatedfurther. The comment did not result in a change to the Supplement.
0.5.6 Time Frame for Assessing Environmental Impacts Comment: -It is not acceptable to give the option of using recent environmental assessments. I What is the definition of recent?...So I would like a definition of what is recent and if we're talking about endangered and threatened species, that list is going to change when a lot of these power plants actually go through decommissioning because species are being put on and I taken off those lists all the time. So what is recent? I would request-our organization requests that they always have a recent-a new, likethat year that they decide to decommission-an environmental assessment. (AT-A/23)
Comment: Georgians for Clean Energy requests that the NRC require licensees undergoing or I planning decommissioning to submit a new environmental assessment. We do not find it acceptable to give licensees the option of using "recent environmental assessments." (CL 0816)
Comment:- Page xv, Lines 37-38. The document identifies certain issues that are "site-specific I for activities occurring outside the disturbed areas in which there is no recent environmental - I assessment." "Recent" should be defined by, for example, specifying a time frame or "shelf life" I November 2002 0-257 NUREG-0586 Supplement 1
Appendix 0 I for environmental assessments, so that licensees have clear notice of when they must prepare I or update such a document for the disturbed area(s) in question. This same problem arises in I Table ES-1, which refers to "current" and "recent" ecological assessments. (CL-16/11)
I Response: The text was revised throughout the Supplement to provide clarificationand the I phrase "recentenvironmentalassessments"is no longer applicableor used.
I Comment: The time frame for assessing the magnitude of the environmental impacts is not I clearly discussed. In some instances (terrestrial ecology page 4-20, lines 39-41), the draft I acknowledges that some impacts will be temporary but once decommissioning is completed, I not significant. The discussion of other issues is silent with regards to when the impact is I assessed. For example, dewatering for a relatively short period while sub-surface foundations I are removed would be performed in accordance with a National Pollutant Discharge Elimination I System (NPDES) permit (section 4.3.2). However the impact on the water table during this I period of decommissioning would probably be noticeable. Once dewatering has ceased the I water table would most likely return to its pre-decommissioning level. The licensee would I reasonably conclude that dewatering during decommissioning is a SMALL (not noticeable, does I not de-stabilize any important attribute of the resource) impact once decommissioning has been I completed and is addressed in this GElS Supplement. The NRC should revise the GElS I Supplement to clarify that the magnitude of the impact should be assessed once I decommissioning activities have ceased and the license is terminated. (CL-01/2)
I Response: The commentor proposes that the NRC assess the magnitude of impacts only after I the decommissioning activities have been concluded and the license terminated. NEPA I requiresa Federalagency to considerin advance every significantaspect of the environmental I impact of the proposed action and to take a hardlook at the environmentalconsequences.
I Such considerationshould occur even if the impact is temporary and minor. Additionally, the I Federalagency is to evaluate the potential for mitigation of the impact. The staff believes that I the consequences of an activity needs to be evaluated at or close to the time that it occurs, I thereby complying with the intent of NEPA to provide full disclosure and also to allow for I mitigation. The comment did not provide new information relevant to this Supplement and will I not be evaluatedfurther. The comment did not result in a change to the Supplement.
1 0.5.7 Reactors Included in the GElS Analysis I Comment: You said you had visited a number of facilities. I wondered if you'd visited any in I New England, in particular, the Maine Yankee facility? So, you talked with some of the folks up I there (Maine Yankee facility) and got a sense of what was--what were the issues and so on?
I (BO-N4)
NUREG-0586 Supplement 1 0-258 November 2002
Appendix 0 Response: Maine Yankee was one of the reactors visited during the scoping and data collection process. The comment did not provide new information relevant to this Supplement and will not be evaluated further. The comment did not result in a change to the Supplement.
Comment: In Table J-2,'the location of Peach Bottom is incorrect., Peach Bottom resides in Delta, and is located less than a mile from Lancaster County and the State of Maryland.
In Table J-2, the location of Three Mile Island b'y county is incorrect. Three Mile Island resides',
in Londonderry Township, Dauphin County. "Northampton" County is located in Northeastern Pennsylvania. In addition, there are four counties located within five miles from Three Mile I Island, i.e. Cumberland, Lancaster, Lebanon, and York. (CL-02/67)
Response: Table J-2 was revised and Dauphin County is given as the county in which Three I Mile Island is located.
0.5.8 Application of NEPA Process to Decommissioning 1 Comment: I am opposed to the following chang e to NUREG-0586: In Supplement 1 to the Generic Environmental Impact Statement on De1commissioning: NRC prevents the National Environmental Policy Act from applying to most of the decommissioning process. (The claim I appears to be that this pro-iosed Supplement 1'satisfied the Environmental Policy Act for most I of the'decommissioning issues.) (CL-43/7) I Comment: The National Environmental Policy Act was written for a purpose, your proposed .I rules side step that' purpose. (CL-25/9)
Comment: I am opposed to the following proposal(s) in the EIS: NRC prevents the' National I Environmental Policy Act from applying to most of the decommissioning process. (CL-26/1 0) 1 Comment: I also utterly oppose preventing the National Environmental Policy Act from applying to most of the decommissioning process. .(CL-33/13)
Comment: NRC prevents the National Environmental Policy Act from applying to most of the I decommissioning process. (The claim appears tIo be that this proposed Supplement 1 satisfies' I the Environmental Policy Act for most of the decommissioning issues.) (CL-48/42)
Comment: But to the people in the affected communities, it is a problem and that problem is I one that they're going to have to live with after the NRC has-washed its hands of the site. So I we do have some real problems with the fragmbeiiation of the decision rnakinb process and the I publicparticipation opportunities, and believe'that indeed ihat there are NEPA violations. I (AT-B/7) I November 2002 0-259 NUREG-0586 Supplement 1
Appendix 0 I Response: NRC does not exclude the decommissioningprocess from the environmental I analysis expected underNEPA or the NRC's environmentalprotection regulations(10 CFR Part 1 51). The NEPA process allows for the development of programmaticand generic ElSs where a "I "hardlook" can be made for programs and issues that have common themes. Powerreactor I licensees cannotperform decommissioningactivities that could result in a significantimpact to I the human environment that was not previously reviewed. Those activitiesare reviewed in the I FinalEnvironmental Statement (FES) or Final EnvironmentalImpact Statement (FEIS) for I construction and operation, Supplements to the FES or FEIS, the GElS for license renewal, I site-specific supplements for license renewal, and the GElS for decommissioning. If any I decommissioning activity might result in significantenvironmentalimpacts and that activity is I not reviewed in one of these aforementioneddocuments, then the licensee must submit a I request for a license amendment. A license amendment requires that the licensee must submit I a Supplement to their environmentalreportand the staff conducts an environmental review on I the request. The comments did not provide new information relevant to this Supplement and I will not be evaluatedfurther. The comments did not result in a change to the Supplement.
I Comment: It is important to address NEPA and "psychological stress." The reality is that "I "psychological stress" exists, and will continue to exist. In fact, if the NRC had revisited the I issue of "psychological stress" and the TMI community, it would have found the following:...The I D.C. Circuit Court decided psychological (psych) stress does not need to be covered during the I restart hearings. However, the Court ruled, that under the National Environmental Policy Act I (NEPA), psych stress must be addressed. The Court ordered an injunction on restart until a I study on psych stress was conducted. However, on April 19, 1983, The U.S. Supreme Court I reversed the D.C. Circuit Court's opinion on psych stress and ruled an environmental study is I not necessary. Two months later, on May 5, 1983, GPU revealed for the first time to the NRC I that management audits, including psychological evaluations, concluded by BETA and RHR, I completed in February andMarch, 1983, were critical of plant operations and management.
I The NRC can hide behind NEPA or any other convenient acronym, but "psychological stress" is I a verifiable fact of life for people who live and work, in and around, nuclear power plants.
I (CL-02/43)
I Response: No activity has been initiatedto vacate the U.S. Supreme Court decision on this I matter. The comment did not provide new information relevant to this Supplement and will not I be evaluated further. The comment did not result in a change to the Supplement.
I Comment: The Appellate Court justices opined that your agency was in violation of its own I regulations and Rulemaking process in approving the experimental decommissioning at the I Rowe reactor without a decommissioning plan and an environmental assessment. In addition, I the court has ruled that decommissioning is a major federal action and requires NEPA I compliance. "An' agency can not skirt NEPA or other statutory commands by exempting a I licensee from compulsory compliance, and then simply labeling its decision "mere oversight" NUREG-0586 Supplement 1 0-260 November 2002
Appendix 0 rather than a major federal action. To do so is manifestly arbitrary and capricious." We believe NEPA compliance is mandatory for decommissioning. A Generic Environmental Impact Statement can not substitute for an individual EIS, as computer modeling can not substitute for actual testing. (CL-50/3)
Response: As stated in Chapter 1 of the Supplement, one reason the 1988 GElS was updated I was to further the purposes of NEPA. The Appellate court did not rule that decommissioning was a major Federalaction. Rather, the court ruled that the NRC had not followed its own - -
regulations in allowing the licensee of Yankee Rowe to remove major components priorto the I completion of the review of the Decommissioning Plan. The NRC revisited this issue as part of I a rulemaking involving the public, and has determined that decommissioningis not a major Federalaction. The comment did not provide new information relevant to this Supplement and I will not be evaluated further. The comment did not result in a change to the Supplement.
0.5.9 Opposition to Use of Generic Impacts, Comment: Existing nuclear power plants are not generically designed and, therefore, a generic program for decommissioning is completely inadequate to protect public health and safety. New and site-specific Environmental Impact Statements must be required to addressss how different power plants should be decommissioned (from the standpoint of historical operations, age-related degradation, salt water intrusion) in the safest manner possible for each I location. In the case of Diablo Canyon, new seismic information should be sought to assure the I public that the process would not increase the dangers of an already dangerously sited nuclear I plant. (CL-53/3)
Response: NRC staff recognizes that there is wide variabilityamong nuclearpower plants.
However, based on the results of our analysis, the impacts resulting from decommissioningare I similar regardlessof plant characteristics. The comment did not provide new information relevant to this Supplement and will not be evaluated further. The comment did not result in a I change to the Supplement. .
Comment: Generic things sound good, but each plant is different. I was originally thinking well, they are all kind of the same system, so it wouldn't matter, they are on the same principle, I but they're not. I mean, there are differences., (AT-D/3) I Response: The generic approachis used (1) when impacts of environmentalissues apply to all plants or a specific characteristicof that plant, (2) when a single significance level has been I assigned to the impacts, and (3) when mitigation of adverse impacts associatedwith the issue I have been consideredin the analysis, and it has been determined thatadditionalsite-specific I mitigation measures are not likely to be sufficiently beneficial to warrantimplementation. If an I
-November 2002 0-261 NUREG-0586 Supplement 1
Appendix 0 I environmental issue does not meet all three requirements,additionalsite-specific review is I required. The comment did not provide new information relevant to this Supplement and will I not be evaluatedfurther. The comment did not result in a change to the Supplement.
I Comment: Georgians for Clean Energy does not believe that a Generic Environmental Impact I Statement regarding decommissioning of nuclear facilities is a sufficient tool for evaluating I impacts borne to specific environments from decommissioning a nuclear power plant.
I (AT-A/1 7) 1 Comment: Again, we feel that a site-specific analysis must be done for each individual nuclear I plant. This includes the area of the site itself, along with downstream and downwind regions I and all areas within the ingestion radius of the facility. (AT-A/32)
I Comment: Georgians for Clean Energy does not believe that a generic environmental impact I statement (EIS) regarding decommissioning of nuclear facilities is a sufficient tool for evaluating I impacts borne to specific environments from decommissioning a nuclear power plant.
I (CL-08/4)
I Comment: I do not support any attempt of your agency to narrow the scope of site-specific I issues by declaring them to be generic. (CL-27/1)
I Comment: Some of my concerns about NUREG-0586 include:-the use of generic I proceedings to eliminate site-specific evaluation of concerns; (CL-38/2)
I Comment: Issues common to the process of decommissioning nuclear reactors should be I raised with every reactor being decommissioned, not excluded from every specific reactor being I decommissioned. These common issues have not been resolved. (CL-28/1)
I Response: The NRC has an obligation to implement effective regulatorypracticesthat involve I public participation. In this Supplement, the NRC establishedan envelope of environmental I impacts resultingfrom decommissioningactivities, identified those activities that can be I bounded by a generic evaluation, and identified those that require a site-specific analysis. The I NRC'concentratedthe environmental analysis on those activities with the greatestlikelihood of I having an environmentalimpact. Even for those impacts that have been determined to be I generic, a licensee is required to perform an assessment of environmental impacts from each I decommissioning activity to determine whether the impacts fall within the generic envelope I described in the Supplement. The comments did not provide new information relevant to this I Supplement and will not be evaluatedfurther. The comments did not result in a change to the I Supplement.
NUREG-0586 Supplement 1 0-262 November 2002
Appendix 0 Comment: We disagree with the NRC conclusion that most of the environmental issues they addressed are deemed as quote, generic and small for all plants, regardless of the activities and identified variables, end quote. (AT-A/19)
Response: The commenter did not provide a specific example or basis to demonstrate that the conclusions were not characterizedcorrectly. The comment did not provide new information relevant to this Supplement and will not be evaluated further. The comment did not result in a change to the Supplement.
Comment: And again, we feel that site-specific studies should be conducted. The economy of rural Georgia is much different from that of urban New York. (AT-A141)
Comment: Therefore, the safest alternative would be; first, to consider each reactor site individually rather than making a blanket policy to cover every site. (CL-1 0/6)
Comment: We again stress system need for site-specific EIS studies on decommissioning for nuclear power reactors. Our communities, from the people to the waterways, are unique and entitled to nothing less.' (AT-N45)
Comment: Georgians for Clean Energy firmly believes that a site-specific analysis must be done for each individual nuclear plant. This includes the area of the site itself along with downstream and downwind regions and all areas within the ingestion radius of the facility. ,As we mentioned at the public meeting in Atlanta, there are already elevated levels of some radioactive contaminants nearly 100 miles downstream of Georgia's Plant Hatch and Plant ':
Vogtle. (CL-08/17)
Comment: We again stress the need for site-specific Environmental Impact Statements on decommissioning for nuclear power reactors. Our communities -- from the pleople to the waterways-are unique and are entitled to nothing less. (CL-08135)
Comment: Furthermore, a "generic" EIS cannot provide adequate assurance that the unique situation and condition of each nuclear facility have been fully analyzed and accounted for.
Each-plant is unique; each plant's impacts must be examined in relationship with all 0ther nuclear facilities that affect the condition of the binvironment. In the real world environment,'
radioactive and hazardous materials are not necessarily static; they move; they interact with other materials; they accumulate; they may have their;Adverse impacts at or near their site of origin'or far'away from it. The totality of thos6eimpacts, upon both human and non-human inhabitants of the biosphere must be incorporated into an environmental analysis and accounted for fully also for adversely affected individuals in any cost-benefit analysis. All issues I should be examined at each plant. (CL-52/8) I November 2002 0-263 NUREG-0586 Supplement 1
Appendix 0 I Response: Site-specific analysis is requiredfor those situations where an environmental I review has not been conducted or where the impacts may be different from those previously I analyzed. NRC staff recognizes that there is wide variabilityamong nuclearpower plants.
I However, based on the results of the analyses presentedin the Supplement, many of the I impacts resultingfrom decommissioningare similarregardlessof plant characteristics. The I comments did not provide new informationrelevant to this Supplement and will not be I evaluated further. The comments did not result in a change to the Supplement.
I Comment: I oppose the use of "Generic" listing of issues. I support "Site Specific" listing so I that local communities can still raise issues they have. (CL-24/2)
I Comment: Many key issues that local communities face as reactors close and owners leave I (liability-free) will be unchallengeable, because they are being listed as "generic" issues.
I (CL-25/5)
I Comment: It is my understanding that the purpose, and certainly the effect, of the proposed I supplement to NUREG-0586 is to reclassify many decommissioning issues as "generic" in order I to avoid a community's right of challenge and to allow owners to depart without liability. I I understand that the NRC supplement seriously limits a community's ability to challenge even I those issues that are considered "site-specific." (CL-36/3)
I Comment: If the changes pass, many key issues that local communities face as reactors close I and owners leave (liability-free) will be unchallengeable, because they are being listed as "I "generic" issues. "Generic" decommissioning issues are ones that NRC determines apply to I numerous reactors and which are supposedly being resolved with this Supplement to the I Generic Environmental Impact Statement. "Site specific" issues are ones than can still be I raised in local communities, but the opportunities to address even site-specific issues is being I curtailed dramatically. I support the designation of environmental justice and endangered I species issues as site-specific (not generic). I oppose Rubblization but support its designation I as site-specific. (CL-43/15)
I Comment: I am opposed to NRC regulations pertaining to Decommissioning which would I allow NRC to make most aspects of decommissioning "generic" rather than site-specific so I NRC cannot be legally reviewed or challenged at individual sites. (CL-44/8)
I Comment: In establishing 80% (24 of 30) of the environmental impacts of decommissioning as I being "generic" the NRC is doing the industry's bidding to restrict or eliminate the affected I public's opportunities to comment on, guide, monitor and review the decommissioning of I nuclear power reactors in their communities. (CL-47/10)
NUREG-0586 Supplement 1 0-264 November 2002
Appendix 0 Comment: Regardless of any uniformity that may or may not exist as issues to consider at decommissioning reactors - and our position is*that any concerns of the relevant communities are site-specific - the NRC's move to make most considerations within the decommissioning process "generic" is a thinly veiled project to eliminate public review and full disclosure through public hearings. (CL-47/11)
Comment: NRC cleverly makes most aspects of decommissioning "generic" rather than site specific,,so they cannot be legally reviewed or challenged at individual sites. (CL-48143)
Comment: 'These events do not warrant nor should they instill public confidence in staff conclusions that the agency and the industry can reasonably make the leap to the generic treatment of environmental impact statements for decommissioning nuclear facilities and effectively take away a community's review and the full disclosure of the extent and location of radioactive contamination both on and off site.' (CL-48/6)
Comment: We have a fundamental dispute with'the NRC effort to eliminate public review and full disclosure through public hearings on decommissioning practices and mitigating environmental impacts based on arbitrary and capricious categories for determining "generic" and "site-specific" proceedings for nuclear power station decommissioning. (CL-48/25)
Comment: I think my concern is always to what extent a generic statement like this takes particular issues that are local out of the local decision-making process, out of the. public hearing that has to be had for-or we were originally led to believe has to be had for each of these. (AT-C/i)
Response: The NRC establishedan envelope of environmentalimpacts resulting from decommissioning activities, identified those activities that can be bounded by a generic evaluation, and identified those that requirea site-specificanalysis. The NRC concentratedthe environmental analysis on those activities with the greatest likelihood of having an environmentalimpact. Even for those impacts that have been determinedto be generic,a
.licensee is requiredto perform an assessment of environmental impacts from each decommissioningactivity to determine whether the impacts fall within the generic envelope.
The description of impacts as site-specific or generic does not preclude local communities from participating. The commenters are referred to the Executive Summary for a description of "generic"and "site-specific."
The public can raise issues using any of several methods. If the licensee has requested an action requiringa license amendment, then the process for interveningin this action is by requestingor participatingin a hearing. The process is set forth in NRC's regulationsin 10 CFR I Part2, "Rules of Practice of Domestic Licensing Proceedingsand Issuance of Orders." If the action of concern does not involve a license amendment, then any member of the public may
' November 2002 0-265 NUREG-0586 Supplement 1
Appendix 0 I raise potentialhealth and safety issues in a petition to the NRC to take specific enforcement I action againsta licensed facility. This provision is containedin the NRC's regulationsand is I often referredto as a "2.206petition"in reference to its location in the regulations(Chapter2, 1 Section 206 or 10 CFR). The comments did not provide new informationrelevant to this I Supplement and will not be evaluated further. The comments did not result in a change to the I Supplement.
I Comment: The above reasons illustrate the lack of a sound basis for staff conclusions that the I decommissioning alternatives of entombment and rubblization are a"minor" environment impact I and can be treated generically to avoid public review and full disclosure in formal public I hearings. We therefore adamantly oppose such generic treatment. (CL-48/35)
I Response: Entombment is the focus of a current NRC rulemaking that would provide further I guidance on this method of decommissioning a nuclearpower facility. If a licensee pursues the I ENTOMBMENT option, there will be activities necessary to ready the facility for the I entombment. The impacts from the activities to preparethe facility for Entombment are I consideredgeneric. A site-specific assessmentrequiredby a proposed restrictedrelease I would naturallyfocus on radiologicalissues.
I Rubblization is not consideredan option for decommissioning, but a potential activity of I decommissioning. The Supplement states that the radiologicalaspects of rubbilizationon I onsite disposalof slightly contaminatedmaterialwould be addressedin a site-specific manner I at the time that the LTP is submitted. The site-specific LTP will provide a mechanism for the I NRC staff's evaluation of the licensee's plans to dispose of rubblized concrete on site. The I radioactivematerialthat remains at the site after the license has been terminatedmust meet I the dose criteriafor license terminationgiven in 10 CFR Part20.
1 The comment did not provide new information relevant to this Supplement and will not be I evaluated further. The comment did not result in a change to the Supplement 1 0.6 General 1 0.6.1 Clarifications and Recommendations Related Specifically to Supplement 1 1 Comment: Second, we would like to see a place in the document where you're comparing the I risks, environmental risks associated with dismantling the facility immediately, versus storing I the material and keep putting the facility in safe store. It's referenced in the document that I there are higher risks, sometimes, of dismantling immediately because the material is more I radioactive. But it doesn't show a comparison of the risks associated with storing it versus I dismantling it in the short-term. (CH-A/13)
NUREG-0586 Supplement 1 0-266 November 2002
Appendix 0 Response: The Supplement provides generaladvantages and disadvantagesfor the various options for decommissioning. Both long-term storage followed by decontaminationand dismantlement and immediate decontaminationand dismantlement were found to be acceptableapproachesto decommissioning. The comment did not provide 'new information relevant to this Supplement and will not be evaluated further. The comment did not result in a change to the Supplement.
Comment: There are some aspects of the regulations that are specific to light water reactors and I just think the document needs to reflect those rather than all reactors. (CH-D/5)
Response: Section 4.3.11.1, "Regulations,"has been revised to reflect that the minimum amounts required to demonstratereasonableassuranceof funds for decommissioning found in 10 CFR 50.75(c) apply only to light water reactors. ,
Comment: Activities that require state or local'permits or approval should be considered to have a SMALL impact under the GELS. Licensees will be required to obtain approval from state and/or local agencies for several activities performed as a part of decommissioning and cite restoration. These activities'may include routine discharge or non-radiological liquids, dewatering, removal or modification of circulating water conduits, and use of portable combustion erngines. Typically, the regulations governing approval for these activities require that the'regulatory agency perform an assessment of the environmental impact(s) and, as appropriate, establish mitigating measures as permit conditions. In the case of water quality issues, the NRC relies on the licensee's compliance with the NPDES permit to conclude that the magnitude of the impact(s) is SMALL. The NRC should revise the GElS Supplement to clarify that the NRC will consider the impact of an activity to be SMALL and rely on the licensee's compliance with a state or local permit, including any mitigating conditions. (CL 01/3)
Response: The determinationof level of significance is specific to the evaluationof environ mental impacts from decommissioning, regardlessof State permits and approvals. The staff does not agree thatjust because the licensee has a State or localpermit that impact of the activity will always be SMALL.- NEPA requiresan evaluationbased on postulatedimpacts. The comment did not provide new information relevant to this Supplement and will not be evaluated further. The comment did not result in a change to'the Supplement.
Comment: The potential impacts of removing circulating water conduits on water quality or aquatic ecology are not consistently discussed or are considered an exception from the staff's conclusions. The Executive Summary states that the "removal of uncontaminated SSCs (such as the intake structure or cooling towers) that were required for the operation of the'reactor are included in the scope of the GELS. However, chapter 4 does not discuss th6 potential impacts' of removing circulating water conduits on water quality (section 4.3.3) and the staff considers November 2002 0-267 NUREG-0586 Supplement 1
Appendix 0 I removal of these structures to be an exception to the generic evaluation for aquatic ecology I (section 4.3.5). Similarly, the tables in Appendix H do not address this issue. Realistically, the I licensee will have to comply with state and/or local regulations to remove the circulating water I conduits or cooling towers. The state and/or local agency would perform an environmental I assessment and, as appropriate, establish conditions in the permit to mitigate any I environmental impact(s). As in the case of water quality issues, the NRC relies on the I licensee's compliance with the NPDES permit to conclude that the magnitude of the impact(s) is I SMALL. The NRC should revise the GElS Supplement to clarify that the NRC will rely on the I environmental assessment performed for and any mitigating conditions included as part of the I state or local permit for removal of circulating water conduits. (CL-01/5)
I Response: The consistency of the discussion and the tables in Section 4.3, "Environmental I Impacts from Nuclear PowerFacility Decommissioning,"of this Supplement have been I addressed. The staff recognizes that removal of circulation water conduits or cooling towers I will be conducted in accordancewith State and local requirements. However, the NRC staff I cannot reach a conclusion on the level of impact basedsolely on the presumedcompliance with I these requirements. Circulatingwater conduits and other SSCs that will be removed after I operation,however, are not expected to detectably change or destabilize the aquatic I environment. The staff conclude that the impact to the aquaticenvironment for these I decommissioning activities is SMALL andno furthermitigation would be required. The staff I conclusion is based on the short duration of most deconstructionactivities, the fact that the I impact is to a previously disturbed ecosystem, and the potential use of mitigative actions,such I as scheduling in-wateractivities duringperiods in which impacts to aquaticresourceswould be I minimal, as well as provided oversight from State and local agencies. The staff's conclusions I in this Supplement do not provide relief or exception from other laws and regulationsrelated to I any of the activities discussedin the Supplement. The staff relies on the licensee's compliance I with other agency regulations,such as the NPDES, as an indicatorof potentially causing I detectable or destabilizingchanges in the aquaticenvironment. Section 4.3, "Environmental I Impacts from NuclearPower FacilityDecommissioning," was revised to be consistent with the I above response.
I Comment: The GEIS's glossary superficially glosses over "Greenfield" and equates it with an I end state of decommissioning ..."According to NRC Regulations, Greenfield is achieved when a I nuclear generating station is returned to "original status" prior to licensing, construction, and I generation of nuclear power. The NRC would then clear the site for "free release" and allow a "I "school or playground" to be constructed at the former nuclear power plant. (CL-02/40)
I Response: The definition of Greenfield in Appendix M, "Glossay,"was revised to describe I Greenfield as one possible end state of decommissioningand that NRC regulationsdo not I require a greenfield end state.
NUREG-0586 Supplement 1 0-268 November 2002
Appendix 0 Comment: Appendix F Summary Table of Permanently Shutdown and Currently Operating Commercial Nuclear Reactors, PG. F-i, Table F-i -Permanently Shutdown Commercial Nuclear Plants (Total Site Area (ac.) For Maine Yankee: 741 (should be 820)). (CL-04/11)
Response: The revised area was included in Table F-1.
Comment: 3.3.3 Decommissioning Process pg. 3-29, 2nd full para. This paragraph is redundant to the preceding and seceding paragraphs and can be deleted in its entirety.
(CL-04/17)
Response: Section 3.3.3, "Summary of Plants that Have PermanentlyCeased Operations,"
was revised to remove redundancy.
Comment: Appendix A Draft Generic Environmental Impact Statement Scoping Summary Report: Comments in Scope pg. A-2, Written Comment Letters: George A. Zinke is listed as the "Director, Nuclear Safety & Regulatory Affairs, U.S. Environmental Protection Agency."
This reference should be revised to indicate; "Director, Nuclear Safety & Regulatory Affairs, Maine Yankee Atomic Power Co." (CL-04/19) :.
Response: Appendix A was renamed Appendix N and Mr. Zinke's correct title included.
Comment: Section 3.1.3, p 3 add "The systems described are typical and may differ at specific facilities." to end of the 1st paragraph. (CL-05/4),
Response: Section 3.1.3, "Descriptionof Systems," was revised and the above phraseadded' to the end of the first paragraph.
Comment: Section 3.1.3, p 3-10, 1st paragraph - add "or similar document" following
"(ODCM)",since limits may be in Technical Specifications ratherthan an ODCM. Also, the description of effluent systems should include mention of an evaporator, since some facilities use evaporation to convert liquid waste to gaseous and monitor their discharge. (CL-05/5).
Response: Section 3.1.3, "Descriptionof Systems," was revised and the above phrase was added. I Comment: Section 3.1.4, p 3-13, last paragraph - shipment of contaminated apparatus or hardware may also occur to support specific activities. (CL-05/6)
Comment: Section 3.1.3, p 3-13, last paragraph - Shipment of contaminated apparatus or I hardware may also'occur to support specific activities. (CL-09/11)
November 2002 0-269 NUREG-0586 Supplement 1
Appendix 0 I Response: Typically, contaminatedapparatusor hardwareare consideredroutinely generated I low-level waste (LLW) even if they were operatedto support specific decommissioning I activities. The comments did not provide new information relevant to this Supplement and will I not be evaluatedfurther. The comments did not result in a change to the Supplement.
I Comment: Section 3.1.3, p 3-14, 1st paragraph - shipment may also occur on barges or other I ships. (CL-0517)
I Response: Section 3.1.3, "Descriptionof Systems," was revised to include barges and other I ships.
I Comment: Section 3.2, p 3 the definition of SAFSTOR should more clearly define that it I includes the final decontamination of the facility. This would be more consistent with definitions I used elsewhere. (CL-05/9)
I Comment: Section 3.2, p 3-16, lines 18-24 -The definition of SAFSTOR should more clearly I define that it includes the final decontamination of the facility. This would be more consistent I with definitions used elsewhere, such as in the original GELS. (CL-09/13)
I Response: Section 3.2, "DecommissioningOptions," was revised to clearly state that final I decontaminationof the facility is part SAFSTOR.
I Comment: Section 4.3.4.4, page 4-16, 1st paragraph - add the following sentence to the end I of the paragraph: "Particulates produced by decommissioning activities within buildings will be I filtered as needed so that air quality impacts will be small." (CL-05/12)
I Response: The staff has chosen not to include the comment in section 4.3.4.4, "Conclusions".
I Section 4.3.4.3, "Evaluation,"does however addressfiltration systems to control the release of I particulatematerialto the environment. The comment did not provide new information relevant I to this supplement and will not be evaluated further. The comment did not result in a change to I the Supplement.
I Comment: Section 4.3.7, p 4-25, last paragraph - This conclusion indicates that the NRC will I meet its responsibilities on a site-specific basis during any decommissioning process, but it I does not specify how the NRC will meet its responsibilities or what information it will need from I licensees. (CL-05/16)
I Response: The responsibilitiesunder the EndangeredSpecies Act (ESA) will be met through I appropriateinteractionsamong the licensee, the NRC, and the jurisdictionalregulatoryagency, I either the U.S. Fish and Wildlife Service (FWS) or the U.S. NationalMarine FisheriesService I (NMFS), or both. Information requiredof the licensee will depend on the planned NUREG-0586 Supplement 1 0-270 November 2002
Appendix 0 decommissioningactivities and the species potentiallypresent. The NRC staff will seek informal consultation with NMFS and the FWS shortly after the licensee announcespermanent I cessation of operation. The comment did not provide new information relevant to this Supplement and will not be evaluatedfurther. The comment did not result in a change to the Supplement.
Comment: Section 4.3.14, pg. 4-61, last paragraph - This conclusion indicates that the NRC I will meet its responsibilities on a site-specific basis during any decommissioning process, but it does not specify how the NRC will meet its responsibilities or what information it will need from licensees. (CL-05/18) I Response: Section 4.3.14, "Cultural,Historicaland ArcheologicalResources," was revised and I identifies what activities can be genericallyevaluated and which require a site specific review.
See section 4.3.14.1 for a discussion of the requirements and section 106 of the National Historic PreservationAct. '
Comment: Abstract, p iii, lines 16 add "explicitly" before "consider" in the 5th sentence.
The original GElS did not explicitly cover reactors except boiling water reactors (BWRs) and pressurized water reactors (PWRs). However, other reactors were not explicitly listed in what was not covered by the GELS. Also, other reactors were listed in the table of decommissioning I reactors in the original GELS. They have been considered covered for activities described in the GElS. (CL-09/2) I Response: -The Abstract was revised and the above change made.
Comment: Executive Summary, p xi, 3rd paragraph, 4th sentence, lines 31 change to "It I does not include research and test reactors or-the decommissioning of reactors that were permanently shutdown as a result of an accident." ,This change provides consistency with the report and does not imply exclusion of all reactors that have been involved in an accident at some time during their operating history. (CL-09/3)
Response: The Executive Summary was revised incorporatingthe phrase "it does not include researchand test reactors."
Comment: Section 3.1, p 3-2, line 21 - the LaCrosse Boiling Water Reactor site is smaller than San Onofre. McGuire Nuclear Station has two operating reactors rather than three. (CL- 1 09/4).
November 2002 0-271 NUREG-0586 Supplement 1
Appendix 0 I Response: The Lacrosse reactoris on approximately 1.2 ha (3 ac) with the total utility owned I site of 66 ha (163 ac). The total site area for San Onofre is 34 ha (84 ac). The staff chose the I total site area to contrast the variousdecommissioning facilities. The comment on the McGuire I plant was correctand the staff chose to use the Turkey Pointplant instead.
I Comment: Section 3.1.1, p 3-2, line 39 and 3-3, line 1 - Fermi 1 is in the final phase I (decontamination and dismantling) of SAFSTOR. (CL-09/5)
I Response: Section 3.1.1, 'Types of Nuclear PowerReactorFacilities,"was revised and the I above phrase incorporatedin the text.
I Comment: Section 3.1.1.3, p 3-4, lines 10 delete 2nd sentence and modify 3rd sentence.
I The Fermi 1 FBR used uranium as its fuel. The information on uranium capturing neutrons to I produce plutonium is correct. Breeding rates are dependent on the FBR's specific design.
I (CL-09/6)
I Response: Section 3.1.1.3, "FastBreederReactors," was revised and the above changes I incorporatedin the text.
I Comment: Section 3.1.1.3, p 3-5, line 1- add "commercial" before "FBR." The final decision I on whether to permanently shutdown the FFTF, a DOE FBR, has not yet been announced.
I (CL-09/7)
I Response: Section 3.1.1.3, "FastBreederReactors," was revised and the word "commercial" I inserted before "FBR". On December 19, 2001 DOE announced the deactivationof the FFTF.
I Comment: Section 3.1.2, p 3-6, lines 18 The Fermi 1 Reactor Building is a steel domed I structure. Below ground, there is considerable concrete shielding, but the building is not I reinforced concrete. (CL-09/8)
I Response: Section 3.1.2, 'Types of Structures Located at a Nuclear PowerFacility," was I revised and the above changes incorporatedin the text.
I Comment: Section 3.1.3, p 3-8, line 32 - Add "The systems described are typical and may I differ at specific facilities." to end of the 1st paragraph. (CL-0919)
I Response: Section 3.1.3, "Descriptionof Systems," was revised and the above sentence I added to the text.
NUREG-0586 Supplement 1 0-272 November 2002
Appendix 0 Comment: -Section 3.1.3, p 3-10, line 7 - Add "or similar document" following "(ODCM)", since limits may be in Technical Specifications rather than an ODCM. Also, the description of effluent systems should include mention of an evaporator, since some facilities use evaporation to convert liquid waste to gaseous and monitor their discharge. (CL-09/10)
Response: Section 3.1.3, "Descriptionof Systems," was revised and "orsimilardocument" added to the text after "ODCM".
Comment: Section 3.1.3, p 3-14, lines 5 Shipment may also occur on barges or other ships. (CL-09/12)
Response:' Section 3.1.3, "Descriptionof Systems," was revised and the reference to barges or ships was included in'the text.
Comment: 'Table 3-2, p 3 Add footnote "c" to Fermi 1. Detroit Edison informed the NRC in late 2001 per the requirements of 10 CFR 50.82, that the final decontamination and dismantling phase of SAFSTOR would be started for Fermi 1. (CL-09/14)
Response: -Table 3-2 was revised and footnote "c"added.
Comment: Section 3.3.3, p 3 Sentences are duplicated between the three full paragraphs on p 3-29. (CL-09/15)
Response: Section 3.3.3, "Summaryof Plants that Have PermanentlyCeased Operations,"
was revised to remove redundanttext.
Comment: Section 4.3.3.3, p 4-12, line 16 - There appears to be a discontinuity between the previous paragraph and the paragraph starting on line 16. Is something missing? (CL-09/16)
Response: Section 4.3.3.3, "Results of Evaluation,"was revised to include the missing information.
Comment: Section 4.3.3.3, p 4-12, lines 28 Add 'The processing of residual sodium products from an FBR is no more likely to result in water quality impact than decommissioning activities at a LWR." (CL-09/118) -
Response: The suggested wording does not add anything to or change the staff's conclusion.
The comment did not provide new information relevant to this Supplement and will not be:.
evaluatedfurther.- The comment did not result in a'change to the Supplement.
November 2002 0-273 NUREG-0586 Supplement 1
Appendix 0 I Comment: Section 4.3.10.2, p 4-40, lines 12 in the paragraph on FBR decommissioning I activities, add that decommissioning a FBR involves removal of sodium and NaK, but that these I decommissioning activities can be performed safely with the proper engineering controls.
I (CL-09/27)
I Response: The suggested wording does not add anything to or change the staffs conclusion.
I The comment did not provide new information relevant to this Supplement and will not be I evaluated further. The comment did not result in a change to the Supplement.
I Comment: Section 4.3.11.1, p 4-41, line 7 - add "LWR" before "licensee" in the third sentence.
I The formula for the specified minimum amount of decommissioning funds applies to LWR's.
I The other regulations on decommissioning funds and evaluation of adequacy do apply to all I reactors, so there is no adverse impact of the formula applying only to LWR's. (CL-09/28)
I Response: Section 4.3.11.1, "Regulations,"was revised and "LWR" was addedbefore "I "licensee".
I Comment: Section 4.3.11.3, p 4-45, lines 4 delete or reword "and is either undergoing I decommissioning or is in safe storage awaiting decommissioning" from the second sentence.
I SAFSTOR or safe storage is a form of decommissioning. (CL-09129)
I Response: Section 4.3.11.3, "Evaluation,"was rewordedeliminating the misperception that I safe storage is not decommissioning.
I Comment: Tables 4-6 and 4-7, p 4 footnote "d" is not used in the tables, but probably I belongs next to the 960 value for the number of shipments from a PWR using SAFSTOR.
I (CL-09/30)
I Response: Tables 4-6 and 4-7 were extensively revised and footnote "d"referring to truck and I railshipments is no longer used.
I Comment: Section 4.3.18.2, p 4-72, lines 38 other irretrievable resources include gases I and tools, but these resources are also minor. (CL-09/31)
I Response: Section 4.3.18.3, "Evaluation,"was revised and "gases"and 'tools" were added to I the text.
I Comment: Section 6.1, p 6 for plants shutdown before existing decommissioning rules I were adopted, the environmental reviews may not be in the PSDAR as discussed in this I section. In such cases environmental aspects not previously addressed that need to be I addressed will be covered in the LTP. (CL-09/32)
NUREG-0586 Supplement 1 0-274 November 2002
Appendix 0 Response: Forplants thatpermanently ceased operationbefore the 1996 rule, the Decommissioning Plan and the EnvironmentalReport become the PSDAR. Decommissioning activities at all permanently shutdown facilities are substantiallyunderway. The major impacts, if any, that may not have been covered by the DecommissioningPlan and the environmental report (such as impacts to minority and low-income populations surroundingthe facility) have alreadyoccurred. In addition, the staff has been sensitive to protected species at existing decommissioning sites with several informal consultationsoccurring over the past several I years. The comment did not provide new information relevant to this Supplement and will not be evaluated further. The comment did not result in a change to the Supplement.
Comment: Table F-lThe site area for Fermi 1.is listed as 1,120 acres. That is the size of the Fermi 2 site; Fermi 1# is on a portion of that site. The original Fermi 1 site was 900 acres.
Currently, the portion of the site considered to be the Fermi 1 nuclear facility on the Fermi 2 site is less than 4 acres. (CL-09134) I Response: The revised area values were incorporatedin Table F-1.
Comment: Fermi l's cooling water source was Lake Erie. Saxton's area is listed as 1.1 acres, I however, the text reported San Onofre as having the smallest site. Also, footnote "b" should be ;I applied to the "Cooling System" header, rather than "Cooling Water Source." (CL-09/35)
Response: Table F-1 was correctedto include Lake Erie as the Fermi I's cooling water source. I The staff chose to list the area of the originallicensedsite for Saxton. Footnote "b"was changed to "coolingsystem" .
Comment: Table F-2, p F Fermi is in Michigan, not Ohio. (CL-09/36)
Response: Ohio was changed to Michigan for Fermi in Table F-2.
Comment: Section G.2.1, p G-13 & G-19 -the conclusion reached that the doses for I SAFSTOR and DECON are not substantially different is partly due to which decommissioning plants were selected to be evaluated. (CL-09/43) .
Response: In some cases, data for different categoriesof facilities were limited, and the data I presentedrepresentsthe best information currently available. All data received from :, ý decommissioning facilities was included in the estimates. The comment did not provide new information relevant to this Supplement and will not be evaluated further. The comment did not I result in a change to the Supplement. ,
November 2002 0-275 NUREG-0586 Supplement 1
Appendix 0 I Comment: Tables E-3, E-5, H-1 and H some additional activities, for example, system I dismantlement and large component removal, could potentially impact air quality. Provisions I are needed for portions of these activities to prevent adverse impacts. (CL-09149)
I Response: Typically, such activitiesare conducted inside enclosed structureswith monitored I releasepoints and are consideredunder the category "MaintainEffluent and Environmental I Monitoring Program." The comment did not provide new information relevant to this I Supplement and will not be evaluated further. The comment did not result in a change to the I Supplement.
I Comment: Table H-2, p H in the "Impact and Summary of Findings" section, "water use" I should be changed to "air quality." (CL-09/50)
I Response: 'Water use" was changed to "airquality"in Table H-2.
I Comment: Section J.1.1, p J add, "selected" before "facilities" in the first sentence of the I first paragraph. Identify the time period used for the comparison in the second paragraph.
I (CL-09156)
I Response: The recommended revision has been made in part. The word "selected"has been I added in the text. The time periodconsidered in the analysis is from the shutdown of the plant.
I Section J. 1.1 was revised.
I Comment: Table J add footnote "c" to Fermi 1. (CL-09157)
I Response: Footnote "c" was added under Fermi 1 in Table J-1.
I Comment: Section 4.3.9.1, page 4-33, refers to the licensee's FSAR. Suggest adding the I words "or equivalent" after "FSAR" since some licensees have a defueled safety analysis report I (DSAR) instead of a FSAR. (CL-15/2)
I Response: The phrase "orequivalent"was added after "FSAR"in Section 4.3.9.1, "I "Regulations".
I Comment: Section 4.3.12.1, page 4-47, second line - Add a period after the word "effects" I and begin the next sentence with the word "Socioeconomic." (CL-15/3)
I Response: The text was revised in Section 4.3.12.1, "Regulations,"consistent with the above I comment.
I Comment: The following Conclusions sections discuss environmental impacts that may have NUREG-0586 Supplement 1 0-276 November 2002
Appendix 0 small, moderate or large impacts: 4.3.1.4 (Onsite/Offsite Land Use), 4.3.5.4 (Aquatic Ecology),
4.3.6.4 (Terrestrial Ecology), 4.3.9.4 (Radiological Accidents), 4.3.10.3 (Occupational Issues),
4.3.12.4 (Socioeconomics). The FGEIS is not clear what, if any, actions a licensee should take depending on if the impacts are small, moderate or large. (CL-1514)
Response: The Supplement was revised to explain those issues that are consideredgeneric and have more than one level of significance. Section 4.3 was changed for clarification.
Comment: 'It is not always clear when a particular decommissioning activity or site/operating condition falls within the envelope of environmental impacts described in Section 4.0 and when that activity or condition would require further analysis. (CL-16/2)
Response: Chapter4 was extensively revised to more clearly define the envelope of generic impacts. However, the comment is too general to provide a specific answer. The comment did not provide new informationrelevant to this supplement and will not be evaluated further. The comment did not result in a specific change to'the Supplement.
Comment: The Supplement should address how the environmental analysis of decommissioning activities takes into account changes in the environmental parameters of the site during plant operation. (CL-1614)
Response: The Supplement has taken into account the changes in the site environment during I the plant's operation.".A genericenvironmental impact statement is a method of evaluating the impacts of similaractivities at similarfacilities resultingin similarimpacts. Changes in the site I environment during the plant operationalperiodare not so significant as to cause the impacts of similaractivities at similarfacilities to be significantly different. The comment did not provide new informationrelevant to this Supplement and will not be evaluated further. The comment did not result in a change to the Supplement.
Comment: The Supplement should provide more specific guidance to licensees regarding the I level of a particular decommissioning activity,, or the site conditions in which an activity is occurring, which'would trigger a site-specific NEPA analysis of the activity by the licensee. For I example,' with regard to levels of activity that would require a site-specific analysis, the Supplement should more specifically define what constitutes a major transportation upgrade.
With regard to site conditions, it should define how much time may pass after the previous disturbance of an aquatic or terrestrial ecosystem before a site-specific analysis is necessary, I or how recent the ecological assessment of that ecosystem must be to rely on the Supplement I instead of a site-specific analysis. This will facilitate both licensees' evaluation of environmental I impacts in required submissions such as the Post Shutdown Decommissioning Activities Report I (PSDAR) and the License Termination Plan (LTP), and NRC's development of site-specific I NEPA documents. (CL-16/6) I November 2002 0-277 NUREG-0586 Supplement 1
Appendix 0 I Response: Chapter4 was extensively revised to more clearly define when a site specific I analysis is required.
I Comment: Response to Comment No. 6-C, page A-13, indicates that impacts from potentially I contaminated sediment are addressed in the Supplement, but we did not find this information.
I (CL-1 6/8) 1 Response: The staff response in the scoping summary report (see comment 6-C, page A-13)
I referred to evaluation of the impacts of potentially contaminatedsediment within the site I boundary. Onsite contaminatedsediments are normally addressedin detail during the license I terminationplan review and is not addressedin any detail in this Supplement. The NRC staff I does not normally require remediation of offsite sediments unless they pose a threat to public I health and safety. The plants were licensed with the expectation that there would be routine I releases to the airand water due to normal operation. These releases are limited to ensure the I public health and safety. Offsite contaminationis monitoredand remediationis not warranted.
I The comment did not provide new information relevant to this Supplement and will not be I evaluated further. The comment did not result in a change to the Supplement.
I Comment: Page 2-5, Section 2.2, Line 10. This section should note that state or local I requirements may be more restrictive than NRC's. (CL-16/16)
I Response: The text in Section 2.2, "Summaly of Current Regulations,"was revised to I recognize that state or local requirements may be more restrictivethan NRC's requirements.
I Comment: Page 3-17, Section 3.2.1, Lines 32-33. Please revise the document to clarify that I while the evaluation of ISFSIs is outside the scope of the GELS, it should be noted that the I DECON alternative does not necessarily completely eliminate the need for long-term security I and surveillance of a facility; an ISFSI at a decommissioned facility will require long-term I security and surveillance. (CL-16/21)
I Response: It is stated(Table 1-1) that ISFSI maintenance is an activity that may be separately I licensed under 10 CFR Part 72 and is out of scope. It is further discussedin Section 1.3, "1 "Scope of This Supplement." The statement in Section 3.2.1, "DECON,"is correct. The facility I being referred to is the reactorfacility and not the ISFSI, which is consideredas a separate I facility. The comment did not provide new information relevant to this Supplement and will not I be evaluated further. The comment did not result in a change to the Supplement.
NUREG-0586 Supplement 1 0-278 November 2002
Appendix 0 Comment: Page 3-29. Lines 29-39 repeat lines 11-21. (CL-16/22)
Response: The redundancyin the lines has been eliminated.
Comment: Page 4-57, Section 4.3.13.4, Lines 36-38. The environmental sections of some PSDARs submitted to date have not provided detailed information. The Supplement should elaborate on the "appropriate information" that licensees should provide relating to environmental justice in the environmental section of their PSDARs to enable NRC to obtain sufficient information on potential environmental justice issues at decommissioning facilities.
(CL-1 6/68)
Response: The requirements for submitting the PSDAR can be found in 7 10 CFR 50.82(a)(4)(1). Guidance on what should be in the PSDAR can be found in Regulatory Guide 1.185, "StandardFormatand Content for Post-Shutdown DecommissioningActivities Report," dated August 2000. The staff plans to update Regulatory Guide 1.185 subsequent to publishing Supplement 1 to NUREG-0586, with guidance on including environmentaljustice considerationsin the PSDAR. -The comment did not provide new information relevant to this Supplement and will not be evaluated further. The comment did not result in a change to the Supplement.
Comment: Page 4-69, Section 4.3.17.2, Line 5. What is meant by "not large enough to destabilize the important attributes of the system?"--(CL-16/71)
Response: In terms of transportationimpacts, MODERATE impacts are those that would result in noticeable changes such as increasedtraffic or increasedroad maintenance requirements,but would not result in the need for major transportationsystem modifications,,
cause substantialchanges in local traffic flow, or cause a significantincrease in traffic fatalities or public radiologicaldose. Section 4.3.17.2 was consistent with the above explanation.
Comment: Pages 4-72 to 4-73, Section 4.3.18.- The discussion of irretrievable resourcesmbre properly belongs in a section that summarizes environmental consequences. The Supplement.
could benefit from having such a section as was'done with the recently issued draft NMSS I guidance document on NRC preparation of NEPA documents. (CL-16172)
Response: This section summarizes irreversibleenvironmentalconsequences for impacted areas. The readeris referred to Table ES-1 for a summary of the environmental impacts of I decommissioning. NRC has not determined that combining the discussion of irretrievable I resources with a summary of environmental consequences would substantiallyimprove the I Supplement. The comment did not provide new information relevant to this Supplement and will not be evaluated further. The comment did not result in a change to the Supplement.
November 2002 0-279 NUREG-0586 Supplement 1 I
Appendix 0 I Comment: Page 4-72, Section 4.3.18, Line 9. It seems inappropriate to include concrete as I an irretrievable resource. (CL-16i73)
I Response: Section 4.3.18, "IrretrievableResources," was revised and concrete was eliminated I as an irretrievableresource.
I Comment: Page 4-72, Section 4.3.18.1, Line 14. The Supplement states that there "are no I regulations that deal specifically with the concept of irretrievable resources." It is unclear what I is meant by this statement. The following statutory and regulatory provisions pertain to I irreversible and irretrievable resources in the NEPA context: -NEPA' 102(2)(C)(v), 42' U.S.C.'
I 4332(2)(C)(v);-40 CFR 1502.16 (CEQ regulations); and,-10 CFR, Part 51, Subpart A, I Appendix A (NRC regulations). (CL-16/74)
I Response: Section 4.3.18.1, "Regulations,"was revised. The first sentence was removed and I the pertinentreferences were added to the section.
I Comment: We would like to comment on the draft NUREG to correct an error in Table 4-3, 1 line 21 regarding the Cost Impacts of Decommissioning for Rancho Seco. Line 21 should read:
I Rancho Seco 913MWe PWR DECON $394.
I Please refer to our letter submitted to the NRC Document Control Desk dated 3/26/01 entitled I Rancho Seco Report on Decommissioning Funding Status. On page 2 of the letter we stated:
"I "...Their [TLG] estimate was $495.4 million in 2000 dollars. The portion of this total that is non I NRC-defined decommissioning activities related to non-radiological dismantlement and I management and storage of spent fuel is $101 million, most of which is related to fuel storage I costs..."
I SMUD, when it first established its decommissioning fund, included radiological dismantlement I costs and costs related to storing spent fuel. Therefore, $495m -$101m leaves $394 million for I equivalent cost discussed in Table 4-3 of the NUREG. (CL-18/1)
I Response: Table 4-3 was revised to reflect the new estimate for decommissioning.
I Comment: The Figure 1-1, "Decommissioning Timeline" should also reflect the 60 year I window, mentioned in 10CFR50.82(a)(3), that starts from the permanent cessation of operation.
I (CL-30/2)
NUREG-0586 Supplement 1 0-280 November 2002
Appendix 0 Response: Figure 1-1 was revised to reflect the sixty year periodfor decommissioning.
Comment: Revise the first part of the last sentence on page 1-5 to read: If a licensee chose to I operate the ISFSI under a Part 50 license, they could choose to continue under the Part 50 license, or by way of license amendment request. (CL-30/3) I Response: Chapter 1, "Introduction,"was revised to accuratelyreflect the requirements in 10 I CFR Part50 and Part72.
Comment: -Under the description of the Turbine building (on page 3-6) revise the last two sentences to read: Primary coolant is not circulated through the turbine building systems in I PWRs., However, it is not unusual for the turbine building to become mildly contaminated I during power generation at PWRs. (CL-30/5)
Response: Section 3.1.2, 'Types of Structures Located in a Nuclear Power Facility," was I revised and the last two sentences in the description of the "'Turbine building"were changedas I proposedabove.
Comment: Add the following sentence to the first paragraph in section 3.1.4: Most of the contamination in the reactor coolant system is from the activation of corrosion products and not I fuel. (CL-30/6)
Response: Section 3.1.4, "Formationand Location of Radioactive Contaminationand Activation in an OperatingPlant,"was revised and the above sentence was added to the text.
Comment: Revise the second to last sentence on page 3-15 to read: The entire structure (or I portions) must be removed ........ (CL-3017)
Response: Section 3.1.4, "Formationand Location of Radioactive Contaminationand' Activation in an OperatingPlant,"was revised consistent with the above comment.
Comment: 'The last sentence on page 3-15 is only true if corrosion products are included. The I sentence should be revised to read: If corrosion products are included, the radioactive decay ....... (CL-30/8)
Response: Radioactive corrosionproducts are the result of activationand can be considered I activationproducts, therefore the staff chose not to make a change to the text of the Supplement. The comment did not provide new information relevant to this Supplement and will I not be evaluated further. The comment did not iesult in a change to the Supplement. I November 2002 O-281- NUREG-0586 Supplement 1
Appendix 0 I Comment: The last two paragraphs on page 3-15 need to be rewritten. The discussion of I contamination and activation needs to be clarified. If requested, CYAPCO will work with the I Commission to rewrite this text. (CL-30/9)
I Response: The staff has determined that for the purpose of this Supplement the explanation I of contaminationand activationis adequate. The comment did not provide new information I relevant to this Supplement and will not be evaluated further. The comment did not result in a I change to the Supplement.
I Comment: Yankee Rowe should be added to the list of plants mentioned in the second to last I paragraph of page 3-26. The Yankee Nuclear Power Station was one of the plants in the I AEC's Demonstration's Program. Yankee Rowe's license number is DPR-3. (CL-30/10)
I Response: Section 3.3.1, "PlantSites," was revised and Yankee Rowe was added to the list.
I Comment: The second to last paragraph on page 3-32 discusses the creation of nuclear I islands. Nuclear islands are not primarily created because of security reasons. The real benefit I in creating nuclear islands is to not interfere with spent fuel storage. The purpose for creating a I nuclear island is to provide a facility for the safe long-term storage of spent fuel, which is I independent of the remainder or the rest of the facility. The purpose of the modifications is to I divorce the spent fuel cooling function from dependence on systems which must be dismantled I as part of the overall decommissioning process. (CL-30/11)
I Response: Section 3.3.3, "DecommissioningProcess,"was revised to more accurately I describe the reasonsfor establishinga nuclearisland.
I Comment: Expand the discussion about Stage 4 of the decommissioning process. This I discussion should contain as much description as the descriptions under stages 1 through 3.
1 (CL-30/12)
I Response: The staff chose not to expand the discussion of Stage 4 of the decommissioning I process. Activities during Stage 4 result in minimal environmentalimpact and focus on I demonstratingthat the previous decommissioning activities have resultedin site radiological I conditionsthat allow termination of the license. The comment did not provide new information I relevant to this supplement and will not be evaluated further. The comment did not result in a I change to the Supplement.
I Comment: Delete "groundwater" from the first sentence in section 4.3.3.4. Releases are not I made to groundwater under NPDES permits. NPDES discharge points discharge to surface I water locations. (CL-30/13)
NUREG-0586 Supplement 1 0-282 November 2002
Appendix 0 Response: Section 4.3.3.4, "Conclusions,"was revised and the term "releases"was removed.
from the first sentence. Section 4.3.3 does considerimpacts to groundwaterdue to decommissioning;therefore, it is appropriatethat the "Conclusions,"Section 4.3.3, include groundwater.
Comment: On Pg 3-17 there is a discussion of the advantages of the DECON alternative for decommissioning. One advantage of DECON is not discussed and should be. Generally speaking the shorted lived nuclides are easier to detect because of their beta/gamma emissions, versus the alpha emissions of longer lived nuclides. The difficulty of detecting the alpha emitters will increase analysis costs and increase the difficulty of performing surveys.
Ultimately the cost of providing RP coverage and of performing the Site Characterization and Final Status Survey will also be increased. (CL-31/6).
Response: Section 3.2, !Decommissioning Options," provides a very generalcomparison of the various options for decommissioning, including the advantages and disadvantagesof each.
option; therefore, the staff has determined that the suggested change provides detailed advantages not consistent with the other options. ..
Comment: Table F-1 lists the total site area for Peach Bottom Unit 1 to be 620 acres.
620 acres is the total site area reported in the Peach Bottom Unit 2 and 3 Updated Final Safety Analysis Report. However, Table F-2 reports the total site area for Peach Bottom Units 2 and 3 to be 618 acres. Table F-2 should be changed to reflect the total site area for Peach Bottom Units 2 and 3 to be 620 acres. (CL-31/14)
Response: Table F-2 was revised and the value 620 acres was used.
Comment: On page L-6 of Appendix L, line 4 refers to criticality accident monitoring, requirements described in .10 CFR 7.24. Criticality accident monitoring requirements are described in'10 CFR 70.24. This typographical error should be corrected. (CL-31/16) .
Response: The reference was correctedto 10 CFR 70.24.
Comment: On page L-6 of Appendix L, line 17 refers to 10 CFR 50.73 as requiring a licensee event report within 30 days., 10 CFR 50.73 was recently revised to require a licensee event report within 60 days. This change should be made to Appendix L. (CL-31/17)
Response: Appendix L was revised to reflect the 60 day limit. ,
Comment: All spent fuel at Dresden Unit 1 will be moved to dry storage on site by the end of the first quarter of 2002. This change needs to be reflected in Table 3-2. (CL-31/19)
November 2002 0-283 NUREG-0586 Supplement 1
Appendix 0 I Response: Table 3-2 was revised to indicate that all the Dresden Unit 1 fuel is in dry storage.
I Comment: And speaking of Appendix F, by the way: please note in Table F-2 that the I Callaway plant is located in Missouri, not in Montana. (CL-51/6)
I Response: Appendix F was revised and Montana was changed to Missouri.
I 0.6.2 Clarification Questions I Comment: I had a question on the difference between the 1988-or one of the differences I between the 1988 version and this supplement. The scope of facilities that are being I addressed is much smaller, it's mainly just nuclear power reactors and I wanted to know for all I the other facilities that were referenced in the '88 document and some of those included like the I MOX facilities. How will those be addressed? Are they going to be addressed in a different I type of document down the road or-I'm just asking along those lines. (AT-Ni)
I Response: This Supplement only addressespermanently shutdown commercial nuclear I power reactors. The environmentalanalysis for the other facilities in the 1988 GElS is still valid.
I As deemed necessary and appropriate,NRC will update the environmentalimpact I assessments for the decommissioningof other facilities evaluatedin the 1988 GElS but not I included in this Supplement. MOX fabricationand utilization facilities will have a separate I environmentalassessmentpreparedby the NRC staff. The comment did not provide new I information relevant to this Supplement and will not be evaluated further. The comment did not I result in a change to the Supplement.
I Comment: The last paragraph in the Conclusions section of the Executive Summary, and I page 2-3 of Section 2.2.1, state that a licensee would have to submit a license amendment I request if environmental assessments are outside the bounds of'the GElS or if the environ I mental impacts of a decommissioning activity have not been previously reviewed. What is the I licensing document that should be modified in the license amendment request? Section 2.2.1 I states the Environmental Report should be revised, but the PSDAR may be a more appropriate I document. (CL-15/1)
I Response: The EnvironmentalReport is the appropriatedocument that needs to be updated.
I The PSDAR requiresa discussion of the reasons for concluding that the environmentalimpacts I associatedwith site-specific DECON activities will be bounded by previously issued I environmental impact assessments. It does not require the analysis of specific impacts related I to specific activities. However, based on the results of the licensee's environmentalreview, the I PSDAR may also require updating. The license amendment would request the incorporationof NUREG-0586 Supplement 1 0-284 November 2002
Appendix 0 a license condition in the license that would allow the activity to proceed. The comment did not provide new information relevant to this Supplement and will not be evaluated further. The comment did not result in a change to the Supplement.
Comment:, Will this Supplement replace entirely the previous NUREG-0586?, (SF-N1)
Response: No. This Supplement will entirely replace the evaluation of environmentalimpacts from decommissioning activities of nuclearpower facilities. The Supplement will be a stand-. , 1 alone document and supercedes the environmentalimpacts to power reactorsdescribedin the 1988 GELS. This Supplement goes beyond the 1988 GElS and considers the permanently shutdown high-temperaturegas-cooled reactors and the fast breeder reactors.-This Supplement does not cover researchand test reactorsor power reactorfacilities that have shut down due to major accidents (i.e., Three Mile Island).- It also does not cover other types of fuel cycle facilities. The comment did not provide new information relevant to this Supplement and will not be evaluated further. The comment did not result in a change to the Supplement.
Comment:, I'm a little confused because if a licensee is outside the bounds or.in an area that is beyond what has been previously reviewed, we're required to submit a licensee amendment. I request. Now I'm confused, since you've got, for these different criteria,-a small impact, and a moderate impact, and a large impact, what is the bounds? (SF-A12) - I Response:, If the evaluation of any activity indicates that it could potentially result in an environmentalimpact that is greaterthan thatpredictedby the Supplement, then the licensee needs to submit a license-amendment request. Forexample, if the change to the facility would result in a moderate impact to the environment and the Supplement predictsa small impact, then the licensee needs to submit an amendment request. The comment did not provide new I information relevant to this Supplement and will not be evaluated further. The comment did not result in a change to the Supplement.
Comment:' In reaching your findings about these impacts, these environmental impacts, the generic issues and impacts, I'm wondering what the baseline you were using was to measure those impacts against. In other words, were you comparing the impacts to the site before the nuclear facility was built or during its peak period? And in that case were the impacts considered cumulative or stand alone? (SF-B/1)
Response.: The impacts were compared againstthose that existed at the time the facility
,permanentlyceased operation. The impacts identified at the time that the facility permanently ceased operation are cumulative impacts from plant construction through operation. Therefore, comparingdecommissioning impacts to impacts at the time the plant ceased operation would November 2002 0-285 NUREG-0586 Supplement 1
Appendix 0 I include cumulative impacts. The comment did not provide new information relevant to this I Supplement and will not be evaluated further. The comment did not result in a change to the I Supplement.
I Comment: My question concerns the last comment that you just made about that no activities I can be performed during decommissioning that would result in significant environmental I impacts not previously reviewed. Would you determine this from the submission of the I PSDAR? Is that how you would determine if anyone was going to do anything that wasn't I previously reviewed? (CH-N1)
I Response: When the licensee preparesthe PSDAR, they will identify the major activities that I they plan to perform during decommissioning. They must evaluate the environmental impacts I from decommissioning activities and compare those impacts to the results of the GElS on I decommissioningand othersite-specific environmentalimpact statements. The licensee is I requiredto evaluate any planned decommissioningactivity againstany previous environmental I assessmentspriorto undertaking that activity [10 CFR 50.82(a)(b)(ii)]. the requirement for the I evaluation is containedin the facility's written procedures. Documentation that such an I evaluation has been conducted is availablefor NRC review during a site visit or inspection. The I comment did not provide new informationrelevant to this Supplement and will not be evaluated I further. The comment did not result in a change to the Supplement.
I Comment: Once the work is performed, is there monitoring to make sure they're in compliance I with the PSDAR? If they're actually acting, doing what they said they were going to do?
I (CH-N2)
I Response: Duringthe decommissioningprocess, NRC inspectors will periodicallyconduct I specialinspections of specific activities at the site. Site visits and inspection will be more I frequent for plants that are undergoing decontaminationand dismantlementand less frequent I for plants that are in storagemode. Since the PSDAR is primarilyan information document I preparedto inform the public and NRC of the licensee's plans and schedule, it is not normally I utilized by the NRC to determine compliance with regulations. The comment did not provide I new information relevant to this Supplement and will not be evaluatedfurther. The comment I did not result in a change to the Supplement.
I Comment: You said that a licensee could go ahead and dismantle without formal approval and I I thought that the licensee based on the document, the licensee had to submit the PSDAR and I then there was a 30-day public process. Were you not counting that because that didn't directly I relate to the question? (CH--N16)
NUREG-0586 Supplement 1 0-286 November 2002
Appendix 0 Response: Initialdecommissioning activitiessuch as drainingsystems, removal of some components, pumps, tanks, disposalof resins, and surface contaminationremoval can occur at any time, including immediately after permanent cessation of operations.-However, no major decommissioning activities may take place until 90 days after the PSDAR has been submitted.
Major decommissioning activities are defined as "anyactivity that results in permanentremoval of major radioactive components, permanently modifies the structure of the containment, or results in dismantlingcomponents for shipment containinggreaterthat Class C waste." A description of the decommissioningprocess is given in Section 3.2. The comment did not provide new information relevant to this Supplement and will not be evaluated further. The comment did not result in a change to the Supplement.
Comment: What I was asking you was then cumulative impacts in terms of the plant during its operating period with the decommissioning activities added onto it, or do you mean something else? (SF-B/2)
Response: For discussionsof cumulative impacts, the NRC consideredthe terminology defined in 40 CFR 1508.7: -"Cumulative impact is the impact on the environment which results from the incrementalimpact of the action [in the case of this Supplement, that is decommis sioning activities] when added to other past,present,and reasonablyforeseeable future actionsI regardlessof what agency (Federalor non-Federal)or person undertakes such other actions.
Cumulative impacts can result from individuallyminor but collectively significantactions taking place over a periodof time." Using this definition, the staff examined the impacts of decommis sioning activity at NRC-licensed nuclearpower facilities and made a cumulative assessmentof decommissioning activitiesand other past,present,and reasonablyforeseeable future activities I at the sites. Section 4.0 of the Supplement has been changed for clarification.
0.6.3 Statements for or Against Nuclear Power Comment: Georgians for Clean Energy promotes the shutdown of our unsafe nuclear power plants here in Georgia and the phase out of nuclear power nationwide. (AT-N8)
Response: Shutting down operatingfacilities is outside the scope of this Supplement, which deals with facilities that have permanentlyceased operations. The comment did not provide new information relevant-to this Supplement and will not be evaluated further. The comment did not result in a change to the Supplement.
Comment: I'm now concerned about the costs, about all the broken promises, because these I all sound-all these systems sound so good. But I can remember-I'm old enough to remember when this was going to be clean, safe and cheap. Electricity was going to be too November 2002 0-287 NUREG-0586 Supplement 1
Appendix 0 I cheap to meter. That sticks with me. And we know that it's as expensive as anything possibly I could be when you consider the whole-the whole cycle from the mining of the uranium to what I happens afterwards. There's a huge process. (AT-D/O0)
I Comment: The nuclear issue is the most important issue facing humanity and has been since I the atom was first split. The nuclear issue is the Sword of Damocles over the planet and all I future generations should we survive the next decade. (CL-20/2)
I Comment: Furthermore, no new nuclear plants should be allowed or built as they will just add I to the existing contamination, and all operating plants should be shutdown to stop further I 'Waste" - such as plutonium-generation. (CL-20/115)
I Comment: The nuclear power industry was a colossal mistake to begin with, as we all know.
I (CL-33/2)
I Comment: The NRC must resist the pressure of the nuclear industry. If their profits are I waning, they have had their turn. The citizens of the U.S., who pay everyone's way, have a I right to expect a healthy environment, and a right to fight for it within the United States legal I system. (But what a shame that a fight is ever needed.) (CL-36/8)
I Comment: It ought to be equally obvious that without public subsidy (via Price-Anderson)
I nuclear power is economically untenable. (CL-4214)
I Comment: It ought to be equally obvious given these factors the complete phase-out of I nuclear power should be a high priority. Alternative power sources such as wind, solar, I hydrogen fuel cell [and conservation] should be vigorously pursued in its stead. (CL-42/5)
I Comment: The enterprise of electricity generation using nuclear fission requires public I subsidy. Without Price-Anderson protection, nuclear power would be economically untenable.
I (CL-46/5)
I Comment: Consideration of these factors must be fully and publicly discussed before exposing I our citizens to additional exposures through development of new nuclear generation facilities.
I The complete phase-out of nuclear power should be considered based on objective analysis of I health and economic effects including probability evaluation of all possible accidents and I incidents, and comparison of all potential energy sources such as wind, solar, hydrogen fuel cell I and including conservation. (CL-46/6)
I Comment: As we have stated earlier, the methods used to decommission a nuclear plant will I affect not only the communities of today but also the livelihood of future generations. The I nuclear industry is leaving humankind a legacy of devastation-epitomized by its long-lived and NUREG-0586 Supplement 1 0-288 November 2002
Appendix 0 highly dangerous nuclear waste. They are unable to solve their waste problem and now, when faced with the eventual shutdown of their plants, are unwilling to take measures to ensure that the public is protected. (CL-08/32)
Response: The comments relate to nuclearenergy in generaland are outside the scope of this Supplement. The comments did not provide new information relevant to this Supplement and will not be evaluatedfurther. The comments did not result in a change to the Supplement.
Comment: Bush is stripping us all of those safeguards we all need to protect citizens--and this includes you. He has only corporate interests--the nuclear power industry being one. (CL 34/3), .
Response:- The missions of the NRC include the protectionof public health and safety and .I protection of the environment. The comment did not provide new information relevant to this Supplement and will not be evaluated further. The comment did not result in a change to the Supplement.
0.6.4 Comments in Support of Decommissioning Comment: I certainly heard Eva loud and clear, that the amount of exposure for decommissioning is less than for operating 'reactors. So our organization is-certainly in favor of decommissioning. Let's just do it right. (AT-B/18)
Comment: We'd like to see the decommissioning of nuclear plants go forward, and we want it to go forward in the safest, most environmentally sound manner. (CH-N4)
Comment: As a preliminary matter, we support the prompt decommissioning of nuclear power plants and urge the U.S. Nuclear Regulatory Commission ("NRC") to ensure that decommissioning goes forward in the safest, most environmentally sound manner. (CL-11/1)
Comment: We would like to make it abundantly clear that we see decommissioning to be the most appropriate and responsible action to take with all nuclear'reactofs. -(CL-4713)
Comment: Certainly, every reactor shut down is another step away from further creation of radioactive waste, the ever-present possibility of nuclear ter'ror (be it a reactor accident or terrorist attack) and the continuing irradiation of our everyday lives. (cL-47/5)
Comment: Our organizations are fully supportive of the permanent closure of nuclear power reactors. (CL-48I7)'
November 2002 0-289 NUREG-0586 Supplement 1
Appendix 0 I Comment: Our goal is to require that nuclear facility owners and operators, to the best of their I ability, function as the good neighbors and responsible corporate citizens they claim to be. That I would include fully encapsulating and isolating all of the wastes and radioactively and I chemically contaminated materials resulting from their operations and decommissioning. It I includes doing everything possible to: 1)Prevent public exposures in the current and future I generations to radiation and chemicals from nuclear power production, waste management, I transportation, "cleanup" and decommissioning; 2)Prevent additional environmental I contamination both onsite and offsite and to remediate and minimize that which has already I occurred. (CL-48/8)
I Response: The comments are in support of safe, efficient, and timely decommissioning of I permanently shutdown power reactors. The comments did not provide new information I relevant to this Supplement and will not be evaluatedfurther. The comments did not result in a I change to the Supplement.
I 0.6.5 General Comments I Comment: I think this is a good beneficial effort to have this generic supplement. I think it's I going to help do evaluations of the environmental consequences of what we're doing. It's going I to make sure in some cases that we look at the right things and don't skip anything. I do agree I with the overall conclusions of the document. And also, I agree on what should be considered I generically and what is site-specific because there are some site-specific issues. (CH-D/1)
I Comment: For the next comment, for older plants, in some cases, there are some differences I in the physical configuration from what was described and assumed. An example is like there I may not be active ventilation systems. We are just going to have to install those systems as I needed to properly protect the air quality and so forth. (CH-D/9)
I Comment: Also, in the licensing arena, our documents may. not include what has already been I assumed to be in the documents for plants that recently shutdown. And in those cases, like for I the environment hazards, if we don't have it already covered in the document, we're going to I have to cover it in the license termination plan. So, I think what will be covered is just, it may I not already be covered in the document. (CH-D/10)
I Comment: Overall, Maine Yankee (MY) believes that the Supplement provides a fair update of I the sections of the 1988 NUREG versions relating to pressurized water reactor, boiling water I reactors, and multiple reactor stations. (CL-04/1)
I Comment: Draft supplement 1 represents a useful update of the environmental impacts of I decommissioning based upon over 200 facility-years' worth of actual decommissioning I experience accumulated by nuclear facilities since the NRC published the initial GElS in 1988.
NUREG-0586 Supplement 1 0-290 November 2002
Appendix 0 NEI concurs with the GElS conclusions, which found that for the "..;.environmental issues assessed, most of the impacts are generic and SMALL for all plants regardless of the activities and identified variables...",(CL-05/1)
Comment: Overall, Detroit Edison agrees with the conclusions in the draft NUREG-0586, Sup 1. The supplement will be helpful and updates the previous Generic Environmental Impact (GELS) on Decommissioning to accommodate changes in regulations and experience gained in recent decommissioning activities. (CL-09/1)
Comment: In conclusion, Detroit Edison thinks the draft supplement to the GElS on decommissioning of nuclear facilities is a good effort and agrees with the overall conclusions.
Some details should be revised to improve accuracy and to ensure planned decommissioning activities, intended to be covered by this supplement, are fully addressed. This will avoid future questions on whether activities are covered and/or bounded by this GElS supplement.
(CL-09158)
Comment: EPA supports the approach NRC has taken in the Supplement of establishing an envelope of environmental impacts resulting from decommissioning activities and identifying those activities which can be bounded by a generic evaluation and those which require a site specific analysis. This approach concentrates the environmental analysis on those activities with the greatest likelihood of having an environmental impact. EPA also commends NRC for drafting a Supplement which facilitates public, understanding in its use of plain English and explanation of technical terms. (CL-16/1)
Comment:, Also, based on information presented in various industry forums, several numbers quoted for some of the other plants may be inaccurate. Each plant should verify the numbers for accuracy. (CL-18/3)
Comment: Just as anyone with common sense can tell this Draft Supplement 1 to NUREG 0586 will have dire consequences if implemented in its current form. (CL-20/3)
Comment:, Exelon continues to maintain that providing guidance, which addresses environmental issues generically, provides the highest standard the public at large can use effectively to challenge industry to return power plant sites to beneficial use upon facility retirement. (CL-31/2) ,
Comment: Excelon believes the proposed Draft Supplement correctly concludes that most of the environmental issues assessed result in impacts that are generic and SMALL for all plants.
We reach this conclusion based upon our experience decommissioning one BWR (Dresden 1),
November 2002 0-291 NUREG-0586 Supplement 1
Appendix 0 I two PWR's (Zion Station), one HTGR (Peach Bottom 1), and our observation of other industry I decommissioning projects. We have not seen to date - and currently do not expect to find I environmental impacts different from those addressed and bounded by this Supplement to the I GELS. (CL-31/1)
I Comment: In general the draft supplement meets the goal of updating the GElS to current I decommissioning practices and dismantlement options. (CL-30/1)
I Comment: There is still time to correct all the serious problems in the Draft, still time for the I NRC to turn from the path of wickedness and ruin the Draft Supplement and GElS will lead to if I passed as is. (CL-20/118)
I Comment: I would point out that on pages C-1 and C-2 are the names of those responsible for I this abomination for reference in case of future lawsuits, so the public should make a note of I that (this is, after all public record, what I have written). (CL-20/117)
I Comment: It appears that the nuclear industry has written its own ticket, as usual, on the I issues in the Draft. P. E-5 notes the help from the Nuclear Energy Institute in gathering I information. (CL-20/64)
I Comment: The NRC is charged to protect the quality of the human environment and we ask I that they can-that they do all they can to uphold that charge. The current draft GElS is not I protective and needs major improvement. (AT-N44)
I Comment: [In addition to the economic gash in the GElS portal, this fatally flawed document I does not adequately addiress, acknowledge, account for, or compute a number of significant I barriers related to radiological decommissioning; including:] Planned Operating Life of a I Nuclear Generating Stations. (CL-0214)
I Comment: [In addition to the economic gash in the GElS portal, this fatally flawed document I does not adequately address, acknowledge, account for, or compute a number of significant I barriers related to radiological decommissioning; including:] Plant Valuation. (CL-02/8)
I Comment: Did the Nuclear Regulatory Commission "encourage" its economists, accounts, and I actuaries to ignore the impact of deregulation and plant devaluations on local communities? Is I it unreasonable to ask the NRC to view decommissioning through a global lens that accounts I for economic reality, objective science, and fiduciary accountability? Or is the Commission I intent on viewing radiological decommissioning through surrealistic prescription monocles I prescribed by the Nuclear Energy Institute, the Edison Electric Institute, Electric Power I Research Institute, and the Institute for Nuclear Power Operations? (CL-02/14)
NUREG-0586 Supplement 1 0-292 November 2002
Appendix 0 Comment: At some point, the NRC will haveto create a decommissioning vessel the incorporates reality as its guide. Frankly, the GElS resembles a script for "Abbott and Costello" prepared by Norman C. Rasmussen, Bernie Snyder and Ken Lay. (CL-02/16)
Comment: The document can be condensed in to three words, namely: "DUMP AND COVER." (CL-20/1)
Comment: Deregulation has already had serious negative impact on local municipalities this will be just another blow. (CL-25112)
Comment: To even think that decommissioning nuclear power plants' regulations via presidential fiat is acceptable is beyond logic and reason. (CL-34/1)
Comment: I find the proposals in Supplement 1 to the Generic Environmental Impact Statement on Decommissioning unrealistic when it comes to the health of United States citizens at the time of decommissioning and to those living years later. (CL-39/1)
Comment: I guess one of the reasons I wanted to'comment on this "Draft Supplement" is because it'so dramantically-reflects the backward World of Alice in Wonderland and of, commercial nuclear power: "Sentence first -- verdict afterwards." Make a'permanent mess first --- try to figure it out afterwards. (CL-51/27) :
Comment: We concur with and adopt by reference th6 comments of the Nuclear Information and Resource Service, submitted by Paul Gunter. (CL-52/1)
Comment: I don't really know why I am bothering io ývrite all this, as the NRC will ignore it anyway, but hope springs eternal as they say. If we don't have comparisons,*we can't have at least some idea of what constitutes the start of a return to a more unpolluted site, and we can't establish what needs bulldozing and taken to a'raýdioactive'wa'ste national sacrifice area.
(CL-20111)
Comment: Additionally, Public Citizen is concerned that the provisions outlined in the Supplement miight allow owners and operators of nuclear power reactors to reduce or c6mpletely evade their civic, environmenial, economic and legal responsibilities. (CL-4712) "
Comment: (The Western Shoshone Nation, AKA the Nevada Nuclear Test Site) that blew radioactive fallout across the nation causing serious illness, birth defects and cancers, besides doing thee same to some nearer the site in Nevada." The'only thing Las Vegas worried ,about,"
was if the tests shbok their g'a mbling tables a~co-rding to press reports. When the wind blew' towards Las Vegas they tried not to test. For Nevada to now whine that they don't see why they should get the spent nuclear fuel as they have no reactors-power reactors-is obscene, November 2002 0-293 NUREG-0586 Supplement 1
Appendix 0 I considering that a huge Curie quantity of the spent fuel was generated making/creating the I plutonium and the tritium for the nuclear weapons most of them supported and didn't care that I the fallout dumped on their fellow planetary citizens. The fact that there were, and are, some I small groups who were, and are against the weapons and the testing and the horrors of nuclear I power does not alter the fact that the state didn't protest. The states current protests, even if I valid for other reasons, ring hollow against that history of nuclear collaboration, when they use I the "no power reactor" excuse to keep the waste out. It is time history was set straight.
I (CL-20/82)
I Comment: Have you all no shame? (CL-20/108)
I Comment: This is ridiculous! (CL-22/1)
I Comment: You do not need to further endanger our lives while the polluters go scott free.
I (CL-34/5)
I Comment: These admonitions have been presented to the NRC repeatedly in many I Commission and staff meetings, agency panels and workshops, public meetings, legal I proceedings. Until they are heard, adopted, and adhered to, this Supplement, the Final GElS I on Decommissioning of Nuclear Facilities and the Decommissioning Rule and NRC's radiation I protection standards will continue to be inadequate and in violation of the applicable laws, I including but not limited to the AEA, NEPA, and APA, cited above. All four should be withdrawn I and entirely rewritten to provide true protection from radiological contaminations. (CL-52/25)
I Response: The comments are general in nature and did not provide new information relevant I to this Supplement and will not be evaluated further. The comments did not result in a change I to the Supplement.
I Comment: ,We support the NRC's current efforts to update the GElS for nuclear power plants I to reflect the industry's experience in decommissioning and to more fully consider issues like I partial site release and re-use of concrete rubble as fill. (CL-01/1)
I Response: Rubblization and partialsite release are evaluatedand discussedin the scope of I the document in Section 1.3 and further addressedin Chapter4, as appropriate. The comment I did not provide new information relevant to this Supplement and will not be evaluatedfurther.
I The comment did not result in a change to the Supplement.
I Comment: As the NRC evaluates the comments received on the GELS, it should look beyond I the actual decommissioning process and focus on what condition the site would be in following I license termination. (CL-17/10)
NUREG-0586 Supplement 1 0-294 November 2002
Appendix 0 Response: Regulations regai'dinglicense termination are in 10 CFR 20, Subpart E. These regulationsand ultimate goal of decommissioningis to ensure that the site will be in a condition suitable for future use in either a restrictedor unrestrictedcapacity. The comment did not provide new information relevant to this Supplement and will not be evaluated further. The comment did not result in a change to the Supplement.
Comment: If the possibility exists that radioactive material will remain onsite under an unrestricted orrestricted use condition the GElS should consider the associated long-term environmental impacts. (CL-17/11)
Response: Regulations regardinglicense termination are found in 10 CFR 20, Subpart E. For sites that have been releasedfor unrestricteduse, there would be no mechanism for future contaminationor radiologicalreleases. Therefore, long-term environmentalimpacts would be negligible. In the event that the site is releasedfor restricteduse, the site would continue to be monitored until the levels have been reduced below 10 CFR 20, SubpartE limits. The, comment did not provide new information relevant to this-Supplement and will not be evaluated further.- The comment did not result in a change to the Supplement.
Comment: Public Citizen is very concerned about several aspects of this supplement to NUREG-0586, specifically those that could pose risks to public health, the public's right to participate in decisions that affect them, and environmental quality. (CL-47/1)
Response: The description of impacts as site-specific orgeneric does not preclude local, communities from participating. The commenter is referredto the Executive Summary for a description of "generic"and "site-specific." The public can raise issues using any of several methods. If the licensee has requested an action requiringa license amendment, then the process for interveningin this action is by requestingor participatingin a hearing. The process is set forth in NRC's regulationsin 10 CFR Part2, "Rulesof Practiceof Domestic Licensing Proceedingsand Issuance of Orders." If the action of concern does not involve a license amendment, then any member of the public may raisepotential health andsafety issues in a petition to the NRC to take specific enforcement action againsta licensed facility. This provision is containedin the NRC's regulationsand is often referred to as a "2.206petition"in reference to its location in the regulations (Chapter2, Section 206 or 10 CFR). The comment did not provide new information relevant to this Supplement and will not be evaluated further.
The comment did not result in a change to the Supplement.
Comment: The potential use of plutonium fuel at the McGuire and Catawba reactors is not adequately addressed in decommissioning-in this decommission document. In fact, the costs of decommissioning are nowhere to be found. So we would request that there be a supplement I right away before mistakes are made in licensing the use of plutonium fuel at the McGuire and I November 2002 0-295 NUREG-0586 Supplement 1
Appendix 0 I Catawba reactors because the decommissioning impacts, including costs, and also including I the additional radioactivity, the additional waste, those are real impacts that are basically left I unaddressed in the generic environmental impact statement for decommissioning. (AT-B19)
I Response: If a MOX Fuel program is adoptedin this country then it may be consideredin the I next Supplement to the GELS. However, at the present time the use of MOX fuel is speculative I at best. The comment did not provide new information relevant to this Supplement and will not I be evaluatedfurthers. The comment did not result in a change to the Supplement.
I Comment: The Oconee plant, which I'm near, which we've gone to visit, it scares me. I mean I the reactors look like they're really solid. One thing they're going to do is cut into the wall to I take-to change the steam generator. They're only going to put it back and somehow-is it I going to be as strong as it was before? (AT-D/8)
I Response: The replacementof a steam generatorat an operating facility is outside the scope I of this Supplement. The comment did not provide new information relevant to this Supplement I and will not be evaluated further. The comment did not result in a change to the Supplement.
I Comment: It has come to my attention that the Nuclear Regulatory Commission is possibly I compromising the security of our nation's future by making way for further build up of nuclear I waste that will theoretically be safe in so many thousands of years. (CL-41/1)
I Response: Spent fuel maintenance and storage are outside the scope of this Supplement as I discussedin Section 1.3, "Scope of this Supplement." The comment did not provide new I information relevant to'this Supplement and will not be evaluated further. The comment did not I result in a change to the Supplement.
NUREG-0586 Supplement 1 0-296 November 2002
Appendix P Public Meeting Transcript Excerpts and Written Comments
Contents
- 1. Transcript of the Public Meeting on December 4, 2001, in San Francisco, California .............................................. P-1
- 2. Transcript of the Public Meeting on December 6, 2001, in Chicago, Illinois .................................................... P-14
- 3. Transcript of the Public Meeting on December 10, 2001, in Boston, Massachusetts .............................................. P-31
- 4. Transcript of the Public Meeting on December 12, 2001, in Atlanta, Georgia .................................................... P-38
- 5. Comment Letters ...................................................... P-75 November 2002 P-iii NUREG-0586, Supplement 1
Appendix P
- 1. Transcript of the Public Meeting on December 4, 2001, in San Francisco, California
[Introduction, Mr. Cameron]
[Presentation by Mr. Scaletti]
[Presentation by Ms. Hickey]
[Questions answered by Mr. Sackschewsky]
[Questions answered by Mr. Masnik]
[Questions answered by Mr. Zalcman]
SF-A Mr. Sokolsky: David Sokolsky with Humboldt Bay Power Plant.
SF-A-i Will this Supplement replace entirely the previous NUREG-0586?
Mr. Scaletti: It will replace in entirety -- or it's a standalone document for nuclear power reactors, yes.
Mr. Sokolsky: Okay.
Mr. Scaletti: The other facilities within -- NUREG-0586 is still applicable to those facilities.
Mr. Sokolsky: All right. That was my understanding in looking at this Draft Supplement, that anything from the previous NUREG is included in the Supplement that's applicable.
Mr. Scaletti: That's correct.
Mr. Sokolsky: So when we respond we no longer have to look at the previous issue, just this Supplement.
Mr. Scaletti: That is correct.
Mr. Sokolsky: Okay. Thank you.
SF-B Ms. Cabasso: My name is Jackie Cabasso. I'm the Executive Director of the Western States Legal Foundation.
SF-B-1 And I have a question for Eva which is that in reaching your findings about these impacts, these environmental impacts, the generic issues and impacts, I'm wondering what the baseline you were using was to measure those impacts against.
November 2002 P-1 NUREG-0586, Supplement 1
I Appendix P In other words, were you comparing the impacts to the site before the nuclear facility was built or during its peak operating period? And in that case were the impacts considered cumulative or standalone?
Ms. Hickey: Okay. Let me make sure I understand your question. You want to know what the baseline was that we were evaluating against -
Ms. Cabasso: Um-hum.
Ms. Hickey: -- and then whether we looked at the impacts cumulatively.
Ms. Cabasso: Urn-hum.
Ms. Hickey: What we were comparing against was, we would look at the impacts that were identified in any previously-written environmental impact statements, final environmental statements that the licensee had published, and any other environmental assessment that had been conducted during the operation.
So we were weren't necessarily looking at the impact; we were looking at the way the impacts might change from during operation, not necessarily from the way the plant was prior to operation. So we were comparing those impacts with other environmental impact statements that had previously been written.
And, yes, we did look at cumulative impacts.
SF-B-2 Ms. Cabasso: Now just could you elaborate on that a little bit? Because what I was asking you was then cumulative impacts in terms of the plant during its operating period with the decommissioning activities added onto it, or do you mean something else?
Ms. Hickey: Well, we looked at it in a variety of ways. We would look at whether the impacts from all of the activities -- well, okay. The radiological was kind of an easy one to establish.
The impacts from all of the activities individually and then how cumulatively the radiological impact to the environment would end up.
We also looked at them across the issues, so we would look at activities -- at an activity and see -- I'm sorry. I'm having a hard time describing this. But we would look at them from -- at an activity and then look at water quality and how water quality might impact potentially air quality or any of the other issues. So from that perspective we looked at it cumulatively across all the issues.
NUREG-0586, Supplement 1 P-2 November 2002