ML19311C737
| ML19311C737 | |
| Person / Time | |
|---|---|
| Site: | San Onofre  |
| Issue date: | 09/23/2014 |
| From: | Public Watchdogs |
| To: | Division of Decommissioning, Uranium Recovery and Waste Programs |
| Cruz Z | |
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| Download: ML19311C737 (40) | |
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Collier Shannon Scott Co.ir Shataa SCOan.it United States Nuclear Regulatory Commission (Is December 31, 2001 0
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WO5 KtSi."i. NW DC2zOs-s10a Page 2 202.342 8400 1iL Collier Shannon Scott 202 342 $4SI FAX based on recycled scrap metal In a recent study commissioned by the National Recycling r ""7 MIXL Wt.,bat 202 342 8*54 Coalition, R W. Beck, Inc reports that combined ferrous and nonferrous metals recycling iiftnbocnw11ohmn .. m industry employment totals approximately 350,000 jobs, with a payroll in excess of $12 billion annually and receipts of approximately $90 billion All of the members of MIRC consume metal scrap to make new metal products The December 31, 2001 recycling of enormous tonnages of scrap by MIRC members provides substantial environmental benefits, including reusing material that otherwise would be discarded and conserving energy.
VIA COURIER AND ELECTRONIC MAIL The energy savings from the steel minimill industry alone in one year are enough to supply the energy needs of the city of Los Angeles for eight years. The recycling of scrap is a sophisticated, Chief technology-based industry, involving highly controlled scrap selection and blending processes to Rules and Directives Branch Division of Administrative Services meet detailed customer specifications A growing number of customers are setting specifications United States Nuclear Regulatory Commission that include certification of minimum radioactivity levels in metal components and products.
11545 Rockville Pike Rockville, Maryland The metals industries that MIRC represents strive to boost public confidence in the safety, strength and recyclability of metal products, and they invest significant time and Re: Draft Supplement to the Final Generic Environmental Impact Statement on resources in product promotion, sponsoring advertising, grass-roots initiatives, and educational Decommissionine of Nuclear Facilities, 66 Fed. Reg. 56,721 (Nov. 9, 2001) activities. Moreover, all of the metals industries expend considerable resources on research regarding the effects of metals on human health and the environment, with an emphasis on Dear Sir or Madam" creating safer products.
The Metals Industries Recycling Coalition ("MIRC') submits the following comments on draft Supplement I to the United States Nuclear Regulatory Commission's ("NRC'S") "Generic In the metals business, scrap metal is a valuable feedstock that is bought and sold as a "4 commodity. Scrap accounts for a significant, if not the largest, portion of metals companies' Environmental Impact Statement on Decommissioning of Nuclear Facilities" ("the GEIS"),
0.. dealing with decommissioning of power reactors 66 Fed. Reg 56,721 (Nov. 9, 2001) The production costs Given that scrap metal has such a high value, the metals industries generally National Environmental Policy Act requires federal government agencies to complete a detailed support public policies that serve to increase the quantity of scrap metal available in the economy environmental impact statement for every "major" action that "significantly affects" the and actively promote recycling Scrap metal with residual radioactive contamination, however, environment. 42 U S C. § 4332(C) NRC will rely on this GEIS and the draft Supplement to including scrap metal that would be released from nuclear power reactor facilities in preparation meet its statutory obligation to prepare an environmental impact statement in future for and during decommissioning, would undercut efforts to protect the scrap supply from decommissioning activities radioactivity, and is not acceptable to the metals industries.
MIRC is concerned because the draft Supplement does not contain any meaningful discussion regarding the serious environmental, economic, and socioeconomic impacts of the II. METALS INDUSTRIES' RESPONSE TO RADIOACTIVITY radioactively contaminated scrap metal that would be released into the economy from facilities preparing for and undergoing decommissioning Such releases would affect the metals Since the 1980s, metals companies have been installing and using sensitive, highly industries' ability to recycle scrap metal and threaten the economic viability of metals sophisticated radiation detection systems Metals producers also have developed sophisticated companies MIRC urges NRC to consider these impacts when preparing the final Supplement to monitoring protocols and procedures to ensure that they do not inadvertently allow contaminated the GEIS. scrap metal, including sealed sources that have escaped NRC regulation, to enter their mills. The metals industries' objectives in doing this are to protect workers and consumers and to prevent I. TIlE METALS INDUSTRIES RECYCLING COALITION radioactive contamination in their mills. Inadvertent meltings of sealed sources can contaminate products, waste streams, mill. equipment and the surrounding property. Radioactive MIRC is an ad hoc coalition of metals industry trade associations comprised of the American Iron and Steel Institute ("AISI"), the Copper and Brass Fabricators Council ("CBFC*), contamination has caused individual metals companies to incur tens of millions of dollars in zC: the Nickel Development Institute ("NiDl"), the Specialty Steel Industry of North America
("SSINA"), and the Steel Manufacturers Association ('SMA") The metals industries comprise a R.W. Beck, Inc., US Recycling Economic Information Study (July, 2001) at ES-6, Figs.
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CD clean-up and decontamination costs, per incident. These incidents can bankrupt individual the sum of allowable internal and external doses to individual members of the general public to metals companies. Metals companies have a financial interest in keeping radioactivity out of 0 1 remn per year. NUREG-0586 at 4-26 (Allowable doses to individual members of the public their mills, and have set their detectors to detect at or slightly above background radiation levels, following license termination are limited to 25 milliremi per year during the control period and to protect against the possibility of sealed sources ending up in the melt. Accordingly, scrap 100 millirem per year after the end of institutional controls. See 10 C.F.R. § 20 1402 ) As metal that sets off metal company radiation detectors is rejected discussed in the previous section, 10 C.F.R. part 20 does not contain any release standards for CL-0313 solid materials. Although it is not certain, a strong possibility exists that power reactors could Ill. NRC'S RELEASE GUIDANCE release scrap metal that has a serious impact on the environment, such as by contaminating the soils or groundwater underneath a scrap yard or by escaping detection and becoming melted CL-03/1 Since at least as early as 1974, NRC has espoused a policy of "unrestricted release" of inadvertently in a metal company furnace. Furthermore, certain isotopes in scrap metal that solid matenials, including scrap metal, from nuclear fuel cycle facilities, without any specific, health-based release crnteria. Unlike NRC requirements applicable to gaseous and liquid releases escape detection before melting may accumulate and concentrate in emission control systems at from nuclear facilities, there are no specific criteria govemning releases of solid materials by metals company facilities, to the extent that metals producers could generate low-level wastes licensees. Requests to release solid material are approved on a case-by-ease basis using existing ("LLW") or mixed wastes.
regulatory guidance and license conditions.
CL-03/4 Even if NRC eventually does establish dose-based clearance standards for solid materials, The regulatory guidance is a generic, five-page document entitled "Regulatory Guide thousands of tons of scrap metal with residual radioactive contamination still would be released 1 86, Termination of Operating Licenses for Nuclear Reactors" ("Reg Guide 1.86"). Reg. Guide into the economy or sent to LLW or industrial waste landfills. If the scrap is released for reuse in 1 86 was published in 1974, without public notice and comment, by NRC's predecessor agency, the economy, it could have a devastating effect on metals recycling. The introduction of added the Atomic Energy Agency. Under Reg. Guide 1.86, nuclear fuel cycle facilities are allowed to radioactivity in the scrap supply would make it difficult or impossible for metals producers to release for unrestricted use solid materials that meet "acceptable surface contamination levels." meet certain product specifications. Customers who require their metals components to be free C) See Table 1, Reg. Guide 1.86 These "acceptable" contamination levels are based on surface of radioactivity are driven by consumer demand for safe products and by the necessity in 0o activity as measured in disintegrations per minute. They are based on the detection technology sensitive applications, such as in computers, for the metal to be radiation-free readily available in 1974 and not on public health or environmental considerations The measurements in disintegrations per minute have no bearnog on. doses to the public or exposure, The mere possibility that products made with recycled metals may contain materials that nor do they account for the impact of the radioactive contamination on metals industry were released from nuclear facilities could cause a significant number of consumers to purchase operations consumer goods made of substitute materials. A survey commissioned by the Steel Alliance found that 61 percent of Americans believed it would be a bad decision (42 percent said "very Under Reg Guide 1.86, nuclear fuel cycle facilities do not have to employ the same level bad") to allow steel from closed down nuclear facilities to be recycled into the mainstream of screening for small amounts of residual surface activity that metals companies must use to production of new steel products. 2When those who opposed the idea of recycling radioactive keep radioactivity out of their mills. Scrap released pursuant to surface activity levels in Reg scrap metal were asked if they would change their mind if they were assured that the material Guide 1 86 has caused radiation detectors at metals company facilities to alarm when no sealed met government safety standards, they remained skeptical, with 74 percent continuing to oppose sources were present. In short, a load of scrap metal that is acceptable for a power reactor such recycling (and 51 percent saying it would be a "very bad" decision). If radioactive scrap facility to release is not an acceptable feedstock for metals company manufacturing operations w.ere recycled into the manufacturing of new steel, three out of four Americans (73 percent) said IV. THE DRAFT SUPPLEMENT they would be less likely to purchase food products packaged in steel cans; 62 percent would be less likely to purchase a steel-framned house; and half (53 percent) would be less likely to A. Environmental Impacts purchase an automobile made of steel. Finally, survey respondents' favorable impression of steel before and after discussing the potential introduction of steel from nuclear facilities being NRC's intent in producing this Supplement was "to consider in a comprehensive manner recycled into everyday products plunged 24 points on a 100-point rating scale,, from all aspects related to the radiological decommissioning of reactors." NUREG-0586 Draft Supp. 1 CL-03/2 at xi (Oct. 2001). Yet, the Supplement does not discuss the potential environmental impacts of 2 The survey was conducted by Wirthlin Worldwide, an independent research firm, and releasing scrap metal or other solid materials pursuant to NRC's unrestricted release guidance, involved polling of four focus groups followed by a phone survey of 1,007 individuals.
except to state that licensed facilities must comply with standards in 10 C F R. part 20, limiting 3 Oil the 100-point scale, a score of 50 indicates a neutral opinion, above 50 a positive opinion, and below 50 a negative opinion.
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C) 0 Collier Shannon Scott United States Nuclear Regulatory Commission Collier Shannon Scott United States Nuclear Regulatory Commission December 31, 2001 December 31.2001 Page 6 Page 5 approximately 68 to 43.6. Hence, the impression of steel went from solidly positive to negative serious problem for the suppliers and transporters, who must manage and arrange for the ultimate disposition of the rejected scrap It would have a similarly enormous adverse impact on the as a result of the radioactive scrap recycling issue.
smaller producers, foundries, scrap dealers and processors, fabricators, and end product manufacturers Metals companies experiencing several alarms daily would continue to incur Therefore, it is not implausible to expect that retail consumers would demand enormous costs, either unfairly increasing their manufacturing costs or compelling them to raise certification that their products are made with mined virgin ores or would eschew metal detection levels to above background, thereby exposing themselves to increased risk of consumer products altogether. This consumer reaction, coupled with the fact that many sensitive inadvertently melting sealed sources Receipt of even slightly elevated levels of radioactively applications, like computer components, require radiation-free metal, would lead manufacturers contaminated scrap imposes enormous costs on metals companies.
to demand that the metal they purchase be free of residual radioactivity. This result would be a marked reduction in metals recycling rates and an increase in consumption of virgin mined ores. 2. Impact on Consumer Perception of Metal Products Thus, the introduction of added radioactivity into the scrap stream would undermine the environmental contributions made each year by recycling scrap metal The unrestricted release of radioactively contaminated metal for recychng'would tarnish the perception of recycling as a social good that should be encouraged Aversion to perceived B. Economic and Socioeconomic Impacts radioactive risk could lead consumers to avoid products made of metal, especially those with a the recycled metal content. Metals recycling industries have worked hard to build public confidence CL-03/5 The draft Supplement discusses the economic impacts of decommissioning, including in the safety and utility of products made from recycled metal. This confidence would be lost if fact that the Barnwell Low-Level Radioactive Waste Management Disposal Facility in South the public, rightly or wrongly, perceives such products to be unsafe. For this reason, metal Carolina, the last remaining facility to dispose almost all classifications of LLW, is scheduled to companies have not, and will not, accept scrap that is known or perceived to be radioactively stop accepting LLW from all NRC licensees except those in the Atlantic Compact, by 2009. Id contaminated 0 at 4-43 Yet, decommissioning of most nuclear power reactors is not expected to occur until
=,,0 after 2009. The existence of the EnviroCare disposal facility in Utah, which can accept Class A The public's perception is that any level or type of radioactivity is unsafe, official wastes for disposal, mitigates the economic impact of losing Barnwell, but nuclear power plant assurances to the contrary notwithstanding. The public, including workers at metals companies, operators still are expected to incur significant waste disposal costs. The Supplement discusses will neither understand nor accept the release of radioactively contaminated scrap from nuclear how these costs are passed on to electricity customers. The Supplement also analyzes the facilities and its use as a feedstock in the manufacture of consumer products socioeconomic impacts of decommissioning with respect to the communities surrounding power reactors. These impacts include direct and indirect job losses, losses in tax revenues and Accordingly, MIRC urges NRC to look at all of the economic consequences (I e, lost reductions in local governments' ability to pay for public services Id. at 4 4-53. Yet, the CL-03/7 sales, employment reductions, and losses in sales by suppliers of equipment, materials, and draft Supplement does not discuss the economic and socioeconomic impacts on the metals services to metals industries) to be incurred by the metals industries and allied sectors, as well as industries related to the release of radioactively contaminated scrap metal into the economy. the losses in tax revenues to be incurred by governmental entities I. Impact on Metals Company Operations 3. Incentives for Unrestricted Release To prevent sealed sources from contaminating their operations, metals companies have The economic and socioeconomic impacts of decommissioning, coupled with the lack of CL-03/8 installed sophisticated radiation detection systems and monitor all incoming shipments of scrap health-based release criteria using dose-based standards, create a disturbing incentive for the metal for radioactivity. When a radiation detector alarms, the metals company responds, nuclear power industry to release as much surplus metal as it can into the economy and market it typically by rejecting the load of scrap or hand sorting it to determine where the radioactive as useful material, rather than incurring additional disposal costs when the scrap metal meets z contamination is located This causes metals companies to incur significant costs. Often metals general regulatory release guidelines but may contain levels of residual radioactivity C producers stop the production process whenever the radioactivity is detected, to take appropriate unacceptable to metals producers. NRC's recognition of these economic and socioeconomic measures. including rejecting the load of scrap outright. These measures are necessary but impacts and its concurrent failure to consider the impacts of contaminated scrap metal on the
- 0 impose unreasonable costs on the metals industries. metals industries create the mistaken impression that the agency has covered all of the significant impacts of decommissioning Co
- 0) CL-03/6 The release of scrap metal from power reactors undergoing decommissioning will present a far more insidious problem than orphan sources, by greatly increasing the volume of co CD radioactive scrap arriving at, and the frequency of alarms at, metals companies This poses a CD
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CD V. CONCLUSION CL-03/9 MIRC appreciates the opportunity to comment on the draft Supplement and urges NRC to consider in the final Supplement to the GEIS the environmental impacts of releasing radioactively contaminated scrap metal into the economy for unrestricted use, as well as the economic impacts on the metals industries and related socioeconomic impacts.
If you have any questions, please contact us Sincerely.
John L. Wittenborn Christina B. Parascandola z0 CD 3
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Maine Yankee Comments on NUREG-0586 Draft Supplement I "Generic Environmental Impact Statement (GETS) on Decommissioning 6sF / of Nuclear Facilities" Mr. H. J. Miller, NRC Regional Administrator, Region I December27, 2001 MN-01-049 RA-01-190 I, General Comments FILED ELECTRONICALLY TO NRC "dgeis [rc.gov" A. Supplement I represents a good effort by the NRC to update the environmental impacts of decommissioning based upon the actual experience encountered by nuclear facilities.
UNITED STATES NUCLEAR REGULATORY COMMISSION B. The Supplement sometimes deviates from this intent of considering impacts related to the Attention. Chief, Rules and Directives Branch Division of Administrative Services C,,
radiological decommissioning, by delving into activities and impacts related to the Mailstop T 6 D 59 removal of uncontaminated structures, systems, and components such as intake structures Washington, DC 20555-0001
- 0) or cooling towers. While the consideration of these impacts may be useful and helpful, these considerations should be properly annotated with a caveat that these activities are
Reference:
(a) License No DPR-36 (Docket No 50-309) beyond NRC's decommissioning jurisdiction.
(b) NRC Notice of Availability of the Draft Supplement to the Final Generic Environmental Impact Statement on Decommissioning of Nuclear II. Comments Related to Section 4 Environmental Impacts Facilities and Notice of Public Meetings, 66FR56721, dated November 9, 2001 CL-04/3 A. 4.3.4 Air Quality, (4.2A.2) pg. 4-14, last para., last full sentence: This statement Maine Yankee Comments on NUREO-0586 Draft Supplement I *Generic indicates that in most cases the number of shipments of other materials (non-radioactive
Subject:
Environmental Impact Statement (GElS) on Decommissioning of Nuclear Facilities" materials) will be small compared to those for LLW. This is not necessarily the case for a
"-U plant which is removing all above grade facilities. However, this fact should not affect CL-04/1 Overall, Maine Yankee (MY) believes that the Supplement provides a fair update of the sections the conclusion that the air quality related environmental impacts for these activities will of the 1988 NUREG versions relating to pressurized water reactor, boiling water reactors, and be small.
CL-04/2 multiple reactor stations. However, while the stated intent of the Supplement is to consider in a comprehensive manner all aspects related to the radiological decommissioning of nuclear reactor CL-04/4 B. 4.3.5 Aquatic Ecology (4.3.5.4) pg. 4-19, 1" para., last sentence. This conclusion would facilities, the Supplement sometimes deviates from this intent by delving into activities and result in site-specific analyses for the use of areas beyond the previously disturbed areas if impacts related to the removal of uncontaminated structures, systems, and components such as there is a potential to impact the aquatic environment. The vagueness of the condition intake structures or cooling towers While the consideration of these impacts may be useful and "potential to impact' could be result in a site-specific analysis for any potential no matter helpful, their inclusion without proper caveat may tend to blur the line of NRC junsdiction. how remotely possible. The NRC should consider rewording the condition to say "there Attached are some specific comments on the draft NUREG Supplement. We appreciate the is expected to be or likely to be an impact" Also on the previous page (pg. 4.18 last para opportunity to provide comments. If you have any questions with regard to our comments, in section 4.3 5.2,) it appears that a site-specific assessment would be required merely if please contact me. the aquatic environment has not been characterized. NRC should clarify that a site specific EIS is not necessary just because the lack aquatic environment characterization, Sincerely, but rather, if an area beyond the previously disturbed area is to be used'and no associated characterization'of the aquatic environment, if applicable, exists, then such a OriginalSigned by Michael A. Whitney for TLW characterization should be conducted. Then as stated above, if there is expected to be or likely to be an impact to the aquatic environment, then a site-specific analysis should be Thomas L. Williamson, Director Z Nuclear Safety and Regulatory Affairs conducted.
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011 c: Mr. M. K. Webb. NRR Project Manager CL-0415 C. 4.3.6 Terrestrial Ecology (4.3 6.4), pg. 4-23, last para in section 4.3.6 4, last sentence.
Mr. C.L Pittiglio. NRC NMSS Project Manager, Decommissioning This should be reworded to be the same as section 4.3.5 4 as modified in the comment Mr. R.Ragland, NRC Region I above.
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6 Maine Yankee Comments on NUREG-0586 Draft Supplement 1 Maine Yankee Comments on NUREG-0586 Draft Supplement 1 0 "Generic Environmental Impact Statement (GEIS) on Decommissioning (n "Generic Environmental Impact Statement (GEIS) on Decommissioning of Nuclear Facilities" of Nuclear Facilities" CD Decommissioning 9
- 1. G.2.2 Dose to Members of the Public CD CL-04/6 D. 4.3.7 Threatened and Endangered Species (4.3.7.4), pg. 4-25, last para., last sentence.
This conclusion indicates that the NRC will meet its responsibilities on a site specific CL-04/12 a. Pg. G-21, Table G. 15 Summary of Effluent Releases Comparison of Operating Facilities and Decommissioning Facilities basis during any decommissioning process, but it does not specify how the NRC will The values associated with the maximum, minimum and average gaseous meet its responsibilities or what information it will need from licensees.
effluents for the Decommissioning Reactors do not add up. The Fission and Activation Gasses for gaseous effluents are incorrectly all the same for the CL-0417 E. 4.3.8 Radiological (4.3.8.3). pg. 4-29, 4 " full para., last sentence. Maine Yankee agrees maximum, minimum and average in each category (PWR & BWR). It appears that it is not necessary to update the estimates for exposure found in the 1988 GELS.
that theminimum category for Decommissioning PWR's is Maine Yankee. If so, the minimum value for Fission and Activation Gasses for gaseous effluents should CL-04/8 F. 4.3.13 Environmental Justice (4.3.13.4), pg. 4-57, last para., last sentence. This be "none detected". Making this correction appears to make the table added up conclusion indicates that licensees will need to provide appropriate information related to assurmng a PWR population of two.
environmental justice as part of the environmental portion of the PSDAR, but it does not CL-04/13 b. Pg. G-22, Table G- 16 Summary of Public Doses from Operating and specify what kind of information is needed or what evaluation criterion should apply. Decommissioning Facilities This table is not well formatted and difficult to interpret. The table mixes the CL-04/9 G. 4.3.14 Cultural, Historical and Archeological Resources (4.3.14.4). pg. 4-61. last collective dose in person-rem with the individual dose in mrem. The years of paragraph in section 4.3.14.4, last sentence. This conclusion indicates that the NRC will concern are assorted. We suggest that the table be simplified and either further meet its responsibilities on a site specific basis during any decommissioning process, but discussed in the Section G.2.2 text or eliminated. The following is Maine it does not specify how the NRC will meet its responsibilities or what information it will
-D Yankee's data on individual public doses from Maine Yankee's effluents for need from licensees.
1998, 1999 & 2000:
N, Maine Yankee Effluent Data 1998 1999 2000 CL-04/1 0 H. 4.3.17 Transportation This section does not seem to give sufficient attention to licensees that ame removing all above grade structures from the site and transporting all of the above Liquid Effluents grade concrete offsite. The volume of concrete for PWR DECON is much to low for this Total Body (mrem) 1.2E-2 1.5E-3 9.6E-3 situation by a factor of three or four. Provided below is Maine Yankee's update of its Critical Organ (mrem) 4.3E-2 2.9E-3 1.8E-2 LLW Volume information. This information is consistent with Maine Yankee's License Gaseous Effluents Termination Plan Revision 2. This waste volume is greater than that assumed in the Critical Organ (mrem) 5.0E-3 5.3E-3 4 3E-3 GELS. However, even with the increased LLW Volume associated with the removal of Beta Air (mrad) ND* ND* ND*
all above grade concrete, Maine Yankee's estimates of public dose is still less than that Gamma Air (mrad) ND* ND* ND*
assumed in the draft supplement or the 1988 GEIS because of the extensive use of rail
- None Detected transportation.
III. Comments Related to Maine Yankee Data Maine Yankee will be reviewing and updating all uses of Maine Yankee data including:
CL-04/11 A. 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))
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CL-04/15 D. Appendix K Transportation Impacts, pg. K-2, Table K-i Low-Level Waste Shipment Data for Decommissioning Nuclear Power Facilities ILLW Volume for Maine Yankee is indicated as 5920 cubic meters. The Maine Yankee LTP Rev. 2 states: 31,924 cubic meters for transport and 26,920 for disposal after processing)
IV. Typographical/Editorial and Other Conmments and Activation in an CL-04116 A. 3.1.4 Formation and Location of Radioactive Contamination Operating Plant, pg. 3-15 This description should include the activation of corrosion "1
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S CL-04/17 B. 3.3.3 Decommissioning Process pg. 3-29, 2 d full para. This paragraph is redundance to the preceding and the seceding paragraphs and can be deleted in its entirety.
CL-04/18 C. 4.3.5 Aquatic Ecology (4.3.5.2), pg. 4-17, 1" para in section 4.3.5.2, 4' sentence, "Aquatic environment s" should be corrected.
CL-04/19 D. 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."
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12/28/01 11 09AM NEI Comments on Draft Supplement 1 0 December 28, 2001 Page 2 3
CD Attached are NEI's comments. They are also being sent by mail--phg Paul H. Genoa NUCLEAR ENERGY INSTITUTE Nuclear Energy Institute Phone. (202) 739-8034 James W. Cavis Fax: (202)785-1898 OPERATIONS IIECT-OR.
E-Mail: phg@nei.org " "1 NUCLEAR GENERATION tI December 28, 2001 Chief, Rules and Directives Branch C) Division of Administrative Services U. S. Nuclear Regulatory Commission Mail Stop T6-D59 Washington, DC 20555-0001 SUBJECT. Industry Comments on Draft Supplement 1 to the Generic Environmental Impact Statement (GEIS) on Decommissioning of Nuclear facilities The Nuclear Energy Institute (NEI) appreciates the opportunity to provide the following comments on behalf of the nuclear industry. The industry attended all four public meetings held by the NRC on the draft GEIS to offer comments in support of the document. While the industry identified technical corrections or additions to improve the accuracy of the document, they do not alter the conclusions reached in the evaluation.
Draft supplement 1 represents a useful update of the environmental impacts of CL-05/1 decommissioning based upon over 200 facility-years' worth of actual decommissioning experience accumulated by nuclear facilities since the NRC published the initial GEIS in 1988. NEI concurs with the GEIS conclusions, which found that for the t...environmental issues assessed, most of the impacts are generic and SMALL for all plants regardlessof the actwittes and identified variables..."
NEI commented in the scoping process that potential environmental impacts associated with the rubblization concept be analyzed in the GEIS Supplement. The non-radiological impacts are assessed, however "...the staff
,2,a '493 has determined that Rubblizatwon, or on-site disposal ofslightly contaminated Z g- ox,- _e9l material,would require a site-specific analysisand the radiologicalaspects of the activity would be addressedat the time the license terminationplan is CD 1q.
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CL-05/2 In order to ensure that the radiological aspects of this activity are assessed CL-05/3 Executive Summary. page xiv. line 20 - references 10 CFR 50.82(a)(6)(ii) which consistently, NEI recommends that standard dose modeling assumptions be states that the licensee must not perform any decommissioning activity that causes documented directly through the Q&A process associated with the NRC guidance any significant environmental impact not previously reviewed. The supplement at consolidation project. page 1-8 beginning on line 23 defines three levels of significance SMALL, Specific comments on the draft are provided in the attachment. They are provided 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 to improve the accuracy of the data included in the draft, however they do not alter the conclusions documented in the supplement. several Environmental Issues, e g. threatened and endangered species are listed as site-specific.
Once again, NEI appreciates the opportunity to provide these comments. If you have questions concerning the enclosed comments, please contact me at (202) 739. Comments on GEIS Section 3:
8105 or Paul Genoa at (202) 739-8034.
CL-05/4 Section 3.1.3. p 3 add 'The systems described are typical and may differ at Sincerely, specific facilities." to end of the 1' paragraph.
Section 3.1.3. n 3-10. 1" parserach - add "or similar document" following (ODCM)",
-=u CL-0515 since limits may be in Technical Specifications rather than an ODCM. Also, the 01 James W. Davis 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.
PHG/maa Enclosure Section 3.1 3. v 3-13. last varamranh- shipment of contaminated apparatus or CL-05/6 hardware may also occur to support specific activities.
CL-05I7 Section 3.1.3. v 3-14. 1iAparaeragh - shipment may also occur on barges or other ships.
CL-0518 Section 3.1 4. p 3-15, last paragraph - clarify whether the last sentence is referring to radiation exposure during decommissioning or operation. In context, the inference is that the activation products provide the main source of radiation exposure to plant personnel in an operating plant, but typically contaminated materials provide more exposure to plant personnel during operation.
z CL-05/9 Section 3.2. p 3 the definition of SAFSTOR should more clearly define that it M includes the final decontamination of the facility. This would be more consistent with definitions used elsewhere.
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to P) CL-O5/10 Section 3.2 v 3 defines two ENTOMB options developed specifically extreme cases envelope a wide range of potential options by describing two possible Section 4 3 7- Pa. 4-25. last paraeranh - This conclusion indicates that the NRC C of entombment. These extremes are useful in bounding an analysis, however they CL-05/16 will meet its responsibilities on a site specific basis during any may be inappropriate for analysis to support a potential rulemaking for this option.
"CD decommissioning process, but it does not specify how the NRC will meet its responsibilities or what information it will need from licensees.
CD Comments on GEIS Section 4:
CL-05/17 Section 4 3 13. Ug. 4-57, last paragranh - This conclusion indicates that licensees CL-05/11 Section 4.3.4.2. p 4-14. 2'd pararraph - not all decommissioning sites have or will will need to provide appropriate information related to environmental justice have building ventilation systems, especially those that are in SAFSTOR for many as part of the environmental portion of the PSDAR, but it does not specify years. Temporary systems will be established, as needed, for gaseous effluents what kind of information is needed or what evaluation criterion should apply.
during decommissioning if installed systems are no longer functional.
CL-05118 Section 4.3.14. nr. 4-61. last naraganh - This conclusion indicates that the NRC Monitoring of air quality is not necessarily performed during the storage period, will meet its responsibilities on a site specific basis during any depending on activities, storage period and source term. decommissioning process, but it does not specify how the NRC will meet its responsibilities or what information it will need from licensees.
end of the CL-05/12 Section 4.3.4.4. R 4-16. V' zararanh - add the following sentence to the paragraph: 'Particulates produced by decommissioning activities within buildings CL-05/19 Section 4,3.17 Vr. 4 This section does not seem to give sufficient attention to will be filtered as needed so that air quality impacts will be small." licensees that are removing all above grade structures from the site and transporting all of the above grade concrete offsite. The volume of concrete CL-05/13 Section 4 3 4 Piz, 4-14. last paragraph - This statement indicates that in most for PWR DECON is much to low for this situation by a factor of three or four
-U cases the number of shipments of other materials (non-radioactive materials) based recent experience.
will be small compared to those for LLW. This is not necessarily the case for 0) a plant that is removing all above grade facilities. However, this fact should not affect the conclusion that the air quality related environmental impacts for these activities will be small.
CL-05/14 Section 4.3.5 oR.4-19. 10 pararraoh - This conclusion would result in site specific analyses for the use of areas beyond the previously disturbed areas if there a potential to impact the aquatic environment exists. The vagueness of the condition "potential to impact" could be result in a site-specific analysis for any potential no matter how remotely possible. The NRC should consider rewording the condition to say "there is expected to be or likely to be an impact" Also on the previous page (pg. 4-18 last paragraph in section 4.3.5.2,)
it appears that a site-specific assessment would be required merely if the aquatic environment has not been characterized. NRC should clarify that a site specific EIS is not necessary just because the lack aquatic environment characterization, but rather, if an area beyond the previously disturbed area is to be used and no associated characterization of the aquatic environment, if applicable, exists, then such a characterization should be conducted. Then as stated above, if there is expected to be or likely to be an impact to the aquatic environment, then a site-specific analysis should be conducted.
CL-05/15 Section 4 3 6. Dr 4-23. last varavraoh - This section should be reworded as in Z
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To: "dgets @ nr gov' <dgels@ nr gov Date: 12/21101 9 48AM Sublect: Bechtel Comments on NUREG-0586. Draft Supplement I December 21, 2001 VIA E-MAIL TO DGEIS(tNRC GOV Chief, Rules and Directives Branch Division of Adrinistrative Services Mai Stop TO 059 US. Nuclear Regulatoty Commission Washington. DC 20555-0001 Subject Public Comment on Draft Supplement to the Final Generic Environmental Impact Statement on Decommlsslonlng of Nuclear Facilities, 66 Fed Reg t'J 56721
Dear Sir or Madam:
on draft
- ) ..- The purpose of this letter Isto provide Bechtel Power Corporations comments on Supplement I to NUREG-0586. "Final Generic Environmental Impact Statement 10 Decommissioning of Nuclear Facilities."
CL-06/1 Table 4-1 provides estimates of cumulativethe occupational dose for decommissioning reactors (comparison of 1988 GElS to new estimates
"-4 order to reflect the conclusions of Section compiled for draft Supplement 1) In 4 3 8. ItIs recommended that a note be added to Table 4-1 to clarfy that these to estimates of cumulative occupational dose are generic and are not intended be site-specific limits Comment #2 Out-of-scope activities are Identified and discussed In Section I and Appendix D.
be CL-06/2 It Is recommended that "Interlm Storage of Greater Than Class C Waste" also In identified as an out-of-scope activity, consistent with the final rule published Federal Register Vol. 66, Number 197, dated October 11,2001.
Comment #3 of, CL-06/3 Section 4 3 9 and Appendix I discuss the potential for, and consequences 'As postulated radiological accidents. On page 1-2 of Appendix I, the text states, several of a result of Improvements In the technology used for decommissioning, lower the accidents listed In Table 1-2 may now be considered to be of a much z probability or, at the least, to result In much-reduced consequences
- Itis recommended that the text be revised to Identify typical technology M
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-M U.S. Nuclear Regulatory Commission December 21, 2001 Page 2 Improvements. For example, some of the plants currently undergoing decommissioning Intend to use single failure proof cranes to preclude the potential for certain postulated spent fuel cask drop or heavy load drop accidents.
Thank you for the opportunity to review and provide comments on draft Supplement I to NUREG-0580. Should you have any questions on the comments, please contact me at (301) 228-6245.
Sincerely, Stephen D.Routh Manager of Regulatory Affairs z"0 Co Co
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December 27, 2001 Sent via certified mail Emailed to dreis@nrc gov nuclear reactors will eventually be decommissioned in many states the public should be given Chief of Rules and Directives Branch more than just four locations nationwide to voice their concerns. Public meetings should also be Div. of Administrative Services held in communities neighboring currently existing nuclear power plants.
Mail Stop T 6 D 59 U S Nuclear Regulatory Commission Georgians for Clean Energy promotes the shutdown of our unsafe nuclear power plants here in Washington, D C. 20555-0001 Georgia and the phase out of nuclear power nationwide. We also advocate for sound, systematic policymaking regarding decommissioning. We continue to oppose the NRC's method of RE: Draft Supplement I to NUREG-0586, Final Generic Environmental Impact Statement on handling nuclear industry issues "generically" and urge that site-specific environmental impact Decommissioning of Nuclear Facilities statements be conducted as each nuclear reactor approaches final shutdown.
COMMENTS OF GEORGIANS FOR CLEAN ENERGY Security Georgians for Clean Energy is a non-profit, statewide membership organization that has been working in Georgia for 18 years to protect air and water resources by changing how energy is CL-08/3 In light of September 11P it is now abundantly clear that nuclear materials are desired by terrorist organizations. Our nation's operating nuclear power plants represent terrorist targets, but so too produced and consumed. We are based in Atlanta, Georgia and have a field office in Savannah. does the nuclear waste they generate. Since a decommissioned nuclear power plant would have a greatly reduced security force, the closed plant could provide an easier opportunity for terrorists These comments and questions serve as a supplement to our oral statement made at the public to obtain nuclear materials. In the case of plants like Hatch that have outdoor storage of nuclear scoping meeting held in Atlanta. GA on December 12. 2001 (see attached). waste, the notion of a reduced security force is even more troubling. Georgians for Clean Energy again stresses the need for a full evaluation of security measures to be assessed prior to issuing a "Public Participation Concerns final GElS.
Co to effectively CL-0811 Georgians for Clean Energy remains concerned about the ability for the public Site-Specific Concerns participate in this and other nuclear related issues that impact Georgia's communities. Due to the tragic events of September I I* the Nuclear Regulatory Agency's (NRC) website was not CL-08/4 Georgians for Clean Energy does not believe that a generic environmental impact statement (EIS) available for a time and is currently severely scaled back, making public access to important regarding decommissioning of nuclear facilities is a sufficient tool for evaluating impacts borne background information very difficult or impossible. NRC staff mentioned at the public meeting to specific environments from decommissioning a nuclear power plant. After the explanation by CL-08/5 on 12112/01 that a full. top-to-bottom review of security concerns would be conducted. the NRC staff at the public meeting in Atlanta, we further disagree with the process of using the Georgians for Clean Energy urges that this review be done prior to the issuance of the final significance levels of SMALL, MODERATE, and LARGE for a variety of issues at a variety of generic impact statement for decommissioning (GEIS). locations to come up with a generic, one-word answer. The classifications are genenc in form, hard to understand, and it is difficult to figure out how the NRC came to those characterizations CL-08/2 Given the difficulty in accessing thorough and accurate information, including potentially even after NRC staff attempted to explain it at the public meeting in Atlanta. If the NRC it is relevant material such as the relicensing documents on Plant Hatch In South Georgia, we feel unwisely chooses to continue using this classification system, Georgians for Clean Energy urges important to both extend the public comment period until these documents can be made readily that, at a minimum, layman's terms be used to define the levels and the methods used to available and to provide more meeting locations to adequately gather public comments. Since categorize the issues.
Z Georgians for Clean Energy requests that the NRC require licensees undergoing or planningto r" CL-08/6 decommissioning to submit a new environmental assessment. We do not find it acceptable m give licensees the option of using "recent environmental assessments" G)
- 6) CL-08/7 Some nuclear plants, like Hatch, have overflowing volumes of nuclear waste that are now being co 0`
stored outdoors which impacts the environment and could affect decommissioning. The NRC CL-08/8 C,, 2 "CD
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the original has no experience in decommissioning nuclear reactors that have operated beyond nuclear power CL-08/9 40-year license period. Nor does the NRC have any experience decommissioning these plants that used plutonium bomb fuel, also known as mixed-oxide fuel (MOX). Again, factors, among others, must be incorporated in addressing the decommissioning of individual CL-08/14 The GAO report also highlights several uncertainties relating to the costs of decommissioning facilities. "Varying cleanup standards and proposed new decommissioning methods introduce additional uncertainty about the costs of decommissioning nuclear power plants in the Economic Concerns future. Plants decommissioned in compliance with NRC's requirements may, under certain conditions, also have to meet, at higher cost, more stringent EPA or state GElS adequately addresses CL-08/10 Georgians for Clean Energy does not believe that the standards. New decommissioning methods being considered by NRC, which involve costs. Though assurances were made at the public meeting in Atlanta that decommissioning adequate, real-world examples have proved otherwise. For instance, leaving more radioactive waste on-site, could reduce short-term decommissioning costs decommissioning funds are energy giants yet increase costs over the longer term. Moreover, they would raise significant technical in the current world of mega-mergers of electric utilities and sudden dissolution of and policy issues concerning the disposal of low-level radioactive waste at plant sites full such as Enron, there is little guarantee in place that companies will be able to pay for the plant Additionally, we are concerned that the method of decommissioning instead of in regulated disposal facilities. Adding to cost uncertainty, NRC allows costs of decommissioning. 2 years before their license is terrmnated--relatively late in the overall owners to wait until a nuclear power plant is determined more by the cost implicauons to the licensee than the decommissioning process--to perform overall radiological assessments to determine ramifications of leaving a contaminated site for the local communities. to whether any residual radiation anywhere at the site will need further clean-up in order meet NRC's site release standards. Accordingly, GAO is recommending that NRC SCL-08/111 An Associated Press news article from December 5, 2001, "Japanese power company begins dismantling country's oldest nuclear reactor," highlighted the enormous financial and technical reconcile its proposed decommissioning methods with existing waste disposal regulations in 0 concerns that Japan is facing regarding decommissioning, "Japan Atomic Power Co., which took and policies and require licensees to assess their plant sites for contamination earlier years the decommissioning process. (P.4-5) the Tokaimura plant off line in 1998, won't begin taking apart the reactor for another 10 It will because extremely high levels of radiation remain inside, said spokesman Eichi Miyatani.
communities.
completely dismantle the plant by 2017 and spend an estimated 92.7 billion yen (US$748 CL-08115 Georgians for Clean Energy is also concerned about economic impacts to the local as average by Georgia nuclear utilities million), Miyatani said." These monetary figures exceed those that were mentioned CL-08116 The NRC needs to pay attention to decommissioning costs proposed needed decommissioning cost estimates at the NRC's public meeting in Atlanta. during rate cases and other proceedings so them is not a situation created where much and maintenance is ignored simply because there was no regulatory attention to the monitoring Accounting Office, real cost of decommissioning.
CL-08/12 Furthermore, a report issued this December by the United States Government Could Be "NRC's Assurances of Decommissioning Funding During Utility Restructuring Improved-GAO-02-48,' brings to light many concerns about the lack of adequate funding Environmental Comments available for decommissioning activities. The following statement by the GAO makes it apparent that the NRC needs to improve, "However, when new owners proposed to continue CL-08117 Georgians for Clean Energy firmly believes that a site-specific analysis must be done and for each rigorous relying on periodic deposits to external sinking funds, NRC's reviews were not always individual nuclear plant. This includes the area of the site itself along with downstream NRC did not mentioned at enough to ensure that decommissioning funds would be adequate. Moreover, downwind regions and all areas within the ingestion radius of the facility. As we operate the always adequately verify the new owners' financial qualifications to safely own and the public meeting in Atlanta, there are already elevated levels of some radioactive contaminants review plants. Accordingly, GAO is making a recommendation to ensure a more consistent nearly 100 miles downstream of Georgia's Plant Hatch and Plant Vogtle.
process for license transfer requests." (P.4)
We are still concerned that the NRC mistakenly poses that decommissioningsites activities will have CL-08/1 8 CL-08/13 Georgians for Clean Energy requests that this extensive report be thoroughly reviewed by the a small impact on water quality or air quality. Construction and demolition across Georgia, did not come NRC staff, be printed in it's entirety as an appendix in the final GEIS as the report most of which do not have nuclear contaminants, contribute to the degradation of our rivers and issued, and that the recommendations by the GAO be studied and an enormous out before the draft GEIS was be air. Georgians for Clean Energy would like to know how the NRC determined that incorporated into the final GEIS. Additionally, the public participation process should project such as decommissioning an entire nuclear plant, which will involve the handling of z
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already requested a copy of the analysis that was done to make this determination, and since we CL-08126 Reactor sites are often contaminated to the extent that the location is made undesirable and make this available to the unsafe for future economic development. As we stated at the public meeting in Atlanta, have not received that analysis yet we continue to urge that the NRC the general public and us. Georgians for Clean Energy urges that site-specific studies be conducted. For example, can these economy of rural Georgia is much different from that of urban New York. How where economic CL-08/19 Additionally, a thorough analysis of groundwater impacts seems lacking. Given Georgia's impacts be treated generically? Some nuclear power plants are in urban settings aquifer, we request that a site-specific assessment of different that in rural areas that have little or no other major employer in current concern over the Floridan impacts could be much request that a more groundwater quality be conducted prior to decommissioning. Also, we the region.
the final EIS. As an thorough analysis of groundwater issues be researched prior to issuing the most recent data from state agencies, such as the Georgia example, the NRC should request Questions:,
"water wars" Environmental Protection Division, that are involved in negotiations regarding and Alabama. Spent between states-as in the ongoing dispute facing Georgia, Florida, CL-08/27 1. How will on-site, outdoor nuclear waste storage dumps, [also known as Independent Fuel Storage Installations-ISFSII like at Plant Hatch, be affected by decommissioning?
decommissioning be ttow will the licensee of an ISFSI be impacted by events that may happen during CL-08120 Georgians for Clean Energy requests that the "mbblization" method of or removed from the final EIS. Chopping up a plant and stonng it on site not only sounds decommissioning, i e. what if there is an accident nearby and the casks are damaged negligent of the fact that there are facilities designed, built and the site is rendered inaccessible?
ridiculous but also is grossly GAO report cited earlier in licensed to handle radioactive materials. A point supported by the of shipping nuclear later sale of thi CL-08/21 these comments. Georgians for Clean Energy does not promote the idea CL-08128 2. How will the facility licensee, in our case, Southern Nuclear, benefit fromafter NRC never told it's deemed waste all over the country and recognizes that nuclear plant owners and the nuclear plant's land to a new owner? Also, how will the land be tracked CL-08/22 nuclear waste dump. a release communities near nuclear plants that they were also accepting a permanent "safe" and the licensee sells it...especially in cases where there may be a leak or a devious example of it in Rubblization is an egregious assault on the public participation process and of radiation into the environment after the initial sale occurred? For instance, isn't
-u corporations casting aside those communities that supported them over the years. the best financial interest of the licensee, in our case Southern Nuclear, to use the fastest and and least expensive decommissioning option so that the license can be terminated industry or licensee of a plant was CL-08/23 Georgians for Clean Energy also opposes any efforts by the nuclear they can sell the land before deficiencies can be found in the manner in which a decommissioning nuclear plant to "recycle" radioactive materials for release into the decommissioned?
Instead, it should be marketplace. No facilities should be able to sell their demolition debris.
in a day dealt with as regulated nuclear waste since the bulk of the materials will be radioactively CL-08/29 3. How is the funding of decommissioning costs guaranteed to be met by a company contaminated and age where gigantic utility companies can collapse at any moment, as has recently happened with Enron?
Health & Safety Comments as fisheries, CL-08/30 4. What legislation or regulations are in place to compensate communities, such to revert to public farmers, etc. in cases of releases or accidents during or after decomiiissioning?
CL-08/24 The nuclear facility's land, even after decommissioning, must not be allowed is less than 25 millirems or private use even if the NRC believes that the radioactivity on the land structures, etc. be built after the per year. Additionally, under no circumstances should future buildings, CL-08131 5. What agency or governing body is responsible for monitoring the site government agency, atop the former nuclear site. decommissioning is deemed "complete"? How do the licensee and a is mandated to protect the public health, allowed to walk away such as the NRC, which the safety of the workers that from a site that will essentially remain radioactive forever?
CL-08125 After the meeting in Atlanta. we are increasingly concerned about will be involved in decommissioning. Will a more specific analysis of worker effects be dealt Z Georgians for C with in the final EIS or is there a separate report that will research health impacts? Conclusion Energy requests that all worker exposures that have occurred at nuclear power plants that Clean and listed in the final GEIS.
are currently being decommissioned be made available to the public 6
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Co' co affect not only I-CL-08/32 As we have stated earlier, the methods used to decommission a nuclear plant will the communities of today but also the livelihood of future generations. The nuclear industry is CD leaving humankind a legacy of devastation-epttomized by its long-lived and highly dangerous 3 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-08/33 The NRC is charged to protect the quality of the human environment and we ask that they all can We CL-08/34 uphold that charge. The current draft GElS is not protective and needs major improvement.
again stress the need for site-specific Environmental Impact Statements on decommissioning for nuclear power reactors. Our communities-from the people to the waterways---are unique and ane entitled to nothing less.
Sincerely, Sara Barczak Safe Energy Director Georgians for Clean Energy Attachment 7
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To:
Lod Davis <davislj@dteenergy corn>
<dgeis@nrc gov>, <swb@nrc goV>, <elk1 @nrC gov>
12/28/01 6 59AM 0/ Page I Date:
Subject:
Comments on Draft Supplement to GElS on Decommissioning Good morning.
Please find attached a letter on -Comments on Draft Supplement to GElS on Decommissionling" (Fermi letter NRIC-01 .0087, dated December 28. 2001).
S.
Should you have any questions or comments, please advise Ms. Lynne Goodman. Manager, Fermi I (Detroit Edison), at 1-734-586-1205 (Should December 28, 2001 the NRC-01-O087 you have any problems with the document transmittal, please advise sender)
Thank you Chief, Rules and Directives Branch Division of Administrative Services Mailstop T6D59 CC: Lynne S Goodman <goodmanl@dteenergy corn> U.S. Nuclear Regulatory Commission
-.1 Washington, DC 20555-0001
Reference:
1.) Draft NUREG-0586, Sup I, "Generic Environmental Impact Statement on Decommissioning of Nuclear Facilities, Draft Supplement Dealing with Decommissioning of Nuclear Power Reactors", dated October
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C., _ 2001 CA.)
Subject:
Comments on Draft Supplement to GEIS on Decommissioning Detroit Edison appreciates the opportunity to comment on Reference 1.
CL-0911 the draft NUREG-0586, Sup 1. The Overall, Detoit Edison agrees with the conclusions inGeneric supplement will be helpful and updates the previous Environmental Impact Statement (GElS) on Decommissioning to accommodate changes in regulations and specific experience gained in recent decommissioning activities. Detroit Edison does have comments on details in the document. The attachment to this letter details the comments.
None of the comments should affect the overall conclusions in the supplement to GELS.
at If there are any questions on these comments, please contact Ms. Lynne Goodman 734-586-1205.
Sincerely, z
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Vice President, Nuclear Generation G) 6)
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U1 00 NRC-01-0087 NRC-01-0087 P December 28,2001December 28, 2001 U) Pago 2 Attachment I "V Page 3 CD D. Minaar (State of Michigan)
C Regional Administrator, Region MI SNRC Resident Office Specific Comments on NUREG-0586, Sup 1:
CL-09/2 Abstract. p iii. lines 16 add "explicitly" before "consider" in the 5 h sentence. The original GElS did not explicitly cover reactors except BWRs and 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 reactors in the original GEIS. They have been considered covered for activities described in the GELS.
CL-09/3 Executive Summary. p xi. 31 paraph.Aih, sentence, lines 31 change to "It 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-09/4 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-09/5 Section 3.1..V 3-2. line 39 and 3-3. line I -Fermi I is in the final phase (decontamination and dismantling) of SAFSTOR.
CL-09/6 Section 3 1 3. p 3-4. lines 10 delete 2" sentence and modify 3" sentence. The Fermi 1 FBR used uranium as its fuel. The information on uranium capturing neutrons to produce plutonium is correct. Breeding rates are dependent on the FBR's specific design.
CL-09/7 Section 3.1 1.3. p 3-5. line I- add "commercial" before "FBR". The final decision on whether to permanently shutdown the FFTF, a DOE FBR, has not yet been announced.
CL-09/8 Section 3.1.2. V3-6. lines 18 The Fermi I Reactor Building is a steel domed structure.
Below ground, there is considerable concrete shielding, but the building is not reinforced concrete.
CL-09/9 Section 3.1.3. P3-8. line 32 - add "The systems described are typical and may differ at specific facilities." to end of the 1i paragraph.
CL-09/10 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 Z convert liquid waste to gaseous and monitor their discharge.
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December 28,2001 Attachment I Attachment I Page 5 Page 4 needed so that air quality impacts will be minimal."
CL-09/12 Section 3 1.3. p 3-14. lines 5 shipment may also occur on barges or other ships.
define that CL-09/13 Section 3.2. p 3-16. lines 18 the definition of SAFSTOR should more clearly with in this section it includes the final decontamination of the facility. This would be more consistent CL-09/23 Section 4.3.9.2. R 4 it is not clear whether the physical injuries discussed definitions used elsewhere; such as in the original GEIS. are only those due to radiological impacts or due to non-radiological aspects of an accident.
The section is on radiological accidents so the former is implied, but the wording is not clear.
informed the NRC in late Table 3-2. p 3 add footnote "c" to Fermi I. Detroit Edison CL-09/14 2001 per the requirements of 10 CFR 50.82, that the final decontamination and dismantling CL-09/24 Section 4.3.9.3. 1 4-35. lines 19 the category of hazardous (non-radiological) chemical phase of SAFSTOR would be started for Fermi 1. related accidents is listed here, which is appropriate since such accidents are possible during decommissioning. The description only mentions potential for injury to the public.
three full paragraphs on p 3-29. However, in Section 4.3.9.2, which describes the classification of accidents as small, CL-09/15 Section 3.3.3. p 3 sentences am duplicated between the moderate and large, effects on workers are also discussed. This should be clarified since it line 16- thereonappears to be a discontinuity between the previous appears to be inconsistent.
CL-09/I16 Section paragraph and thep4-12.
4.3.3.3. paragraph starting line 16. Is something missing?
CL-09/25 Section 4.3.10.1. R4 the hazard of flames and fires should be addressed in the section be measured per the on physical hazards.
CL-09/17 Section 4.3 3.3., 4-12. line 23 - pH would not necessarily (normally)
LTP. Also, while considerable attention is placed on minimizing spills during c-u decommissioning, hazardous spills have occurred at decommissioning sites. The same types CL-09126 Section 4.3.10.1, R4-39 -the following items should be added to the list of activities that of activities as performed at operating units, which have resulted in spills at operating units, expose workers to chemical hazards:
01o can lead to spills at decommissioning units. The likelihood is less since less water treatment and so less bulk chemical handling is typically performed at decommissioning sites.
- Removal of chemical containing systems, such as demineralizers, and acid and caustic containing tanks '
CL-09/18 Section 4.3.3.3. 04-12. lines 28-3Q - add 'The processing of residual sodium products from
- Removal of sodium and NaK residues an FBR is no more likely to result in water quality impact than decommissioning activities at a LWR." CL-09/27 Section 4.3,10.2- g 4-40, lines 12 in the paragraph on FBR decommissioning activities, add that decommissioning a FBR involves removal of sodium and NaK, but that these CL-09/19 Section 4.3.4.2. p 4-14. lines. 11 not all decommissioning sites have or will have decommissioning activities can be performed safely with the proper engineering controls.
building ventilation systems, especially those that are in SAFSTOR for many years.
Temporary systems will be established, as needed, for gaseous and particulate effluents CL-09/28 Section 4.3.!1.1. 0441. line 7-add "LWR" before "licensee" in the third sentence. The during decommissioning if installed systems are no longer functional. formula for the specified minimum amount of decommissioning funds applies to LWR's.
The other regulations on decommissioning funds and evaluation of adequacy do apply to all CL-09/20 Monitoring of air quality is not necessarily performed during the storage period, depending reactors, so there is no adverse impact of the formula applying only to LWR's on activities, storage period and source term.
CL-09/29 Section 4.3.11.3. p4-45, lines 4 delete or reword "and is either undergoing fZ CL-09/21 Section 4.3 4 3. p 4 other activities during decommissioning could result in release of decommissioning or is in safe storage awaiting decommissioning" from the second sentence.
X particulate matter. This includes temporary suspension of particles during cutting activities SAFSTOR or safe storage is a form of decommissioning.
and production of particulates from processing of sodium and NaK at an FBR. Such 60 particulate matter is filtered, as necessary, prior to 4release, to avoid or minimize adverse air Tables 4-6 and 4-.,p 4 footnote "d" is not used in the tables, but probably belongs next CL-09/30 quality impacts. While this is recognized on p 4-1 , it should also be included in the section on "Results of Evaluation".
to the 960 value for the number of shipments from a PWR using SAFSTOR.
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CL-09/31 Section 4 3 18 2. p 4-72, lines 38 other irretrievable resources include gases and tools, a CL-09/22 Section 4 3.4 4. p.4-16, line I - add the following sentence to the end of the paragraph:
but these resources are also minor.
"Particulates produced by decommissioning activities within buildings will be filtered as
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NRC-01-0087 CY1 NRC-0 1-0087 December 28, 2001 December 28, 2001 Attachment 1 cn Attachment 1 Page 7 CD Page 6 CD ergonomically safe to prevent injuries)
CL-09132 Section 6 1. R 6 for plants shutdown before existing decommissioning rules were adopted, the environmental reviews may not be in the PSDAR as discussed in this section. In Large component transportation (The transportation issues all involve lifting of such cases environmental aspects not previously addressed that need to be addressed will be materials to remove them or bring them onto the site. Care also is needed if vehicle is covered in the LTP. backing up during the evolution.)
CL-09/33 Tables E-3 and E-5 LLW transportation The issue of occupational hazards applies to activities in addition to those indicated in Table E-3. Since Table E-5 is based on Table E-3, it also needs to be revised to reflect the Equipment into site transportation following.
Backfill tracked into site Such additional activities that can affect or involve occupational issues are as follows. A brief explanation of why follows each item. Non-radioactive waste transportation Adjust site training (Industrial safety type training needs to be continued and revised Complete final radiation survey (The survey will involve working at heights if based on job hazards to ensure workers are trained for activities or areas buildings remain, and possibly accessing hard to reach locations.)
le g. confined spaces] involved in decommissioning)
CL-09/34 Table F-I CD Establish a reactor coolant system vent pathway (Depending on specific method, this The site area for Fermi I is listed as 1,120 acres. That is the size of the Fermi 2 site; Fermi I could involve cutting, welding and working at heights) 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 I nuclear facility on the Fermi 2 site is less than 4 acres.
Establish containment vent pathway (Depending on specific method, this could involve cutting, welding and working at heights)
CL-09/35 Ferrm l's cooling water source was Lake Erie. Saxton's area is listed as 1.1 acres, however, the text reported San Onofre as having the smallest site. Also, footnote "b" should be applied Do preventive and corrective maintenance on SSCs (Maintenance activities at an to the "Cooling System" header, rather than "Cooling Water Source."
operating plant or decommissioning plant can involve industrial hazards, some more so than others. There can be energized systems, pressurized fluids, rotating CL-09/36 Table -. , P-F Fermi is in Michigan, not Ohio.
equipment, etc.)
CL-09/37 Section G. 1.1.4 1. R G delete or revise fourth bullet. Conditions typically encountered in Chemical decontamination (Occupational hazards include chemicals and pressurized exposures from normal facility operations result in external dose, rather than internal dose.
fluids) Internal deposition of particles can occur, but this is less common than external dose. Also, clarify last bullet.
High pressure water sprays of surface (High pressure sprays are themselves a hazard due to energy involved. Precautions need to be taken to use them safely) CL-09/38 Section G 1.14 3.p G-8, lines 13 this somewhat explains selection of the occupational nominal probability coefficient in Table G-4 for fatal cancers, but does not explain selection Cut out radioactive piping (Cutting typically involves torches or cutting wheels, of hereditary coefficient.
creation of fumes or particles, and rigging)
CL-09/39 Table G-6, p G-1 I - the table per its title covers dose limits for an individual member of the Remove large and small tanks or other radioactive components from the facility public under 10 CFR 20. The ALARA air emission dose constraint listed in the table is not a (Careful rigging is needed to maintain control and prevent injury. If this activity also 10 CFR 20 limt.
z involves cutting the equipment free, the hazards of cutting are also involved)
CL-09/40 Section G 2 1.P G-1 3. lines 26-45 - the conclusion in the first sentence of the third paragraph CD LLW packaging and storage (Handling the LLW and packages needs to be performed 1
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C) NRC-01-0087 NRC-01-0087 December 28, 2001 December 28, 2001 Attachment I Attachment 1 Page 9 Page 8 protective equipment planned and workers briefed for each activity. This is an immediate, is misleading. The main reason that the occupational doses at reactors undergoing short-term (for the duration of the activity) type of review, while most environmental issues decommissioning are a small fraction of dose accumulated at operating facilities, as shown in have longer term implications.
Table G-9, is that there are many more operating plants than decommissioning plants. The average for decommissioning plants shown in the table is less than the operating plant, but not only a small fraction. However, if occupational issues are to be included in this environmental review, the additional activities discussed earlier also need to be included.
CL-09141 It also is not clear how, why, and how many plants were selected for Tables G-l I and G-12. CL-09/49 Tables E-3. E-5. H-I and H some additional activities, for example, system Additionally, the first sentence of the fourth paragraph should indicate that the data is dismantlement and large component removal, could potentially impact air quality. Provisions estimated worker dose for major types of decommissioning activities. Actual data appeared are needed for portions of these activities to prevent adverse impacts.
to be listed for only one plant in the tables.
CL-09/50 Table H-2. p H in the "Impact and Summary of Findings" section, "water use" should be CL-09/42 Table G-12, pG the two numbers listed for San Onofre should be explained. changed to "air quality".
CL-09143 Section G 2.1. p 0- 13 & G-1 9 - the conclusion reached that the doses for SAFSTOR and Table 1-5. R 1 add fire and hazardous materials to associated accidents for removal of DECON are not substantially different is partly due to which decommissioning plants were CL-09/51 contaminated pipe and tubing.
selected to be evaluated.
-u IO CL-09/44 Table G-14 it appears strange that only 26-34 operating plants were listed as reporting dose CL-09152 Table 1-5. p 1 add fire and hazardous materials to associated accidents for metal and
-Jq component dismantlement, intact removal or partial segmentation of large components from gaseous effluents each year, since all plants are required to report. Also, the selection of the first three subcategories of removal of reactor pressure vessel and internals.
the years 1985-1987 appears strange for an update report.
CL-09/45 Section G.2.2, p G while the conclusion appears correct, it is strange that information CL-09/53 Table 1-5. p 1 add fire to associated accidents for cut piping attachments. Add fire and hazardous materials to associated accidents for decontamination, segmentation and disposal was only available for a small sample of facilities. This data is reported to the NRC annually of RCS and other larger bore piping.
by licensees.
CL-09/46 Table 0.15 - the basis of this table should be better explained. How were the plants CL-09154 Table I-5. 1,1 add fire to associated accidents for deactivate systems, disposal of nonessential structures and systems; establish a permanent reactor coolant system vent path; selected? What years are covered?
establish a permanent containment vent path; remove dedicated safe-shutdown dies'el and generator, and remove unused equipment during SAFSTOR. Add hazardous materials to CL-09/47 Table G how were the plants listed in this table selected? It appears to be a strange non deactivate systems; disposal of nonessential structures and systems; drain and flush plant representative sample.
systems; process, package, and ship liquid and solid radioactive wastes; remove dedicated safe-shutdown diesel and generator, dispose of non-radioactive hazardous waste; and limited CL-09/48 Tables H-I and H as addressed under comments on Tables E-3 and E-5, other activities decontamination of selected structures and systems.
Z involve occupational hazards.
C m In general: any activities that involve cutting or welding could lead to a fire. Precautions are Occupational issues do not seem to belong as an environment issue category. Safety of CL-09/55 implemented to minimize the possibility and respond quickly if a fire starts. Depending on G) workers is considered as a separate category when planning work. From a regulatory the materials in the systems during operation or during earlier decommissioning activities, a 6 perspective, OSHA and state agencies typically promulgate regulation on worker safety, not 01 hazardous materials accident is possible when removing systems, handling waste or using Co the EPA or stati environmental agencies. The environmental issues typically are impacts to decontamination materials. Again, precautions are planned to minimize the possibility.
the air, water, or land both on and off site, while other environmental issues that impact people are evaluated for the public. The type of review is also different for occupational CL-09/56 Section M.l.1. p J-iI - add, "selected" before "facilities" in the first sentence of the first CD issues than other environmental issues. As each work package isplanned, the hazards of the paragraph. Identify the time period used for the comparison in the second paragraph.
job need to be addressed in the planning and appropriate methods, engineering controls and
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CI) Attachment I C Attachment 1 Page I I Page 10 CD CD CL-09/58 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 CL-09/57 Table J add footnote "c" to Fermi 1. 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 GEIS supplement.
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Letter 10, page 1 Letter 10, page 2 Thank you for holding these meetings infour locations around the From: adele kushner <adelek @ailtel.net> 4ý -F-6Z1 CL-1 0/12 country, and for encouraging public participation.
To: <dgeisOnrc gov>
Date:
Subject:
12/29101 6.48PM NUREG-058N Comments on Draft Supplement I to NUREG-0586, Final Generic Environmental Impact Statement on Decommissioning of Nuclear Facilities.
C Adele Kushner, Executive Director Action for a Clean Environment Inc.
319 Wynn Lake Circle, Alto GA 30510 706-778-3661 CL-1 0/1 Although the alternatives proposed for decommissioning nuclear adelek@alltel.net facilities all sound reasonable, the proposal in general has one major problem, which is the NRC's lack of credibilrty due to past errors and cover-ups.
-°.*'1 CL-1 0/2 The present openness Is most welcome, and a nice change, but past history hangs over NRC like a dark cloud.
- 3. °1 CL-10/3 My direct experience Is limited to having heard an eyewitness account of -I the decommissioning of Yankee Rowe This person reported a whole list of unfortunate Incidents that released contamination Into the air and groundwater, contaminating workers on site who were not wearing protective clothing, and possibly contaminating people along the rag and truck routes where parts of the plant were being transported.
CL-10/4 Inaddition, many reports of lost shipments of nuclear waste and materials, including fuel rods, in various padts of the country come to light, another hazard of transporting radioactive matenals.
CL-10/5 Wherever human beings are involved, there are bound to be errors and accidents. The human element cannot be removed, as we found out at Three Mile Island and Chemobyl.
CL-i 0/6 Therefore, the safest alternative would be, first, to consider each reactor site Individually rather than making a blanket policy to cover every site. Second, the lowest possiblity of releasing contamination CL-10/7 into the environment requires entombing radioactive structures, systems and components In a long-lived substance, maintaining and monitoring it, until the radioactive level is reduced to a safe level, which would take manyyears.
CL-i10/8 This method would be the most likely to reduce exposure to workers and the public, and would not require workers familiar with the original construction Any of the methods proposed would require long time maintenance and CL- 10/9 monitoring, but keeping itIn its onginal location would mean that the community would be familiar with it, i would be visible, and the community would be likely to care about its monitoring. Infact, Involving the community Inthe whole process could utilize their experience and encourage their help.
CL-10/10 Allowing the licensee to choose the decommissioning method Is not recommended, due to the usual pressures to cut costs despite the obvious z dangers.
C X CL-09/1 1 ALARA Is not a sufficient basis for judging proper methods.
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m Debbie Musiker <dmusiker@lakemichigan.org> December 31, 2001 From:
- 0) To: "dgeis@nrc.gov <dgeis@nrc gov>
Date: 12131/01 11:10AM Chief, Rules and Directives Branch Cn
Subject:
Comments on DGEIS on Decommissioning of Nuclear Facilities Division of Administrative Services MailstopT6 D 59 CD U S. Nuclear Regulatory Commission B On behalf of the Lake Michigan Federation and the Environmental Law & Policy Washington. D C. 20555-0001 CD Center of the Midwest, please accept the attached comments regarding the Draft Supplement to the Final Generic Environmental Impact Statement on Re: Comments on Draft Supplement to the Final Generic Environmental Decommissioning of Nuclear Facilities, NUREG-0586. Impact Statement on Decommissioning of Nuclear Facilities, NUREG-.0586.
Please contact Debbie Musiker d you have any difficulty opening the attached document or have any other questions. Thank you for your
Dear Rules and Directives Branch Chief:
consideration.
Please accept the following comments on behalf of the Lake Michigan Fcderauon and the Environmental Best regards, Law & Pohcy Center of the Midwest. The Lake Michigan Federauon is a not-for-profit environmental organization that works to restore fish and wildlife habitat, conserve land and water, and eliminate pollution Debbie Musiker in the watershed of America's largest lake.
Lake Michigan Federation dmusiker@lakemichigan.org The Environmental Law & Policy Center isa Midwest public interest environmental advocacy organizaon, 312-939-0838 working, among other things to aclheve cleaner energy resources and implement sustainable energy strategies.
Paul Gaynor '1 Environmental Law & Policy Center of the Midwest CL-11/1 As a preliminary matter, we support the prompt decommissioning of nuclear power plants and urge the pgaynor@elpc.org *. .~.1-United States Nuclear Regulatory Comnnission ("NRC") to ensure that decommissioning goes forward in C
312-795-3713 the safest, most environmentally sound manner.
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.3 In reviewing the Draft Supplement to the Final Generic Environmental Impact Statement (heremafter, 0.. "Draft GEIS"), NUREG - 0586. we have several concerns.
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CL-1 1/2 freshwater supply,
- 1. Considering the importance of the Great Lakes, which represent 20% of the world'slocated the NRC should prepare a site-specific impact analysis for the 18 nuclear facilities on the CL-1 1/3 United States side of the Great Lakes. The potential threat of a release along the shoreline or into the lake of radioactive material during decommissioning or storage of spent fuel requires special CL- 11/4 consideration. The Draft GElS does not adequately consider the effects on aquatic ecology caused by an accidental, radioactive release.
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Other aquatic environmental Impacts also merit site-specific review. The location of intake and radioactivity of the material will still be high. With less security, these facilities are at greater risk CL-I 1/5 outfall structures in the lake alone requires site-specific analysis. As written, the Draft GEIS does for attack.
CL-I 1/6 not make clear whether an intakeloutfall structure on the facilityl is considered part of a previously disturbed area If deemed part of the previously disturbed area, any work on the Intake/outfall CL- 1/14 5. The NRC should be required to exnresslvanorove a post-shutdown decommissioning activities report structure will be deemed generic and the impact small. (CSDAR')before a licensee initiates decommissioning activities Otherwise, the licensees have little incentive to perform a rigorous analysis of whether their decommissioning activities fit within the envelope of environmental impacts set forth in the GElS Instead, they will likely assume they CL-I 1/7 Any work on or removal of an intake/outfall structure should trigger site-specific analysis. fit within the guidelines when they prepare their PSDAR. Moreover, a formal approval process Indeed, the Draft GEIS explains that the removal of near-shore or In-water structures could result should incorporate more opportunity for public Input.
in the establishment of non-indigenous species to the exclusion of native species. DGEIS, 4-17.
It also explains that In some cases wetlands will develop in areas where the construction of the 6. The Final GEIS should directly Indicate that licensees must obtain all necessary environmental perrmts facility alters surface drainage patterns. DGEIS,4-18. The Draft GEIS suggests that site-specific CL- 1115 prior to beginning the decommissioning process. Omitting this information may imply that the analysis is appropriate Incertain circumstances when the impact is beyond the previously disturbed compliance with the requirements of this GETS is adequate.
area and when there Isa potential to impact the aquadc environment. DGEIS, 4-19. The above examples of establishment of non-indigenous species or wetlands are exactly the types of impacts that require site-specific analysis. Yet, the site-specific analysis recommended may not cover these examples because they may occur within the previously disturbed area.
Removal of intake/outfall structures may be the most beneficial action to the aquatic ecology, but it CL-I 1/8 should not go forward without site-spedfic study of the environmental impacts.
CL-1 1/9 2. Sixty years Is an arbitrary and inappropriate time period to allow a nuclear reactor to remain in SAFSTOR, where the contaminated facility will largely remain intact and spent fuel may remain on-site. According to NRC staff. no technical basis exists for this 60-year timeframe.2 See Transcript, December 6.2001 Public Meeting, Drake Hotel, Chicago. First. ifa company waits too long to decommission, it will lose its Institutional memory and familiarity with the facility's
,-U structures because current workers may be deceased or otherwise unavailable. Such intricate knowledge of the facility Iscritical to avoiding radioactive releases during decommissioning.
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CL-11/10 Second. we are concerned that over the course of 60 years. the ownership of nuclear plants, financial status of licensees, and decommissioning obligations for many plants could change; if companies have not operated the facility long enough to accrue sufficient funds for decommissioning, and then go Into an extended SAFSTOR period, bankruptcy of the facility owner could Jeopardize clean up at the site. The extended time of storage combined with reduced staffing associated with SAFSTOR could mean that these sites are more likely to be subject to accident, theft of equipment, or attack.
CL-11/11 Third, the Draft GEIS does not explain at what point in time radioactive decay of the material will make It sufficiently safe to proceed with any further dismantling. NRC should shorten the acceptable time period for SAFSTOR and link it to the timeframe that would make the material safer. NRC should encourage licensees to go forward with dismantiing the facility under DECON as soon as appropriate, even if they start with placing the facility in SAFSTOR.
CL- 1/12 3. The terrorist attacks of September 11, 2001 have raised many Issues concerning the currently, inadequate security of our nation's nuclear reactors. Because decommissioning creates opportunities for release of spent fuel and structures contaminated with radioactive material, the z Final GEIS should revisit the appropnate security needed during decommissioning. Indeed, under C CL- 1/13 the current plan, facilities under SAFSTOR will have fewer personnel at the site even though the 6
L0 Co I If the intakeloutfall structure is located off the facility, it is excluded from the Draft GEIS analysis and
- 0) may not be given appropriate consideration.
2 Moreover, the 60-year period may be inconsistent with the explanation on page 1-6 of the Draft GElS that "C spent fuel may be stored safely on-site for approximately 30 years after the licensed life of the facility.
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- 0) The Lake Michigan Federation and the Environmental Law & Policy Center of the Midwest urge the NRC "P to do more to protect the Great Lakes from the risks associated with decominussioning as it prepares the C/) Final G12lS.
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z Letter 12, page 1 Letter 12, page 2 CD CT CD From: "Ed Martin' <edmartin@law corn>
111-710 Ed Martin ATTORNEY ATLAW 00 .cdgels@nrc.gmow To:
Date: 12131101 2:29PM PC. Box273 Voice (404)979-8478 Fax (208) 371-0024 Draft Supplement I to NUREG-0586 Decatur,GA 30031
Subject:
I attach hereto my supplemental comments on the above. December 31, 2001 Thank you for your kind attention to this submission. Please do not hesitate to contact me ifyou have any questions. I look forward to hearing from you. Chief, Rules and Directives Branch Division of Administrative Services Sincerely, Mailstop T 6 D 59 By Electronic Mail U.S. Nuclear Regulatory Commission Ed Martin Washington, DC 20555-0001' Re: Draft Supplement I to NUREG-0586 Sent by Law Mail Ladies and Gentlemen:
This will supplement my comments at the December 12 public meeting in
- 1) CL-1 2/1 Atlanta. As I noted at the time, I am concerned about the silence of the draft supplement
- - -l .1 on public participation in the decommissioning process. Commenters raised these concerns 18 months ago, but the draft supplement does not seem to address them.
As I read the supplement, its effect will be to predetermine a number of issues
' CL-12/2 about decommissioning of all public-utility power reactors. This will remove those CA) issues from examination in trial-type proceedings, where licensees' evidence or the, C.-, NRC's assumptions and conclusions could be tested and exposed to public scrutiny.
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Unless the public is allowed to intervene in decommissioning proceedings and CL- 2/3 participate fully in those proceedings, it cannot be certain that trustworthy decisions will result. Your 1996 brochure Public Involvement in the Nuclear Regulatory Process, NUREG/BR.02 15, assures us that "the public has an opportunity to participate in NRC's decisionmaking process to ... decommission a facility."
Public participation short of party-intervener status and review of less than all issues relevant to each plant seems to me a recipe for inadequate decisionmaking. If your agency restricts review, I believe you will be reneging on your promises to the public, as well as violating NRC's laws and regulations and the Administrative Procedure Act.
Thank you for the opportunity to supplement my earlier comments. I look z forward to your response.
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Yours very truly.
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&6b 54Z/ New England Coalition on Nuclear Pollution From: VT . NH . ME . MA Ri CT . NY
- 0) To: <dgeis@ nrc gee>
Date: 12131/01 5.31PM POST OFFICE BOX 545, BRATTLEBORO, VERMONT 05302 CAD Subject. COMMENTS on DECOM GElS C
-0 Attached as Ms WORD FILE. Please aknowledge receipt. Thank You and Happy Now Year. Ray December 31, 2001 CD Chief, Rules and Directives Branch Division of Administrative Services MailStopT6D59 U.S. Nuclear Regulatory Commission Washington, DC 20555-0001
-'I Re: NUREG - 0586 Draft Supplement 1, Generic Environmental Impact Statement on Decommisslonine Nuclear Facilities Draft Supplement Dealing With Decommissioning of Nuclear Power Reactors C.,
Written Comments Prepared by Raymond Shadis on Behalf of the New England Coalition on Nuclear Pollution CL-1 3/1 1. Not Risk-Informed - The U.S. Nuclear Regulatory Commission (NRC) has applied extraordinary effort to risk-inform reactor oversight but, save for Appendix G of this report, has avoided translation of environmental impacts from dose based-language to CL- 3/2 risk-based language. The US Environmental Protection Agency (EPA) and most state CA) agencies that set radiation exposure standards employ measures, limits, or goals expressed in terms of risk. NRC Radiological Site Release Criteria appear to yield a higher risk to the public than those risk levels acceptable to EPA under CERCLA. If this is so, then the GEIS should contain the comparisons (risk to risk, nuclear to chemical, one in ten thousand to one in a million) in plain language. The presentation of risk in Appendix G is unnecessarily obtuse and murky. It appears not to contain a comparison to permissible or target risks from non-radiological pollutants, which in all fairness, it should.
Appendix 1, Summary of Accidents For PWR and BWR Plants Undergoine CL-13/3 Decommissioning Operations, Table 1-3 lists accidents considered in various individual plant evaluations but lists no potential consequences and no probabilities. So what good is this list except to show the random and will-nilly cafeteria approach to individual plants picking out and designing bounding accident scenarios? At one plant the limiting scenario is fuel handling accident; at another it is a fire in the low level waste storage building. Case in Point: No fire scenarios are listed for Maine Yankee under Table 1-3, yet recently a fire occurred in a low-level waste dewatering unit and burned a several PJŽ3 hundred degrees for more than an hour. A local volunteer fire company approached the fire without respirators and without advice from radiation protection personnel. A GEIS should contain a comprehensive generic list of potential accidents (scenarios) together with probabilities and potential consequences.
z - 9/3 Presenting licensee estimates of consequences without comment or qualification as in CL-13/4
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California of 25.8 percent. This may be the stupidest table ever presented in an NRC Table 1-4, Highest Offsite Doses Calculated for Postulated Accidents in Licensing Basis document.
Documents, provides an incomplete picture of real potential consequences. For example, Maine Yankee asserts that loss of spent fuel pool heat sink will result in the same offsite CL-13/10 Table J-3 Impact of Plant Closure and Decommissioning on Local Tax Revenues does dose as a liquid waste spill, that of .23 REM. Other than a reference to another study, not show any impacts of decommissioning activities on tax revenues there fore the table NRC does not bother to explain what sort of dose spent fuel pool drain down might result is incorrectly titled. There could be some small near term impact of decommissioning on in if remedial action is not taken. As dose consequences can be rather large, the actual tax revenues, for example, taxes levied on capital equipment purchased by local vendors figures should be included in the GEIS. working on decommissioning and taxes on spent fuel storage facilities.
CL-13/5 2. Impact of Closure -The draft supplement attempts to reflect the impact of plant closure on CL_-13111 No effort is made to determine if marketability of local homes is increased by nuclear jobs, community tax revenues, and population. The impact of reactor shutdown a must be plant close. Marketability would determine price and ultimately impact tax-base.
considered apart from decommissioning. The decision to shutdown, to lay-off workers, to devalue the plant for tax purposes and so on, is not automatically a decision to At sites considered for re-powering, no consideration is given to the tax worth of the re CL-13/12 decommission the plant. It may be a shutdown for a long-term repair or upgrade period. powered site. Haddam Neck, for example, has applied for early partial site release so that Or it may be intended to mothball the facility with the decision to decommission or not the construction of a gas-fired plant may begin even before decommissioning is delayed a decade or more. In any case, if workforce reduction at shutdown is a part of completed. Fort St. Vraln hosts a gas-fired plant. If impact of closure is to be considered decommissioning, then workforce replenishment because of fuel storage or enforcement in a GEIS on decommissioning, so then should reuse be considered.
of administrative site release conditions should also be considered.
CL-13/13 In Maine, utility ratepayers are entitled to share in moneys recovered from the sale of CL-13/6 If decommissioning is to he risk-informed and the impacts of shut down are to be plant components and commodities, such as pipe and cable, as well as real estate and considered, then the cost and environmental and risk impacts of continued operation unspent decommissioning funds. While not taxes, per se, these are funds or credits added should also be compared. Maine Yankee shutdown rather than face the costs of steam to the general public revenue.
generator replacement and correction of a host of safety defects, including system-wide
-uo cable separation issues, inadequate high energy line break protection, inadequate CL-13/14 3. Environmental Impacts Section 4.3.8.2, Potential Radiolorical Impacts from C), containment volume, marginal emergency diesel generator capacity, 95 percent of fire Decommissioning Activities, fails to adequately consider the potential for seals defective, undersized atmospheric steam dump valves, and on and on. Haddam decommissioning activities to spread or hide radiological contamination. The Neck had similar problems. Just prior t the closure of Yankee Rowe, NRC staff was presumption is that accidents or mistakes will not take place, when experience at arguing internally about the sanity of permitting the plant to run one more fuel cycle with decommissioning plants shows that they do. The report fails to draw from this a badly embrittled reactor vessel. I experience. For example, early in the decommissioning of one site and prior to complete CL-13/7 If the costs of the decision to shutdown are included, then the cost of the immediate radiological survey, a trench was dug across an impacted area to lay an electrical cable to power equipment no longer serviced through the plant. The trench was left open to the alternative, repair and continued operation, ought to be included as well as comparative weather for a few days, then backfilled with loose material and thus could permit environmental impact and comparative risk.
rainwater to carry contamination deeper and spread it further. Individually, such activities CL-13/8 Table J-I Impact of Plant Closure and Decommissioning at Nuclear Power Plants may not provide what are termed significant doses, but they have the potential to add incremental to the dose of future site occupants and overall risk and may violate ALARA Currently Being Decommissioned includes three plants that have already passed from principles. The potential environmental impacts of such activities should be evaluated.
decommissioning to license termination. Maximum workforce and post termination Incidents have occurred in which workers left the site with contaminated clothing and in workforce figures arm scant, incorrect, misleading, and more or less, useless for the which train car loads of class A waste were permitted to languish for weeks on a siding in purpose of gaining usable information. Maine Yankee currently has more than 400 a residential community. Although radiation levels in these instances were extremely low, workers on site; not 295 as listed. Without a reference date, maximum workforce z the potential for greater exposures existed. Such scenarios should be considered, worst C numbers mean what? During outages? During major repairs and retrofits? Of twenty-two case, in preparing the GEIS.
m plants listed, workforce figures are given for only seven.
0 CL-13/15 Section 4.3.11.2 Potential Impacts of Decommissioning Activities on Cost correctly CL-13/9 Table J-2 Impact of Plant Closure and DecoImmissioning on Population Chanie'showes no points out that there are many variables in decommissioning that affect cost; among them co causal relationship between closure, decommissioning and population change. Of twenty are the size and type of reactor, the extent of contamination, property taxes and so on.
one plant locations listed, all save two show population increases in the host county G) However the GEIS does no more than list these variables without any attempt to assign following plant closure. Did Rainer County, Oregon increase its population' by 16.5 "Co the weight which any of them contribute. The GElS correctly points out that only three 0 percent as an impact of the Trojan Nuclear Plant shutdown? It is even harder to credit that commercial power reactors have successfully completed decommissioning, but does not the impa of the closure of 65 MWe Humbolt Bay is an increase in the population of (D
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0o say that they can hardly be considered typical of those plants under and entering decommissioning. Fort St. Vrain was a modest sized plant of oddball High Temperature Gas design and decommissioned on a fixed price, loss-leader price by a large manufacturing firm, Shoreham only ran the equivalent of one full power day, and CD Pathfinder was a 59MWe peanut of a plant. Thus it would be instructive to look at how
- costs are apportioned among today's more representative plants currently under CD decommissioning and from this base, knowing which are sensitive to scale and which are
_sensitive to choice, project final costs. These costs should be broken down and compared in the GElS.
CL-13116 Section 4.3.16.2 Potential Imp~acts of Noise from Decommissioning Activities seems to deal with noise as significant only at hearing-loss levels, however the admission is made that noise can be annoying. It can also degrade the general environment, and the aesthetic environment, lead to sleep loss, diminished creativity, and lost sales of goods and property. Where decommissioning schedules require night work, large pneumatic hammers can be heard miles distant from the site. The GELS should also consider noise from explosive demolition.
CL-1 3/17 Table 4-6 Radiological Impacts of Transporting LLW to Offsite Disposal Facilities is something of a puzzle. Waste volumes and radiological impacts in the table are much greater for the SAFSTOR decommissioning option (45,000 cubic meters/ 78 person-rem) than for the DECON option ( 10,000 cubic meters 48 person-rem). Same plant, if you lot the radiation dissipate with time, you wind up with more waste. With all due respect, this CA) ~ makes no readily apparent sense.
0)
CL-13/18 3. Spent Fuel Storage The GEIS does not consider the impacts of spent fuel storage. We believe this to be based on artificial distinctions. Both Maine Yankee and Haddam Neck have identified establishing an Independent Spent Fuel Storage Facility as a" critical pathway" in decommissioning. ISFSI construction has been regulated under the very same Part 50 license that will be terminated upon successful decommissioning. Only then will a Part 72 license be issued. The ISFSI is in the middle of a decommissioning site and physically inseparable from decommissioning. Its impacts should be considered among the impacts of decommissioning in the GEIS.
CL-13/19 4. Exported Impacts The on site disposal of radiological demolition debris (rubblization) is considered in the GELS. With rubblization abandoned at Maine Yankee, the cumulative effect of disposal of the debris at a licensed facility elsewhere is not considered. This makes no sense. Nor does it make sense to "lose" Impacts when contaminated materials are shipped to handling facilities for recycling. Different choices made at the decommissioning site will result in different impacts to workers and other citizenry offsite and away. These effects should not be artificially separated from the environmental impacts of decommissioning simply because they are exported.
Raymond Shahs -Post Office 1ox 76, Edgecomb, Mama 04556 Z (2o07582 - 7801 C'D Co Co
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z Letter 14, page 1 Letter 14, page 2 CD (D
From: Mark Oncavage <oncavage@ bellsouth.net> Comments on NUREG-0586 K)
To: <dgeis @nrc.gov> t<4 / Draft Supplement 1 Date: 12131/01 7:45PM
Subject:
Decommissioning Comments by Mark P. Oncavage
Dear Sir:
CL-14/1 1. The evaluation of each nuclear plant site for radioactive contamination can I am submitting the following comments to draft Supplement 1, only be done on a site-specific basis. Data of site contamination from NUREG-0586, Generic Environmental Impact Statement on Decommissioning Nuclear Facilities. Shoreham with zero years of operating experience cannot be compared with Sincerely, Mark P. Oncavage 33 years of operation at Big Rock Point and either of those sites can not be compared with a potential 120 years of Calvert Cliff operation or a potential 180 years of Oconee operation. Stating that, generically, all Impacts of radioactive contamination from all sites are similar (P. 4-28), is simply wrong.
The Important concept underlying the Environmental Impact Statement for
-(..
decommissioning nuclear plants is the health and safety of the public. The
-I Nuclear Regulatory Commission Staff (NRC) is writing an EIS based on an
. unsupported assumption. The impacts of a nuclear plant site contaminated
-J
- C-) "withradioactivity can be SMALL or MODERATE or LARGE,' but the impacts i.,1 are site-specific and are not similar nor generic.
CL-14/2 2. The evaluation of each nuclear plant plant site for radioactive contamination can only be done on a site-specific basis. The liquid low-level radioactive waste dump for St. Lucie 1 and 2 Is the Atlantic Ocean, whereas the dump for liquid low-level radioactive wastes at Turkey Point 3 and 4 is a closed cooling canal system. The northern end of the canal system, Lake Warren, is the designated dump. Ifthe sediments of Lake Warren and the cooling canals contain levels of radioactivity above those levels that are z deemed safe for unrestricted human activity, then Lake Warren Is one of the C
- U "safety-related structures, systems, and componentsr that needs to be G) decontaminated and dismantled. Lake Warren and the canals are also safety co related as they function to mitigate the effects of a design basis accident by Ln collecting and concentrating radioactive spills, dumped liquids, leachates, and
,,.. / -e2.- site runoff. Other nuclear plants that dump their liquid radioactive wastes into evaluations.
3/t CD (, V-) closed waters will also require site-specific
z Letter 14, page 3 Letter 14, page 4 C
m 0
6 CA A. Using funds for temporary procedures, such as SAFSTOR, is CL-14/3 3. The evaluation of each nuclear plant site for radioactive contamination can (n inappropriate.
00 only be done on a site-specific basis. In NUREG-0743, page 4-11, Turkey B. Using funds for the maintenance and monitoring of temporary Point units 3 and 4 averaged 340 curies of radioactive solid waste per year.
V procedures, such as CD Twenty two years later NUREG-1437, Supplement 5, page 2-12 states that in CD SAFSTOR, is inappropriate.
1999, units 3 and 4 shipped solid waste containing 834.3 curies per year, an C. Transferring funds from PSC/PUC control to licensee control is increase of 145 %, yet Turkey Point is only 47 % through its potential inappropriate.
operational life. Projections concerning the amounts of radioactivity in solid D. Using funds for the temporary storage of spent fuel, such as waste, gaseous waste, liquid waste, and site contamination appear to be pure ISFSI or PFS, is guesswork with a potential operational life of 60 years per unit. For the NRC inappropriate.
Staff to conclude that site contamination for all nuclear plant sites is E. Using funds for the settlement of bankruptcy claims is generically similar and that the impacts to the human environment are inappropriate.
SMALL, has no basis in fact. The NRC Staff needs to present the reasoning F. Using funds as collateral is inappropriate.
behind its projections to the scientific community for scientific scrutiny.
G. All other uses of funds that do not directly result in the permanent cleanup CL-14/4 Cu 4. Rubblization (p. 4-14), the breaking of contaminated concrete structures of contaminated nuclear plant sites, Is inappropriate.
into gravels and blocks cannot be considered an option where:
0o Since the funds were obtained as an extra fee from ratepayers for the A. the leachate plume could contaminate potable water, purpose of safely decommissioning nuclear plants, all of the funds need to be B. the leachate plume could contaminate water used for food used for that purpose.
production such as farming, fishing, seafood harvest, or dairy, CL-14/6 6. The massive destruction of September 11 th accomplished by the Al Qaeda C. the leachate plume could contaminate closed bodies of water terrorists has rendered the Waste Confidence Policy Ineffective and obsolete.
such as cooling No reasonable person can be assured that high-level nuclear waste can be canals or cooling ponds, and safely stored at plant sites under present conditions. The GElS fails to D. airborne particles could contaminate food crops, fishing waters, consider the consequences of acts of terrorism and acts of war perpetrated seafood by suicidal zealots against spent fuel facilities at decommissioned nuclear harvesting waters, or dairy areas. plant sites. This failure of the GElS needs to be remedied.
All contaminated building materials must be removed from the nuclear plant site. CL-14/7 7. The GElS needs to create a chronological list of all the decommissioning activities that accept public participation. All public participation opportunities zSCL-1415
- 5. The Generic Environmental Impact Statement needs to specify such as meetings, hearings, oral comments, written comments, petitions, and CD Inappropriate uses of decommissioning funds.
CD i3 C)
C)
z Letter 14, page 5 0<
CD 3
C) interventions need to be listed. At later times when specific dates are known, 0
N) this list needs to be advertised locally in the affected area. The licensee should also solicit public input on the formulation of decommissioning plans well before the decisions are made.
Submitted December 31, 2001 z
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CD CD
z Letter 15, page 1 Letter 15, page 2 C=
cn "Sokolsky, DavidW <DDS2@pge.com> *
- 6'* / <16 PG&E COMMENTS TO FGEIS C,, From:
- 0) To: "-dgeis@nrc.gov' <dgeis @nrc.gov>
G3 Date: 1/2/02 5:29PM DECEMBER 20, 2001
Subject:
FW: GElS COMMENTS c<<FGEIS_commentsl .doc>> CL-i5/i o The last paragraph in the Conclusions section of the Executive Summary, M
The above file represents Pacific Gas &Electric Company's revised comments and page 2-3 of Section 2.2.1, state that a licensee would have to submit a license amendment request ifenvironmental assessments are outside
=3 to the draft Gerenic Envnonmental Impact Satement on Decommissioning of Nuclear Facilities, NUREG-0586, Supplement 1. The comments in the21; above file are identical to the comments previously sent to you on December the bounds of the GElS or ifthe environmental impacts of a however, the previous comment on Section 4.3.4.2, page 4-13, Is withdrawn decommissioning activity have not been previously reviewed. What is the because the FGEIS Scope states '... activities perfomed before permanent licensing document that should be modified in the license amendment cessation of operations or impacts that are related to the decision to cease operations (for example, the Impact from the loss of generation capacity) request? Section 2.2.1 states the Environmental Report should be are outside the scope of the FGEIS." In this case the air impact of EIR for revised, but the PSDAR may be a more appropriate document.
replacement power would/should have been addressed in the onginal SAFSTOR. CL-15/2
- Section 4.3.9.1, page 4-33, refers to the licensee's FSAR. Suggest adding David Sokolsky Z Li the words "or equivalent" after "FSAR" since some licensees have a Supervisor of Licensing defueled safety analysis report (DSAR) instead of a FSAR.
Humboldt Bay Power Plant C) word Phone 707-444-0801 Internal 8-375-0801 CL-15/3 9 Section 4.3.12.1, page 4-47, second line - Add a period after the
,", c"
.J "effects" and begin the next sentence with the word "Socioeconomic."
">-. Onginal Message Conclusions sections discuss environmental impacts that may CL-15/4 9 The followingmoderate
"> From: Sokolsky, David have small, or large impacts:
"> Sent: Friday, December 21, 2001 4:38 PM
".Pb >To: 'dgeis@nrc.gov' a ">Cc: Moulia. Thomas; Nugent, Patrick / "o 4.3.1.4 (Onsite/Offsite Land Use)
Subject:
GElS COMMENTS "o 4.3.5.4 (Aquatic Ecology)
(7"
> <<FGEIS_comments.doc>> "o 4.3.6.4 (Terrestrial Ecology)
"o 4.3.9.4 (Radiological Accidents)
">The attached WORD file contains Pacific Gas &Electric Company comments on "o 4.3.10.3 (Occupational Issues)
">the draft Gerenic Envnonmental Impact Satement on Decommissioning of "o 4.3.12.4 (Socioeconomics)
"> Nuclear Facilities. NUREG-0586, Supplement 1. Ifyou have any questions
"> on these comments, please contact me.
The FGEIS is not clear what, ifany, actions a licensee should take
"> David Sokolsky depending on ifthe impacts are small, moderate or large?
"> Supervisor of icensing
"> Humboldt Bay Power Plant
"> Phone 707-444-0801 CL-15/6 &Section 3.1.4, page 3-15, does not reflect that alpha-emitting Transuranic
"> Internal 8-375-0801 radioactivity is significant at some plants. This radioactivity is formed after failed fuel releases small amounts of Uranium (as well as fission products) to the reactor coolant. Subsequent activation of the Uranium results in the formation of Transuranic isotopes of Plutonium, Americium and Cunum, most of which decay with alpha radiations. For the plants where this Issue "Widlams, CC: "Moulia, Thomas" <TAMI Opge corn>, "Nugent, Patrick* <PxN2@pge corn>,
Terry" <TJW3@pge.com>
is significant, the production of airborne alpha radioactivity during decommisioning activities must be carefully controlled to avoid radiation exposure from inhaled alpha radioactivity.
z 3
CD CD ,Ž'- VL I,
z Letter 16, page 1 Letter 16, page 2 02 CD o<
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3/4,) CL-16/2 EPA's major comments on the Supplement are: (1) 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 and when that activity or condition would require
... ./,2/J0e CL-1 6/3 further analysis; (2) the Supplement should distinguish better among certain of the small, moderate and large impact levels and better explain certain assumptions used in setting these December 21, 2001 CL- 6/4 levels; (3) the Supplement should address how the environmental analysis of decommissioning activities takes into account changes in the environmental parameters of the site during plant CL-16/5 operation; and, (4) the Supplement should provide a more robust discussion of ground water impacts. Further detail on EPA's concerns is found in the enclosed "Detailed Comments."
Chief, Rules and Directives Branch Division of Administrative Services Mail Stop T 6 D 59 Thank you for the opportunity to review this document. If you have any questions or U.S. Nuclear Regulatory Commission would like to meet to discuss our concerns, please contact Susan Absher of my staff. She may be Washington, DC 20555-0001 reached at (202) 564-7151.
U S. EPA Comments on Draft Supplement to Generic EIS for Decommissioning of Nuclear Sincerely, Power Reactors /s/
Dear Sir/Madam:
Anne Norton Miller In accordance with the National Environmental Policy Act (NEPA). Section 309 of the Director Clean Air Act, and the Council on Environmental Quality's implementing regulations (40 CFR Office of Federal Activities 1500-1508). the Environmental Protection Agency (EPA) is providing you comments on the Draft Supplement (the Supplement) to the Generic Environmental Impact Statement (GEIS) for
Enclosures:
2' Dec6mmisstontng of Nuclear Power Reactors, dated October 2001 (NUREG-0586, Draft Summary of Rating Definitions Supplement l, CEQ #010416). Detailed EPA Comments on the Draft Supplement to the GEIS The Supplement updates the 1988 GElS to reflect technological and regulatory changes and NRC's and licensees' experience with decommissioning nuclear power reactors. The environmental impacts described in the Supplement supersede those described in the 1988 GEIS.
The Supplement may be used as a stand-alone document without need to refer to the 1988 GEIS.
CL-1 6/1 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 Inits use of plain English and explanation of technical terms.
z C As indicated below and in the enclosed detailed comments, EPA is requesting that NRC provide clarifications, supplementary information and explanations of certain conclusions found X
ITI in the draft Supplement. EPA is therefore rating this Supplement as "EC-2", Environmental
- 6) Concerns - Insufficient Information. A summary of the rating definitions is enclosed.
,0 0) cin ,'%pA-( -o/c5 G,,eA .- 7-f Z)
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Z Letter 16, page 3 Letter 16, page 4 C
m 06 Ln CO Detailed EPA Comments on Draft Supplement to Generic EIS for Decomnmissioning of Nuclear Power Reactors CD (NRC NUREG-0586, Draft Supplement 1, October 2001)
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I*mmary of EPA Rating Definitions General Comments a proposed p~P1 aatsrw = 0i was developed as a ameas to summarize EPA's level of concern with environmental i"ii.i ofalphabetical categories that signify EPA's evaluationof the action The ratings ar.-
numeriCal categories that signify an evaluation of the adequacy ofthe EIS CL-16/6 . The Supplement should provide more specific guidance to licensees regarding the level of a impacts of the propwos...
particular decommussioning activtty. or the site conditions an which an activity as occurring.
Enviroumntall Impact of the Action which would trigger a site-specific NEPA analysis of the activity by the licensoe. For example, with regard to levels of activity that would require a site-specific analysis, the Supplement should "LO" (Lack of Obiections) The EPA review has not identified any potential environmental impacts more specifically define what constitutes a major transportation upgrade. With regard to site disclosed opportunities for application of requiring substantive changes to the proposal. The review may have changes to the proposal conditions, it should define how much time may pass after the previous disturbance of an aquatic mitigation measures that could be accomplished with no more than minor or terrestrial ecosystem before a site-specific analysis is necessary, or how recent the ecological "EC' (Environmental Concems). The EPA review has identified environmental impacts that should be assessment of that ecosystem must be to rely on the Supplement instead of a site-spccific avoided in order to fully protect the environment. Cctive measures may require changes to the preferred analysis. This will facilitate both licensees' evaluation of environmental impacts in required alternative or application of mitigation measures that can reduce the environmental impact. EPA would like to work submissions such as the Post Shutdown Decommissioning Activities Report (PSDAR) and the with the Iea agency to reduce these imact License TerminaUon Plan (LTP), and NRC's development of site-specific NEPA documents.
"EO" (Environmental The EPA review has identified significant environmental impacts that
.biections.
adequate protection for the environment. Corrective measures may require CL-16/7 2. profile of the site, the Supplement In order to provide a complete and up-to-date environmentalsite-specific must be avoided es order to provide some other project aermative (micluding the no should direct licensees to summarize the following in their NEPA analyses (and as substantial changes to the preferred alternative or comidmation of construction environmental reports (for plants agency to reduce these impacts. appropriate in the PSDAR and LTP) (a) pro-plant action alternative or a new alternative. EPA intends to work with the lead constricted before the enactment of NEPA) and environmental impact statements (EISs)
"-U EU" (Environmentallv UnsatisfactorI The EPA review has identified adverse environmental impacts regarding the impacts of plant construction and operation, (b) environmental reports and/or of public health or welfare or that are of ýsufficient magnitude that they are unsastisactory from the standpoint I the potentially assessments that were prepared during the penod the plant was sn operation regarding the quality EPA intends to work with the lead agency to reduce thes impacts environmental will be recommended for referral to the impacts of plant operation, (c) significant requirements and changes in the licensee's unsatisfactory impacts are not corrected at the final EIS stage, this proposal CEQ environmental permits, and (d) changes in the environmental parameters of a facility site dunng operation and the impacts of any such changes (see also Response to Comment #6-A, Adequacy of the Impact Statemeat page A- 11).
environmental impact(s)
"Categorvy PAdesuatet EPA believes the draft EIS adequately sets forth the CL-16/8 3. Response to Comment No. 6-C. page A-13, indicates that impacts from potentially contamnnated to the project or action No furlher of the preferred alternative and those of the alternatives reasonably available of larifying language or sediment are addressed in the Supplement, but we did not find this information.
analysis or data collection is necessary, but the reviewer may suggest the addition information.
CL-1 6/9 4. While EPA did not identify security issues during the GELSEPA scoping process, the events of Sept.
"*ateorv 2' (Insufficient lnformation} The draft EIS does not contain sufficient information EPA for EPA II have brought them to the forefront of public concern. suggests that NRC include in the protect the environment, or the final Supplement a general discussion on how the Cornmission ts addressing security from to fully assess evironmental impacts that should be avoided inorder to fully the spectrum of alternatives analyzed in reviewer has identified new reasonably available alteratives that are within terrorism at plants undergoing decommissioning.
The identified additional information, the draft EIS, which could reduce the environmental impacts of the action data, analyses, or discussion should be included in the final EIS. a viable option for CL-16/10 5. The Supplement (page 3-16) indicates that ENTOMB is still considered
.Catesorv 3" flnadeaus(e) EPA does not believe that the draft EIS adequately assesses potentally decommissioning. Section 3 2.3 notes that the Supplement includes a bounding analysis, but that identified new, reasonably available any environmental issues arising from a subsequent rulemaksng on ENTOMB will be addressed significant envrommental imparts of the action, or the EPA reviewer has EIS, which should be analyzed in alternatives that are outside of the spectrum of alternatives analyzed inthe draft that the identified additional in that rulemaking and its supporting environmental documentation. EPA urges NRC to consider order to reduce the potentially significant environmental impacts EPA believes in any subsequent analysis of EMTOMB the issue of residual dose and the potential need for should have full public review at a draft information, data, anallyses, or discussions are of such a magnitude that they state approval of any de facto disposal.
of the NEPA and/or Section 309 review, stage. EPA does not believe that the draft EIS is adequate for the purposes be formally revised and made available for public comment ma supplemental or revised draft EIS.
and thus should the basis of the potential significant impacts involved, this proposal could be a candidate for referral to the CEQ. Executive Summary On
ý9 - tt9/ e3
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Z Letter 16, page 5 Letter 16, page 6 CD 9
Ct, in" Co 2 3 r" CL-16/11 6 Page xv, Lines 37-38. The document identifies certain Issues that are "site-specific for activities occurring outside the disturbed areas in which there is no recent environmental assessment." CL-16119 14. Page 3-1l. Section 3.1 3. Lines 17-18. Please revise the document to clarify that Resource Conservation and Recovery Act hazardous waste disposal permits and Clean Water Act NPDES "Recent" should be defined by, for example, specifying a time frame or "shelf life" for permits are administered either by EPA or, where EPA has authorized the state RCRA program environmental assessments, so that licensees have clear notice of when they must prepare or or the state has assumed the NPDES program, by the state. (See NUREG 1628, Question 4.2.2) update such a document for the disturbed area(s) in question. This same problem arises in Table ES-I, which refers to "current" and "recent" ecological assessments. Also, the text should briefly discuss the management of PCBs and PCB-containing materials under the Toxic Substances Control Act.
Introdiuction CL-16120 15. Page 3-16. Section 3.1 4. Line l. This line notes that spent fuel comprises the largest amount of Pare 1-5. Section 1.3. This section states that except for decommissioning planning activities, radioactive material at a shutdown facility. It would be informative to include here a summary of CL-16112 7. or reference to the data in Appendix 0 on the amount of radioactive material at various types of the Supplement only considers activities following removal of the fuel from the reactor. The exclusions include "impacts that result directly and immediately from the act of permanently power plants.
ceasing operations" such as the environmental impacts of ceasing thermal discharges to receiving waters which the Supplement states "is essentially a restoration of existing conditions." This CL-16/21 16. Page 3-17. Section 3.2.1. Lines 32-33. Please revise the document to clarify that while the ignores the potentially adverse effects that the thermal discharges may have had on the ecosystem evaluation of ISFSIs is outside the scope of the GETS, it should be noted that the DECON while the plant was operating; and, while the affected ecosystem may recover from the thermal alternative does not necessarily completely eliminate the need for long-term securityýand discharges, such recovery may not be the equivalent of restoration to the originally existing surveillance of a facility; an ISFSI at a decommissioned facility will require long-term security conditions. Also, a species may have become established and dependent upon the thermal and surveillance.
discharge.
CL-16/22 17. Pge 329, Lines 29-39 repeat lines 11-21.
CL-16/13 S. Pag; 1-7. Section 1.3. Lines 30-33, The document needs to explain the grounds for the determination that the environmental impacts of concrete leaching into site groundwater as the Environmental Impacts result of rubblization can be evaluated generically. See also groundwater comments below.
Land Use Page I- . Lines 10-13 EPA agrees that inadvertent releases resulting from an accident should be P.,, CL-16/14 9.
1-CA) handled on a site-specific basis. We would like to see an explanation of how the analysis of CL-16/23 18. Page 4-6. Section 4.3,1.2. Lines 15-16. This section defines a previously disturbed area as an impacts from an accident would be handled.
area where land disturbance occurred "ddring construction or operation of the site." This definition may allow licensees to undertake decommissioning activities resulting in adverse CL-16/15 10. P;re t-8. Section 1.4.EPA encourages NRC wherever possible to make the Levels of environmental imlpacts without first performing a site-specific analysis of those impacts. For Significance (small, moderate and large) used in the Supplement more definitive by including example, it might allow a licensee to disturb an area that was disturbed several decades ago risk ranges, referencing the appropriate NRC regulations or providing examples of impacts. We note that in several cases the qualitative analysis Is given in units of person-rem with no during plant construction even if that area was not used during plant operation and has essentially regulatory limit provided. returned to its original condition, j&- native species have fully returned. The Supplement should define what constitutes a "previous" disturbance, Mg,by specifying a time frame, so such CL-16/16 i1. Page 2-5. Section 2.2. Line 10. This section should note that state or local requirements may be adverse impacts are not permitted to occur.
more restrictive than NRC's.
CL-16/24 19. Page 4-6. Section 4.3 12. Lines 25-29. The following terms are too broad or too vague to Description of the NRC Licensed Reactor Facilities and the Decommissioning Process provide licensees sufficient guidance about when a site-specific analysis is necessary: with regard to SMALL impacts, "very little new development" and "minimal changes"; with regard to CL-16117 12. Pare 3-5. Section 3.1.2. Lines 31-33 and Page 3-8. Lines 13-16. The document states on MODERATE impacts, "considerable new development" and "some changes"; and with regard to page 3-5 that "the impacts of dismantling all SSCs (structures, systems and components) that LARGE impacts, ,large-scale new development" and "major change." Providing specific were built or installed at the site to support power production are considered in this Supplement." examples from decommissioning or decommissioned facilities would be very useful.
z It then states on page 3-8 that the Supplement does not evaluate switchyards which "may remain C on the site". If they are dismantled, would they be evaluated? CL-16/25 20. Page 4-6. Section 4,3.1.3. Lines 33-4I. Using NUREG-1437's estimate that -I to -4 ha (-2.5 to ITI 10 ac) of land is needed for steam generator replacement activities, the document assumes that G CL-16/18 13. Pare 3-10. Section 31.3. Lines 32-25. The supplement states that "the amount of liquid and the land use Impacts of major component removal during decommissioning "should be similar or 0 gaseous radioactive waste generated is usually lower for decommissioning plants". Must the, less," and that the land used during major component removal "[glenerally ... has been previously UT plant's waste remain within the limits established during operations to be bounded by this GEIS? disturbed during construction of the facility." Does this mean that a licensee must perform a
- 0) site-specific analysis of impacts if the land use impacts of major component removal may or will r.
"Co
z Letter 16, page 7 Letter 16, page 8 G) 6 00 5 be greater than the estimated impacts of steam generator replacement, or if the land used during be SMALL." As currently written, it suggests that NRC will obtain a permitting authority's Cw "environmental assessment of aquatic impacts" and "consider the assessment in its determination
. major component removal has not been previously disturbed during construction of the facility?
"-u of the magnitude of the environmental impacts" of deconussioning activities at individual sites.
" CL-16/26 21. Page 4-7. Section 4 3 1.3. Lines 1-2. The Supplement notes that "almost all of the sites" will use It also suggests that NRC will "establish its own impact determination[sJ" on a site-specific basis 3 land previously disturbed during construction; should one assume that a facility using land not in the absence of such environmental assessments. Please clarify.
previously disturbed will need to conduct a site-specific analysis? Similarly, under Z "Conclusions" on that page, it states that impacts for "offsite land use" are considered small CL-16/33 28. Pape 4-11. Section 4.3 3.1. Lines 4-5. Please revise the Supplement to indicate that the NPDES "unless "major transportation upgrades are necessary." The examples given are establishing program only regulates point source discharges to surface waters, not discharges to groundwater water, rail or road transportation links. Is one to assume that any establishment of offsite or non-point source pollution. (See also section 4.3.34 ) As noted above, the document should transportation would require a site-specific analysis? Would impacts only be to off-site land uses note that point source discharges to surface waters also may be regulated under state wastewater or to on-site as well? Specific examples would help here. discharge permitting programs, and discharges to groundwater may be regulated under state programs.
CL- 6/27 22. Page 4-7. Section 4.3.1.3. Lines 10-12. Please explain the basis for the assumption that where previously disturbed areas are not large enough to support decommissioning activities, "it is CL-16/34 29. Page 4-1 I. Section 4.3 3 1. Lines 7-9 and Section 4.3.3.2. Line 16. The document assumes that likely" that the impact of disturbing previously undisturbed areas would be "temporary and facilities' NPDES permit limits during decommissioning "are generally the same limits that are SMALL" enforced for an operating plant," that facilities' permits "may require a monitoring program," and that "these monitoring programs are usually continued through the decommissioning period."
Water Use Should the reader assume that a licensee must perform a site-specific analysts of water quality impacts if any one of these conditions is not met? If not, why not? (See also section 4.3.3 4: is a CL-16/28 23. Pare 4-9. Section 4.3 2.2. Lines 12-14. The Supplement should briefly describe the "common site-specific analysis required where discharges to surface water may or will exceed the engineering practices to limit water use impacts." When describing how water impacts were NPDES-pcrinitted levels? Again, if not, why not?)
evaluated (sec. 4.3.2.3.), it would be helpful to include the average and maximum water usage pre- and post-operation of those plants that have ceased operation. CL-16/35 30. Page 4-11. Section 4.3.3.2. Lines 17-18. 21-23. This language could be interpreted erroneously
"-0 to indicate that discharges to groundwater are monitored under NPDES permits. The Supplement should address the water quality impacts of decommissioning activities on Water Quality groundwater separately from the impacts on surface water. In lines 34-35. the Supplement CL-16/29 24. Pages 4-10 through 4-12. Section 4.3.3. This section focuses primarily on the water quality should describe the conditions in which nonradiological impacts to groundwater and from non-point source pollution may be considered SMALL, MODERATE or LARGE.
impacts of nonradiological discharges from point sources to surface water (and the regulation of such discharges under the NPDES program). It should more fully discuss the water quality CL-16/36 31. Pa*e 4-11 to 4-12. Section 4.3.3.3.
impacts of both nonradiological discharges to groundwater (and their possible regulation under state programs) and non-point source pollution, and if necessary should indicate that one or both The discussion in this section could support a requirement for licensees to perform site-specific of these types of impacts require site-specific analysis. All of these types of discharges have analyses of the potential water quality impacts of their decommissioning activities under certain potential water quality impacts that need to be evaluated. circumstances; notably, language such as performing these activities in different orders can have a "significantly different impact on water quality," that the SAFSTOR option "may exacerbate CL-16/30 25. Pages 4-10 to 4-1I. Section 4 3.3 1. This subsection on water quality regulations should water quality issues," and that certain activities "may result in changes in local water chemistry" distinguish between "intentional" and "unintentional" nonradiological discharges to both surface implies the potential need for site-specific analysis.
water and groundwater. As currently drafted, the section blurs these distinct types of discharges, and the regulatory schemes relevant to each. In particular, the statement that rubblization may affect groundwater pH and thereby "affect the transport properties of radioactive and nonradioacUve chemicals in the subsurface" appears to require a site-specific analysis. The document notes in other places (..g, Page 1-7, Lines 26-33)
CL-16/31 26. Page 4-10, Section 4 3 3.1. Line 42. The Supplement refers to a "permttming authority" before it that the nonradiological impacts of rubblization, including concrete leaching into groundwater, identifies what type of permit is at issue. As a result, the reader does not know who the can be evaluated generically. Section 4.3.3.3 does not support this conclusion.
permittung authority is. It would be helpful to note that "intentional releases of non-radiological discharges" to surface waters are regulated under EPA or state wastewater discharge permitting Page 4-12. Section 4.3.3.3. Linesl6-17. The Supplement states that unintentional releases of CL-16/37 32.
programs, and such discharges to groundwater may be regulated under state programs.
hazardous substances historically have been infrequent at decommissioning facilities, and that CL-16/32 27. Pare 4.10. Section 43 3 I.Lines 41-44 and Paee 4-11. Lines 1-2. This paragraph is confusing in except for a few substances, hazardous substances spills are "localized, quickly detected, and relatively easy to remediate." Does this mean that a licensee must perform a site-specific light of the statement on Page 4-12 "that the issue of surface or groundwater quality for all analysis of potential water quality impacts if a hazardous substance is spilled or otherwise decommissioning activities is generic and that the environmental impacts for these activities will Z
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released to the environment during decommissioning. How is "hazardous substance" defined?
Examples or a better definition of "localized". "quickly detected" and "ease of remediation" CL- 6/44 39. Pagg 4-15, Section 4.3.4.3. Lines 21.23. This section states that "[nmo anticipated new methods of conducting decommissioning and no peculiarities of operating plant sites are anticipated to should also be provided.
affect this pattern" of managing fugitive dust. Is the reader to assume that a licensee who nonradiological proposes using a new decommissioning method must perform a site-specific analysis of potential CL-16/38 33. Page 4.12. Section 4.3.34. As noted above, the NPDES program only regulates impacts?
discharges to surface waters from point sources, not discharges to groundwater. This subsection should also draw conclusions about the potential water quality impacts of nonradiological Aquatic Ecology discharges to groundwater and non-point source pollution during decommissioning.
CL-16/39 34. Page 4-14, Section 4.3.4.2. Lines 6-8. The Supplement states that emissions from workers' CL-16/45 40. Page 4.16. Section 4.3.5. Lines 25-29. This section%discussion of impacts to aquatic resources following plant shutdown seems to contradict the example given on page 1-5, lines 6-7, of plant vehicles "should be lower" during decommissioning than during plant construction or outages discharges post-shutdown being outside the scope of this document. Similarly, the discussion at and are "usually lower" than during plant operation. Is there any data from decommissioned, Pane 4-19. Section 4 3.6. Lines 26-29 seems to contradict page I-5. Note also the comment plants to support these statements? Also, does one assume that a site-specific analysis of above on the page 1-5 language.
plant potential air quality impacts is required if such emissions may or will be higher than during construction, outages or operation? Page 4-17, Section 4.3,5,2. Line 38 and pa=e 4-18. Section 4 3 5 2. Lines 4 and 14./Tbe term CL-16/46 41.
most decommissioning "previously disturbed" needs definition.
CL-16/40 35. Page 4-14. Section 4.3.4.2. Lines10-24. The Supplement states that and activities am conducted in facility buildings with systems that are 'typically maintained Page 4-18. Section 4.3.5.2. Lines 14-17. The Supplement should provide specific guidance on result. CL-16/47 42.
periodically operated" during decommissioning to minimize airborne contamination. As a how to weigh the primary factors to be considered in evaluating the adverse impacts of "materials released when systems are dismantled and equipment is removed are not likely to be a decommissioning activities in "previously disturbed" areas. How much habitat can be disturbed released to the environment In significant quantities." Again, does the reader assume that before a site-specific analysis is required? How much time can have passed since the initial licensee must perform a site-specific analysis of potential air quality impacts if a certain level disturbance? How is a licensee to evaluate the successional patterns of the aquatic communities?
if (definition?) of decommissioning activity may or will not be conducted in facility buildings, or
-D the systems used to minimize airborne contamination may or will not be maintained and/or CL-16/48 43. Page 4-18, Section 4.3.5 2. Lines 17-23. The Supplement states that the potential impact of operated according to a certain level of effort? How is "significant quantity" defined?, disturbing areas beyond the original construction area is SMALL and can be characterized U1 generically if "the aquatic environment has been characterized," and that a site-specific analysis CL- 6/41 36. Pagg 4-14. Section 4.3 4.2. Lines 26-33. The Supplement states that fugitive dust emissions is needed if "decommissioning activities occur in aquatic environments have not been during movement of equipment outside of facility buildings are "likely .. to be confined to the characterized." What must this characterization consist of, and when and how recently must it immediate vicinity of the equipment," "in general ... limited to a small number of events" and "of have been performed. to allow a licensee to conclude that it is sufficient and can properly support relatively short duration." Again, is the reader to assume that a licensee must perform a the conclusion that potential impacts are SMALL?
site-specific analysis of potential air quality impacts where one of these conditions is not met?
Also, how are "immediate", "small number of events" and "relatively short duration" defined? Page 4-19, Section 4.3 5 4. Lines 4-6. This subsection appears to define a "previously disturbed Further, must the facility employ mitigation measures to minimize dust; if so, where are these CL-16/49 44.
area" as "within the security fences or surrounding paved, graveled, or otherwise developed areas specified? without removal of near-shore or in-water structures." Does this definition also al[oly to land use activities on page 4-6, Section 4.3.1.2, Lines 15-16? Does the definition mean that i licensee CL-16/42 37. pane 4-14. Section 4.3.4 2. Lines 40-43 and Page 4-15, Section 4 3.4.2. Lines 1-2. The who plans to remove near-shore or in-water structures in "previously disturbed areaV' must Supplement states that there is an average of less than one shipment per day of low-level waste perform a site-specific analysis of the 'potential aquatic ecology impacts?
(LLW) from a decommissioning plant; that, "in most cases, the number of shipments of other materials to and from a decommissioning facility will be less than that for LLW;" and that Page 4-19. Section 4.3.5.2. Lines 8-11. How is "previous" defined? What is the relationship therefore emissions associated with the transportation of materials from such a plant "are not CL-16/50 45.
between these "previous ecological surveys that indicate a low probability of adversely affecting expected to have a significant impact on air quality." Again, is the reader to assume that a ecological resources" and the aquatic environment characterizations referred to on Page 4-18, licensee must perform a site-specific analysis of potential air quality impacts if the number of Lines 17.23' This subsection suggests that the aquatic ecology impacts of decommissioning z shipments of materials to or from its decommissioning facility will exceed the level of less than activities conducted in areas that were not "previously disturbed" will be SMALL if a previous C one shipment per day? survey has demonstrated a low probability of adverse effects on the ecosystem, while Section m CL-16/43 38.
Pape 4-15. Section 4.3 4 2. Lines 4-7. The definition of what constitutes SMALL, MODERATE 4.3 4 2 suggests that the aquatic ecology impacts of decommissioning activities in such areas will be SMALL if a characterization has demonstrated the possibility of some adverse effects to and LARGE air quality impacts would be helped by providing specific examples from "sensitive resources," but the facility will manage those resources for their protection during decommissioning or decommissioned facilities.
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00 9 P0 U) of a facility. For this reason, EPA recommends that the Supplement require a site-specific decommissioning activities. analysis of all of the potential environmental impacts of rubblhzation. both nonradiological and radiological.
"_ CL-16/51 46. Pape 4-19. Section 4.3.5.2. Lines 11-16. The Supplement should define more precisely the CD circumstances under which a site-specsfic analysis of potential aquatic ecology impacts in previously undisturbed areas is required. How is the licensee to determine whether an activity CL-16/58 53. Pare 4-22. Section 4.3.6.4. Lines 37-39. This subsection appears to define a "previously 3CD disturbed area" as "within the security fences or surrounding paved, graveled, or otherwise has the potential to impact the environment? How should the magnitude of potential impacts be developed areas." How does this definition relate to the definition provided on Page 4-6, Section determined? Also, can a licensee avoid doing a site-specific analysis by implementing a 4.3.1.2, lines 15-16?
protection plan to protect the aquatic environment?
Terrestrial Ecology CL-16/59 54. Page 4-22. Section 4.3.6 4. Lines 40-43. This subsection suggests that the terrestrial ecology impacts of decommissioning activities conducted in areas that were not previously disturbed will be SMALL if a "previous" survey has demonstrated a low probability of adverse effects on the be CL- 6/52 47. Pare 4-21. Section 4 3 62. Lines I. 15 and 24. The term "previously disturbed" should ecosystem. How recent must the "previous" survey have been?
defined or examples provided.
CL-16/60 55 Pae 4-22. SectionJ4.3.6.2. Line 43 and Pape 4-23. Section 4.3.6.2. Lines 1-5 The Supplement CL-16/53 48. Page 4-21. Section 4.3.6 2. Lines 15-17. The Supplement should provide specific guidance on should better define or provide examples of circumstances under which a site-specific analysis of how to weigh the primary factors to be considered in evaluating the adverse impacts of potential terrestrial ecology impacts in previously undisturbed areas is required. What decommissioning activities in "previously disturbed" areas. 1tow much habitat can be disturbed constitutes a "potential of adverse impact to important terrestrial resources"? What is an before a site-specific analysis is required? How much time can have passed since the intial "important" terrestrial resource? The document should provide criteria by which a licensee can disturbance? How is a licensee to evaluate the successional patterns of the native communities? determine whether an activity has this "potential," as opposed to merely a "low probability of adversely affecting ecological resources." The Supplement should also clarify whether a licensee CL-16/54 49. Page 4-21. Section 4.3.6 2. Lines 23-25. What is a "significant" terrestrial resource? What does can avoid doing a site-specific analysis by implementing a protection plan to protect the "potentially" affected mean? These terms need to be defined or examples provided so that terrestrial environment.
licensees understand when they are required to perform a site-specific analysis.
-U Threatened and Endangered Species 0.)
CL-16/55 5o. Page 4-21. Section 4.3-6 2. Lines 25-29. The document states that the potential impact of a3) disturbing areas beyond the original construction area is SMALL and can be characterized for the CL-16/61 56. Page 4-23. Section 4 3 7, Lines 10-12. The supplement should elaborate on the basis generically if "the terrestrial environment has been characterized." Moreover, a site-specific statement that "the potential impacts of nuclear power facility decommissioning efforts on analysis is needed if "decommissioning activities occur in terrestrial environments that have not threatened or endangered species will normally be no greater and likely less than the effects of been characterized." What must this characterization consist of, and when/how recently must it plant operations."
have been performed, to allow a licensee to conclude that it is sufficient and can properly support the conclusion that potential impacts are SMALL? CL-16/62 57. Paae 4-25 Section 4.3.'7.2. Lines 3-7. The Supplement should provide guidance on determning the amount of habitat that can be disturbed beyond previously disturbed areas.
CL-16/56 51. Pares 4-21 to 4-22. Section 4.3.6.3. The document assumes that "[t]n most cases, the amount of land required to support the decommussioning process is relatively small and is normally a very Radiological small portion of the overall plant site." It also states that "licensees typically anticipate utilizing an area of between 0.4 ha (1 ac) to approximately 10.5 ha (26 ac) to support the CL-16/63 58. Page 4-27. section 4 3 8. lines 17-21. The Supplement should clarify the statement about the decommissioning process." EPA assumes this means that a licensee must perform a site-specific "relatively lower sensitivity of non-human species to radiation." Is this statement based on analysis of impacts if the terrestrial ecology impacts of decomnussioning activities may or will scientific studies or is the impact to non-humans not known? Why were decommissioning's be greater than 10.5 ha (26 ac). If this assumption is incorrect, when is a site-specific analysis is radiological impacts on ecological receptors defined as outside the scope of the Supplement?
required and why7 CL-16/64 59. Page 4-28. Section 4.3.8.3. This discussion in this section indicates that public and occupational Page 4-22. Section 4.3 6 3. Lines 27-29. The document assumes that the "activity other of rubblization dose comparisons were made with the facility's EIS for normal operations and with the 1988 CL-16/57 52. GEIS. This statement appears to contradict earlier statements about the assessment of impacts of construction material should not have significant nonradiological impacts beyond decommissioning activities except for potential short-term noise and dust effects." However, on being based on NRC regulatory limits for worker protection. Please clarify how the comparisons Page 4-12, the document states that rubblizatton may affect groundwater pH and thereby "affect were made.
the transport properties of radioactive and nonradioactive chemicals in the subsurface." Any radioactive or nonradioactive chemicals in the subsurface that are mobilized as a result of CL-16/65 60. Page 4-29. Section 4.3.8 3. Line 14 indicates that the data used in the evaluation are those concrete leaching from rubblized material could have an adverse effect on the terrestrial ecology Z
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