ML19332D404
| ML19332D404 | |
| Person / Time | |
|---|---|
| Issue date: | 11/14/1989 |
| From: | NRC |
| To: | |
| References | |
| FRN-55FR29043 AD04-1-021, AD4-1, AD4-1-21, NUDOCS 8912010147 | |
| Download: ML19332D404 (46) | |
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. OFFICIAL TRANSCRIPT OF PROCEEDINGS l
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!!j, J,
Mency.'
Nuclear Regulatory Con. mission c
Public Workshop on Technical and
Title:
Policy considerations ror wuclear
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Power Plant License Renewal:
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Environmental Effects
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Docket No.
SESSION 8 r
Reston, Virginia DATE:
PAGEi Tuesday, November 14, 1989 1-34 i
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ANN RILEY & ASSOCIATES, LTD.
o 1612 K St. N.W. Suite 300 Mshington, D.C. 20006 (202) 293-3950 8912010147 891114 PDR MISC 26%J))L(Q)L47L PNU
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1 UNITED STATES OF AMERICA
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NUCLEAR REGULATORY COMMISSION 3
4 5
PUBLIC WORKSHOP 6
ON i
7 TECHNICAL AND POLICY CONSIDERATIONS 8
FOR l
9 NUCLEAR POWER PLANT LICENSE RENEWAL I
l 10 r
11 12 Session 8
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13
.j 14 15 Sheraton Resort Hotel
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16 Conference Rooms A, B and C 17 11810 Sunrise Valley Drive 18 Reston, Virginia i
19 1
20 21 Tuesday, November 14, 1989 22 8:30 o' clock a.m.
23 25 s
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SESSION LEADBRS k,)/'
2 Donald P. Cleary, Senior Task Manager, Reactor
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and Plant Safety Issues Branch, Division of f
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Safety Issue Resolution 5
Frank P. Gillespie, 0,fractor, Program Management, i
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Policy Development and Analysis Staff 1
7 PARTICI?AWTS t
0 Don Edwards, Yanke Atonic Power Co. for NUMARC 9
Jay Si'.bstg, Shaw, Pittman, Potts & Trow'> ridge for 10 Northern States Power Company 11 Jane Grant, Yankee Atomic Power Co.
12 Joseph Gallo, Hopkins & Sutter
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13 Geary Mizuno, NRC l
14 Themis Speis, NRC 15 Jim Chapman, Yankee Atomic Power Co.
16 Bill Rasin, NUMARC i
17 18 19 20 21 22 23 24 25
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PR0CEEDINGS 2
[8:30 a.m.)
3 MR. CLEARY:
Shall we get started?
I'm Don Cleary 4
from the NRC staff.
This is Session 8 on Environmental 5
Effects.
With me at the table, Frank Gillespie, who you all 6
know from yesterday; and Geary Mizuno from the Office of 7
General Counsel.
r 8
I'm going to request that when you sponk, please use 9
the microphones and give your name and affiliation so that we 10 can get it in the transcript.
11 I'm going to start off by providing a summary of the f
12 questions that have been already distributed, and then open it
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13 up to the speakers that have indicated an interest in making i
14 comment.
I'll just identify the ones that we have on the list l
15 now; NUMARC, Northern States Power, Yankee Atomic, and Joe i
16 Gallo from Hopkins, Sutter.
17' (Slide.)
l 18 MR. CLEARY:
The basic framework that we're looking 19 at is that we're in the process of a rulemaking, licenso 20 renewal, which requires a NEPA analysis.
That rulemaking will 21 provide some specifications for future individual plant 22 relicensing actions which, in turn, will require a NEPA 23 analysis.
l 24 One of the major things that we're trying to come to 25 grips with is whether these two requirements should be tied in
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any way.
Our approach so far has been, relative to the i
2 rulemaking, to take a fairly narrow view of the rule.
There is 3
already a rule on the books and legislation permits 4
relicensing.
5 We look at this rulemaking as providing greater 6
detail in terms of what's required in an application and the 7
standards that we'll use in reviewing the application and 8
making our determination.
The rule, in itself, does not lead 9
te anything significantly different from what's clready 10 permitted.
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11 We can take a narrow view if we also assume that in 12 individual relicensing actions that there will be a NEPA 13 analysis done.
Last spring, there was mounting concern within 14 NRC that perhaps we should be taking a close look at looking 15 into the future in terms of the individual relicensing actions 16 and perhaps taking a generic approach which would limit the 17 scope and systematize the individual relicensing actions when 18 they came up.
19 The extreme hope was that essentially all of the NEPA 20 issues could be put to rest generically through what would be a 21 separate rulemaking, a Part 51 rulemaking.
That raises the 22 question of the relationship of a Part 51 rulemaking, a generic 23 exercise versus a more limited exercise, NEPA analysis for the
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24 narrow purposes of what is basically a Part 50 rule.
25 The Commission has asked us to report back to them
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1 with recommendations as to whether the generic environmental j
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document should be undertaken and whether it should be tied to t
3-the Part 50 rulemaking.
In essence, it would then support the i
4 Part 50 rulemaking, in addition to the purposes of a Part 51 5
rulemaking, which would narrow the scope of relicensing 6
reviews, NEPA reviews in the future.
t 7
One of the major considerations is schedule.
It will 1
8 take time to do a generic analysis.
Basically, a generic i'
9 annlysis would have to do a fairly convincing job of bounding 10 all of the significant issues that could como up on a site-11 specific basis, site-spec 3fic plant-specific basis.
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12 I think the staff generally believes that the Part 50
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13 rule could proceed on a faster schedule than would be permitted 14 if it were tied to a generic NEPA exercise.
As you know, we 15 are proposing to publish proposed rule at the end of May, early 16 June.
If it is not tied to -- if it's just supported by a 17 narrowly scoped environmental document,-it's conceivable that 3
18 the final rule could be published about a year later.
i 19 If it is tied to a generic environmental document and 20 a Part 51 rulemaking, it would take a considerable number of I
21 months longer to reach the point where everything comes 22 together and the final license renewal rule could be published.
23 At the moment, that final date, if everything is done together,
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is April of 1992 on our schedule.
24 25 In addition to the question of what documents we 4
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1 generate now and later and the schedule implications, we'd like
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to look at some substantive questions in terms of what are the i
3 environmental effects that can be anticipated from this rule 4
from relicensing; are there any really significant ones or, as 5
may people believe, are they within the realm of experience and 6
rather innocuous.
7 There are questions of analysis; after you have 8
scoped the issues that you want to look at, how you would go 9
about collecting information.
Thir woul.d be a very large task 10 in a generic exarcius, bacause the objective, as I said, would 11 be to bound, in a convincing way, all of the site-and plant-12 specific potential impacts.
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13 There is a question of data, information, where it's 14 not all in NRC files.
There's a considerable amount of stock 15 of knowledge in NRC, but it's not systematic, it's not easily 16 retrievable, and it's not necessarily always convincing.
17 The question of where the data and information would 18
'come from, the open literature; to what extent would industry 19 have to be involved in such an exercise; to what extent is 20 there information, data located within state agencies; expert 21
' knowledge located within state and Federal agencies; and, to 22 what extent could we tap such information and data.
l 23
[ Slide.)
24 MR. CLEARY:
The conclusions that one would draw from
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25 analyses on specific issues are not purely objective.
They i
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reflect changing scientific standards in terms of what is l
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2 environmentally significant over times reflect changing 3
societal standards in terms of what is significant over time.
4 We need to address this.
Our analysis may not be on l
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the standards we apply in making decisions as to what the l
6 analysis shows us.
It may not be the same in all cases as it 7
was ten years ago or fifteen years ago.
Ten or fifteen years 8
from now, if the analysis were done then, it may not be exactly 9
the same as if it were done right now.
So this is an area 10 that we have to look at.
11 If we go to a generic environmental document, there j
12 would be required a significant public scoping process, and 13 this is one of the areas that we'd be pursuing in that scoping 14 process.
Then there are several areas, topical areas, issue 15 areas that are-of particular interest, either in terms of what 16 the appropriate scope is, the policy implications, the
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l 17 relationship to existing regulations, to existing policy, and 18 also some of the analytical concerns.
19 These are severe accident consequences, how would we t
20 treat these generically.
As most of you may realize, in NRC, 21 environmental impact statements for individual plants, since 22 the late 1970's, severe accident consequences have become a 23 major portion in terms of total number of pages coverage.
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24 There is spent fuel storage capacity.
We have vaste 25 confidence rule which should provide some restraints on what
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1 we're focusing on, but there are broader issues, uncertainties, 2
and to what extent can we -- under those uncertainties in terms 3
of availability and the timing of availability of off-site t
4 storage facilities for spent fuel come into consideration.
l 5
According to Part 51 relicensing, license renewal is 6
an operating license action.
Under Part 51, we needn't
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7 consider. alternatives.
However, for the programmatic approach, 8
which would be that which narrowly supports the relicensing 9
rule, the Part 50 aspects of it, we do have to look at j
10 alternatives to relicensing and how much that is -- is it 11 fairly clear to everyona that relicensing relative to the 12 alternatives is pretty clearcut, that the benefits are warrant-13 free licensing or are there controversies in that area?
14 Finally, something that I mentioned before; if we do 15 go into generic exercise, those of us who have given thought to 16 what has to be done believe that we will need considerable 17 cooperation in the process of developing a generic document 18 from Federal and state agencies, as well as industry.
19 With that, I'd like to move on to comments from those 20 who have prepared them, and then open this to the floor for t
21 discussion.
NUMARC is first on the list.
22 MR. EDWARDS:
Good morning.
My name is Don Edwards.
23 I'm speaking on behalf of the NUMARC/NUPLEX Working Group.
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24 appreciate your comments this morning.
Don, we've been 25 thinking a great deal about this.
In fact, the review of
1 environmental effects has been a matter of great discussion and i
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spirited opinion-giving for some time in the Working Group.
3 In fact, as late as last night, we were revisiting 4
the issue of our position and, in fact, it's only through the i
5 heroic efforts of a couple of very dedicated people that we 6
have slides to share with you today.
So I will explore with 7
you these slides and'see if we can describe our position.
8
[ Slide.)
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9 MR. EDWARDS:
Basically, at the present time, NUMARC 10 believes there needs to be two environmental assessments done.
11 First, an environmental assessment specifically to support the 12 rulemaking.
The major Federal action involved is the 13 implementation of the Atomic Energy Act which says that you can 14 renew licenses.
15 The scope need only address the impact of the 16 rulemaking and we believe it can be done in the same timeframe li as the renewal rule, which is a draft in May of 1990 and a 18 final in May 1991.
That says May there.
We also believe that 19 an environmental impact statement for license renewal is 20 probably not necessary and we believe that for license renewal 21 purposes that an EA is an appropriate first step.
22 NUMARC has conducted a study of environmental impacts 23.
on a generic basis for renewal on the basis of a rule that we 24 had formulated which assumed continued operation of the plants 25 under the present operating conditions.
And the conclusions we
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'l reached were that the environmental impacts were minimal.
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In addition, we believe that the high level waste 3
confidence-findings are going to incorporate renewal and, l
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4 therefore, one of the major reasons for EIS has probably been 5
removed.
6
[ Slide.)
7 MR. EDWARDS:
In conjunction with the rulemaking, we f
8 believe that NRC should change 51.20(B) (2) to permit an 9
environmental assessment on an individual plant basis.
We 10 believe the licensee filing will be merely an update of I
11 existing reports.
We believe this change is consistant with 12 the regulatory philosophy that's already been proposed for this l
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Again, the NUMARC study supports that.
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1 14 I mentioned a second environmental assessment, and 15 this one would be focused at changing Part 51.
This would 16 address the full scope of environmental issues needed to i
17 support the issuance of licenses.
We believe the work we've l
18 done can be geared so the results can be used in individual 19 cases, individual filings.
And we're looking very much at 20 schedule.
21 Don, you mentioned the concern about schedule.
We 1
22 believe the resolution of the broad scope of environmental i
23 issues needs to be balanced against the need to have the 24 licenses issued.
We think if this is done in a timely fashion, 25 that staff resources can be saved for all plants.
And we I
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1 believe that if it isn't done in a timely fashion, that staff k-l 2
resources are going to be devoted to litigation, at least on l
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the lead plants.
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4 (Slide.)
5 MR. EDWARDS:
So this concurrent environmental 7
6 assessment and Part 51 revision must not constrain either the 7
rule itself or the lead plant applications.
8 The license renewal rule, as we said, we needs to be 9
final in May 1991 before lead plants file, and we believe that 10 that change to Part 51 can be made.
We believe that the 11 separation needs to take place because the Part 51 rulemaking i
12 could be held up if they're coupled.
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13 (Slide.]
1 14 MR. EDWARDS:
With regard to topics, the
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15 NUMARC/NUPLEX study assessed in generic terms the environmental 16 effects resulting from heat discharges; chemical and blocide 17 discharges; routine radiologic emissions, gaseous, liquid and j
18
' solid; decommissioning and dismantling; radiological emissions 19 due to accidents; the uranium fuel cycle; and, construction at 20 the plant site.
21 Now, for the purposes of construction at the plant 22 site, we considered modifications at about the same level that 23 are being undertaken at the present time during operation.
24 During our study, we did not identify other initiators.
25 (Slide.)
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MR. EDWARDS:
This study, as I said, found minimal l
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2 impacts.
Routine radiological impacts from gaseous and liquid 3
releases are comparable to the experiences from currently 4
operating plants.
We took a look at population density and j
5 assumed-a two percent per year increase, and then looked at the 6
risk because of that.
We found that to be small and, in fact, 7
within the range of variability between sites and within the 8
overall uncertainty.
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Non-radiological releases were found to be not 10 significant.
We used generic data; one set of data was the 11 compilation of release records from all the operating plants.
12 We used fairly conservative assumptions.
And we recognize that (D
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13 our study needs to be verified in terms of its applicability to 14 an individual plant, but we concluded that the continued 15 operation of existing power plants would not produce 16 environmental effects different from those experienced during 17 the initial term.
18 We have listed in the report, and will provide with I
i 19 our written comments, the studies that we identified.
I'm sure l.
20 that NUMARC would like to explore, i.7 another conversation, if 21 there's other initiatives we could uridertake to support your 22 data collection efforts in this regard.
That's all the slides.
23 With regard to the questione, we believe that the 24 discussion of severe accidents that was done recently for
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l 25 Limerick and comanche Peak could provide sufficient detail to L
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i permit treatment of severe accidents in this undertaking.
As 2
was demonstrated for Comanche Peak, the information from a 3
Level 3 PRA is not necessary for the discussion of severe 4
accidents.
5 We believe that spent fuel storage considerations are 6
currently being addressed by the high level waste confidence 7
proceeding and we'think that the EA should adopt those results.
l 8
Finally, we think the NRC should assure that the i
9 states and other Federal acencies are solicited for written 10 comments on the draft environmental assessments as they're 11 available in accordance with the schedule we recommended.
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That concludes my remarks.
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13 NR. CLEARY:
Do we have a presentation by Northern 14 States Power?
15 MR. SILBERGt We don't all have to sit in the dark 16 because I don't have any slides.
I'm Jay Silberg from the law 17 firm of Shaw, Pittman, Potts & Trowbridge, speaking on behalf 18 of Northern States Power.
19 I would generally like to agree with Don's comments.
20 I think we support, in general terms, both the approach that 21 the staff outlined and the approach that Don outlined.
We 22 start off with a most important consideration, and that is that 23 the timing of the renewal rule must be consistcnt with the
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24 submission of the lead plant applications.
Again, we're 25 looking at this May 1991 schedule.
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We believe that there should be an environmental i
2 assessment prepared for that rule.
It should be an assessment 3
which focuses on the Federal action of promulgating a rule f
4 which is looking towards the review of renewal applications.
5 Preparation of environmental assessment limited to the rule 6
would be consistent with what NRC has done when it has 7
promulgated other amendments to 10 CFR Part 50.
l 8
We think preparation of such an environmental 9.
assessment can be done consistent with the schedule that is not 10 outlined for issuance of the renewal rule.
On a parallel path, 11 we would urge the Commission to identify those environmental
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12 impacts for individual renewals that can be generically
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'v 13 determined by scoping or by otherwise.
14 We would suggest that that be done in the same way l
15 that the NRC has generically determined the environmental 16 impacts for activities, such as the back end of the nuclear 17 fuel cycle and nuclear transportation, both of which are 18 currently incorporated in 10 CFR Part 51 and Tables S-3 and S-19 4.
20 The process of preparing an environmental survey and 21 incorporating the results of that survey in a rule through an 22 administrative procedures, like rulemaking, have been blessed i
23 by the Supreme Court in the Vermont Yankee case, clearly a 24 precedent which the NRC can have confidence in.
25 We think that that survey, environmental survey
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1 process and the rule can be done on a parallel path and can be I
2 perhaps brought to completion soon after the May 1991 date, or j
3 certainly as soon as possible.
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We woui.4 also urge that the Commission amend Part 51
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5 so that individual plant renewal applications will be
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accompanied by environmental assessments instead of 7
environmental impact statements.
From what we know so far, l
8 there is no indication th.st anything more than an updating of 9
the information that was prepared for the environmental impact 10 statements for-the construction and operation of operating 11 power plants will be necessary, and we think that that can be 12 done in the context of an environmental assessment.
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13 On some of the specific issues.
Severe accidents, we 34 think, can clearly be done generically.
NRC has handled severe 15 accident matters for environmental impact statements on nuclear 16 power plants prior to the Limerick decision on a generic basis.
l 17 We think based on the Limerick and Comanche Peak, that that can 18 be done generically as well, and that those results can be i
19 incorporated in a table in Part 51, thereby avoiding the need 20 to litigate those matters in each individual renewal 21 proceeding.
22 Spent fuel storage, we think, has been adequately 23 handled by the waste confidence proceeding, and those can also
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24 be incorporated in plant-specific environmental assessments.
25 In terms of consideration of alternatives, the I
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1 environmental assessment for the rule itself, we think, should p
2 consider alternatives to a renewal rule, and that alternative 3
would be ad hoc consideration as opposed to consideration under 4
an NRC rule.
That alternative, we think, can be dealt with 5
without upsetting the schedule for preparation of an 6
environmental assessment.
i 7
For plant-specific altornatives, we think that those 8
should be incorporated either in the plant-specific 9
environmental assessments or, if the environmental nurvey l
10 process which I have described can come up with bounding i
I 11 analyses that will cover all plants, that it may perhaps be 12 done on a generic basis.
I think that's something that will 13 have to depend on the outcome of the environmental survey.
F 14 Thank you.
15 MR. CLEARY:
Yankee Atomic is next.
i 16 MS. GRANT:
Good morning.
My name is Jane Grant and l
l 17 I'm with the Yankee Atomic Electric Company.
Let me first 18 start by saying that at the present time, Yankee supports the i
l 19 positions that Don Edwards has just explained for NUMARC.
l l
20 There is one point in particular, though, that Don 21 made and Jay made it, as well, that Yankee believes is very l-22 important and, therefore, deserves repeating for the third 1
l 23 time.
That point has to do with the environmental assessment 24 for the actual license renewal, the Part 50 rulemaking versus 25 the Part 51 rulemaking.
L 1
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(Slide.)
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2 MS. GRANT:
Yankee supports the use of an 3
environmental assessment for the license renewal rulemaking for 4
that Part 50.
We believe that it satisfies both NEPA and the 5
NRC requirements.
Now, Yankee also supports the use of a i
6 comprehensive environmental assessment, something that is 7
similar in scope to Regulatory Guide 4.2, to address generic 8
issues.
9 We think that such a comprehensive environmental 10 assessment will, indeed, bear out NUMARC's findings that it-11 made in its recent rtudy, which are that tha impacts due to 12 license renewal are, indeed, very small.
Now, that
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14 envelope the gencric environmental impacts, to reduce the scope i
15 and the number of issues that an individual plant would than l
16 have to address in its own application.
17
[ Slide.)
18 MS. GRANT:
However, a comprehensive environmental 19 assessment to address generic issues and then to support a Part 20 51 rulemaking really should be done separately, as was 21 mentioned, but in parallel to an environmental assessment that 22 is needed to support the Part 50 rulemaking.
23 If NRC resources are so limited that this approach, 24 this parallel approach cannot be done, then we would urge the 25 Commission to initially focus its environmental assessment l
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1 efforts on meeting the rulemaking schedule, on getting a rule
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s-2 out before the lead plants apply.
And we're looking at a
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3 schedule of a proposed rule in May 1990 and a final rule in May
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4 of 1991.
5 As mentioned several times in this workshop, Yankee l
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6 will be submitting its application in June of 1991 and, as far
.7-as we're concerned, regulatory limbo is just not a good place
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8 to be.
So we really need a final rule out before June of 1991.
l 1
9
[ Slide.)
10 MS. GRANT:
The final point that I'd like to make, 11 and this really has to do with.the scope of the applicants' 12 environmental reports, is that the objective of the n()
13 anvironmental review for license renewal should be to submit 14 sufficient information in the application to demonstrate that r
15 there are no significant itapacts on the environment due to l
16 continued operation.
17 In other words, just as age-related degradation 18 should be the focus of license renewal on the safety side, so 19 should only those incremental environmental effects associated l
20 with the renewal term, be the focus of license renewal on the 21 environmental side.
L 22 That concludes my remarks.
23 MR. CLEARY:
Joe Gallo.
24 MR. GALLO:
My name is Joe Gallo with the law firm of 25 Hopkins & Sutter.
I would like to focus my brief remarks on L-
l l
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one aspect of what the previous speakers addressed.
That is, I j
2 agree that an EA is an appropriate document to support the promulgation of the Part 50 rule; that is, the license renewal
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4 rulemaking.
5 I think that EA should be properly scoped in 6
accordance with the Commission's regulations, with particular 7
attention to that regulation in Part 51 that spells out the j
8 contents for an environmental assessment.
I also agree with 9
the statement made by the NRC that alternatives should be 10 considered.
11 There is one aspect of the alternatives and their I
12 consideration for the license renawal regulation that I'd like 13 to emphasire, which I think is a potential problem.
Over the 14 months -- by now, it's the years -- that license renewal has i
15 been in activity, I've heard some speak in terms of an l
16 alternative of no license renewal.
17 That is that one alternative to a license renewal L
18 rule is not to renew operating license at all.
That is not an i
19 available alternative, in my opinion.
The NRC has the 20 authority to renew licenses, but what they're about is i
21 implementing that authority and the existing set of regulations 22 would permit the renewal of a license.
l 23 There is not a structure for how that should be done,
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24 but it could be done on an ad hoc basis within the existing 25 structure, Therefore, alternatives te be considered in this 1
i 20 1
environmental assessment for purposes of the part 50 rule are l
l 2
the present proposal, the current licensing basis, the 3
application of new plant requirements, no regulation at all; 4
that is, just maintain the status quo; and, finally, some of 5
the variations that were discussed by the staff in NUREG 1317.
6 I think if these alternatives are addressed, then l
l 7
that will be an adequate discussion for purposes of the 8
environmental assessment that would support the issuance of the 9
license renewal rule.
In my judgment, although I've not done 10 the analysis, it would seem that the staff is on the right 11-track with the alternative that they've proposed.
12 Thank you.
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13 KR, MIZUNO:
After the presentations by the various 14 participants, I'm wondering whether we should just pluk up our 15 bags and go.
Actually, there are three questions that I wanted t
16 the industry to address; if not here, then certainly in written f
l 17' submissions that I believe that the industry intends to submit.
18 The first is what is the baseline for comparison of 19 either an EA or an EIS for an individual license proceeding; 20 whether it is the environmental impacts at the site without a 21 facility; in other words, the original site situation; or is 22 the baseline operation under the initial operating license?
23 To restate it another way, when you are comparing the
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24 impacts of renewed operation, are you comparing it against the 25 operation under the previous operating license or are you
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1 looking at the impacts as compared to the original site V
2 condition?
3 when you address this, we would like to have you l
4 address not only -- not only to give your position, but to also i
5 present the policy and legal basis for your position on this 6
question.
7 MR. GILLESPIE Just for maybe completeness, and I'll-8 ask this question not being a lawyer, but it seems the only 9
alternative to not renewing the license is let the site et:
i 10 there and get decommissioned.
So the real world baseline is if 11 you don't renew the license, the facility is going into a safe-12 store and decommissioning mode.
So, in fact, the baseline 13 shou]J never be, I wouldn't think, an empty site because an l
14 empty site is not what will be there.
l 35 So the erviror. rental impacts have to start with the 16 real world alternatives.
I suggest if you do write in, satisfy 1
17 a non-lawyer, give me a sentence on what happens if you let the 18 site sit.there and rust and decommission it, because that's 19 what's going to happen if you don't renew it.
To me, that i
20 seems like the real baseline that we're working from.
21 MR. MIZUNO:
The second question is what is going to 22 be necessary from the NRC's standpoint of preparing either an 23 EIS or an EA for those facilities where an EIS was not prepared
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24 at either the original CP or the original OL stage?
25 I understand that there are a number of facilities, a l.
7
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22 1
minority, I believe, where there are no EISs for these 2
facilities.
So the question is given the fact that we are now 3
going to be renewing the operating license, what does the NRC 4
have to do at this point to satisfy NEPA?
Specifically what 5
we're looking for is an idea of the scope of issues and the i
6 detail that is necessary and how the NRC will fulfill its 7
responsibility in that area.
8 I would suspect that, as part of answering that 9
question, you will also have to address the type of 10 information, the scope and the depth of information that would i
11 have to be submitted by the licensee in their supplementary l
12 environmental report or whatever document that they intend to j
13 submit to support the renewal application.
14 MR. GALLO:
I'd like to take a crack at thFt 15 question.
My name is Joe Gallo from Hopkins & Sutter.
As I 16 understood the question, and correct me, Geary, if I don't 17 restate it correctly, but what is the signiz'icance or 18 importance of a situation where an operating license is up for 19 renewal and it has not been the subject of a prior EIS with 20 respect to NEPA considerations.
21 He's nodding in the affirmative that I've restated 22 the question properly.
In.my opinion, and we've looked at this 23 question recently, the significance is really nil because the 24 proper scope in terms of license renewal are the impacts of the 25 proposed action.
i r
5 23 l
1 The proposed action is, let's assume, 20-year license
\\- ,
2 renewal.
It's a forward-looking, 20-year license renewal and t
3 the impact of that continued operation, for that particular
(
4 reactor, for that 20-year period are the impacts that ought to 5
be looked at.
For purposes of. conducting your evaluation, the 6
status quo should be taken; that is, this plant has been l
7 constructed, this plant has been operated for a long number of 8
years.
The status que should be taken at the time that the
)
9 renewal license is being up for consideration and is being i
10 submitted for NEPA evaluation.
11 I'm not sure just where you draw that line in time, 32 but at some point you do.
Existing environmental information x(
(
'13 for those plants exists because the NRC has required monitoring 14 and surveys to be done of the environmental effects.
For 15 examplo, radiological impacts, thermal discharges, and all 16 those impacts have been monitored and that information has been i
17 documented and maintained, just like all the other plants thec 18 were required to do so even though they had an EIS that was 19 prepared in support of the operating license.
[
l l
20 Now, there is one significant legal reason; actually, 21 there are two legal reasons.
The law says for NEPA that the l-l 22 impacts of concern are those associated with the proposed 1'
23 action.
That's point one.
If you were to look back and 24 somehow assess the previous impacts and evaluate those to some 25 extent, in my opinion, that would be the retroactive l
l l.
i 24 i
1 application of the National Environmental policy Act, which the j
2 cases are quite long on, but that's inappropriate.
l 3
And I don't think here we have a situation where the 4
exceptions to that rule apply.
Now, that's a general answer to 5
your question.
You're really looking for some citation in g
6 support of those conclusions and I would propose that we would 7
submit that to you in response to the written answers to 8
questions.
9 MR. MIZUNO:
If I could amplify my question.
I guess l
10' an important thing to also address is the question of, I guess, i
[
'l) the practicalities of conforming with NEPA where an existing --
j
~
i 1?
a plant which has an exiting EIS can merely, in a sense, tier i1
.on their past environmental report and the NRC can. tier on the 14 past EIS, whereas a plant which does not have preexisting EIS, 15' there is no-baseline or a base document to tier off of.
l.
16 Therefore, there might be certain analyses that need 17 to be performed or certain data to be collected which will 18 entail a greater resource effort for those plants which do not 19 have an EIS prepared as opposed to those plants that do have an 20 EIS.
21 MR. SILBERG:
Jay Silberg from Shaw, Pittman.
Let me 22 support Joe's position.
The issue of tiering, I think, is not l-23 relevant from a legal standpoint.
It may be from a practical 24 standpoint.
The issue that the NRC has to look at is whether 25 the renewal action is a major Federal action significantly n
-iU I
r f.i 25 1
1 effecting the quality of the human environment, the magic words 2
out of NEPA.
3 And you do take as the baseline what exists at the l
4 time you're making the action or, at least, not earlier than 5
the time that the application comes in.
You don't go back to a i
6 green site.
I think that answers yoor first question.
3 You don't have to reinvent where we were when 8
Columbus discovered America.
We take the environment as it 9
exists when the Federal Government is taking its action.
I 10 agree with Frank that the appropriate alternatives to look at 11 are not whether you return the site to a nice wooded area, but 12 you have a power plant that hasn't been-renewed.
O(J
.13 It may well be that that alternative can be resolved 14 generically, the same way that the Commisoion resolved 15 generically the issue of cor.sidering need for power at the 16 operating license-stage.
17 The Commission had a rulemaking and decided that that 18 was not a realistic alternative.
And the Commission may well, 19 in the survey process that I outlined, be able to make that 20 same determination for renewal plants.
That's a factual 21 question and I'm not willing to say that the Commission must
-22.
come out that way, but it certainly is within the realm of 23 possibility that they can do that, particularly based on the
( )
24 early generic determination that the commission made.
25 The question of tiering really is irrelevant.
The
26 r~s 1
.NRC.has to look at the facts on a plant that did not have an 2
environmental impact statement and determine whether there is 3
significant impact to the human environment.
4 If you can make that finding that there are no 5
significant impacts, whether or not there was an EIS the first r
6 time, then you properly would prepare an environmental 7
assessment and not an environmental impact statement.
+
8 If you can't make that finding, if the conclusion-9 from looking e.t-the data that's available from whatever source
.s that there.are significant environmental impacts, then you i
10 11 have to take the next step and prepare an environmental impact 12 statement, 13 My guess is, based on EISs and EAs that I've looked' 14 at, that you will be able to make no-significant-hazards, no-15 significant-impacts finding and prepare an EA even where there 16 has not been an environmental impact statement prepared earlier 17' in the process.
18 MR. MIZUNO:
Thank you.
My final question is not 19 strictly a legal one as opposed to a practical and policy 20 question.
In this case, I would not expect. legal comments to 21 come out.
It's just that I happen to be the attorney here.
22 MR. GILLESPIE:
But they're okay, right?
23 MR. MIZUNO:
Yes, they're okay.
Specifically, what I
()
24 would like to have is a discussion from a policy and a resource 25 standpoint, the reasons why the industry feels that -- whether
Q 27 1
.there is-insignificant difference in the amount of resources-
- g 3
'(-)'~
-2 and differences in schedule impacts for doing an environmental 3-assessment as opposed to doing EIS.
4 I guess specifically I'm thinking about the 5
environmental assessment as opposed to EIS at individual 6
licensing proceedings.
You may also want to address that for 7
the rulemaking, but my main interest is in the EIS versus EA 8
area.
Again, I would expect that'your arguments would be l
9-largely practical and policy oriented as opposed to legal.
10 MR. GILLESPIE:
We have a representative from the 11 state of Vermont in the back and he raised an interesting l
12 question at a meeting one time on low level waste.
The basic O
- (,/
13 question was did states, at some point in the very near future, 14 or something, become the owners of all the waste generated in 1
15 their states and what happens if the state hasn't agreed to 16 take the waste off-site and all that garbage starts collecting 17 on the individual sites.
1 l
18 Is that something that's generically a problem across 1~
19 the board?
It kind of surprised me at the meeting.
I hadn't 20 thought about it at all.
Is low level waste and the ownership l
21 of it in the next ten years a major problem?
Will it be or do 22 most utilities feel very comfortable that the states have 23 compacts that are going to be up and running and all the t
24 requirements of various acts are going to be complied with so 25 that we don't have to deal with the environmental impacts of
1 di r
]
28 1
low level waste being stored on nuclear power plant sites?
l I,_s
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i 1
^
. 2-(No response.)
3 MR. GILLESPIE:
Either no one thought about it, 4
either, or no one knows.
I don't know.
That's why I asked.
5 MR. SILBERG:
I'll take a shot at that.
Jay Silberg.
6 The issue of where individual compacts stand is clearly unique 7
to each compact and I don't think you can make a generic-8 determination that either all compacts will or all compacts 1
9 won't be able to meet the various milestones that are set by 10 the Low Level Waste Amendments Act.
11 The issue of the environmental impacts, I think, is a 12 different one than the legal issue of who owns the waste.
The I) 13 question that you have to look at is what-is the environmental 14 impact of the waste that might be generated by plants, whether i
-15 that waste is shipped off-site for disposal or stored on-site.
16 The shipment and the off-site storage has already 17 been generically handled in one of the tables in Part 51, and I 18 see no reason why the same impacts -- the impacts are 19 essentially identical -- would apply whether that waste is on-l-
20J site or off-site.
In fact, there might be less impacts because
'21 you would have no transportation if the waste was stored on-22 site.
L 23 But I think that is an issue which can certainly be l
('T --
24 handled on a generic basis by scoping and bounding what the V
25 environmental impacts are for the waste storage and disposal.
l'
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+
29
)
l' I really think the Commission should not get into the mode of
,s A
2 judging where compacts stand at any given point in time, 3
because that's not the issue that you should be looking at.
4-The issue you should focus on is what are the impacts 5-of the waste that would be generated.
6 MR. CLEARY:
One of the things the Commission has-7 requested us to report back to them.on is the use of Level 3 8
PRA.
This has come up in other-sessions and has been 9.
discussed.
.It seems to me that in the environmental analysis, 10 we, indeed, do look at the off-site consequences of severe 11.
accidents.
It's a focus of severe accidents within the context 12 of NEPA.
fI 13 Given that this is an issue, given that we do the w/
14 analysis and have been doing the analysis, I raise the 15 question, and I hope I get some response on this; given that it i
16 is a topic of concern under NEPA, does that analysis have any 17 contribution to make to feed back into relicensing decisions?
18 Is there, should there be any tie given that under NEPA we're 19 concerned with this, whereas in the safety analysis we l
20 typically don't go to the off-site consequence level.
l 21 Do I have any response on that?
l 22 MR. EDWARDS:
I'm Don Edwards.
Let me reiterate the 23 NUMARC statement I made in the slides in response to that.
We L /~N 24 feel if the information is available, it may be useful to use U
(
25 it.
But your own work on Comanche Peak demonstrated you don't l
l l'
1 30 1-need it to. reach the conclusions you need to reach to deal with J
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2
.the issues.
3.
So making it a requirement certainly isn't necessary 4
and that's what was the intent of that bullet on the slide.
i 5
MR. GILLESPIE:
Let me ask.
Put your Yankee hat on
'6 for me now.
You've come pretty close to, let'me say, finishing 7
your IPE and I sat through a presentation where I know you 8
looked at various' kinds of alternativesLin mitigation kind of 9
space.
10 MR. EDWARDS:
Yes.
11 MR. GILLESPIE:
One of the elements, be it a Level 3 12 PRA or whatever, of the IPE program was to look at various cost j )
13 effective alternatives in that kind of space.
Would it be fair l
14 to say -- or let me throw out the question to say that-the l
15 basic process we're going through now with the IPE, which does 16 request alternatives to be looked at and a line be drawn.
17 Would-that be an appropriate fallback vehicle to say here's 18 where there is more data than even existed for Comanche Peak, 19 that the data is kind of already there and being generated?
20 MR. EDWARDS:
If it's available. -If it's available, 21 yes.
But to tie it together I thought was the question and I 22 don't see --
23 MR. GILLESPIE:
I!m asking a different question.
I 24 think what I'm asking is you can go through a very detailed PRA 25 and a Level 3 and do crack calculations and all that, or you
.~ -
R 31 1
can do something somewhat foreshortened, which is what the IPE 2
program has people doing, looking at various alternatives.
3-Would, in general, those mitigation alternatives, do 4
you think, fit the bill?
I'm asking because I know you've gone 5
through this and you've put a lot of thought into it.-
Would 6
that evaluation of alternatives via the IPE actually be enough 7
information to fit the disclosure requirements of NEPA of 8
evaluating-various alternatives for mitigation of severe 9
accidents?
And you're making judgment; some are worth doing 10 and some aren't.
11 MR. EDWARDS:
Probably.
12 MR. GILLESPIE:
It just seems to me we're getting the E N) 5 13-same information through a different vehicle than needing to go 14 through something else.
Themis?
15 MR. SPEIS:
I want to make sure that the IPE is
'16 asking for containment performance improvement alternatives, 17 not necessarily to carry that into consequence space, but it's 18 certainly the next logical space and that's what you --
19 MR. GILLESPIE:
I don't know that full disclosure 20 means looking at alternatives.
I don't know.that NEPA requires l
21 going all the way through to the consequence level if you know 22 that the alternatives -- if you feel highly confident the 23 alternatives you're evaluating will make it better, that
()
24 there's really any need to quantify all the consequences.
25 I think we have a program in place that gives us
L :
^'
32
?+
1 probably the-information we need without doing something extra,
.{
2 is what I'm saying.
3 MR. EDWARDS:. I'm going to let your PRA man come back 4
at you.
3 MR. CHAPMAN:
I'm going to qualify this.
Jim Chapman l
6 from Yankee.
Outside of NEPA -
let me address it outside of
-7 NEPA.
Clearly, over the last ten years, we have investigated 8
the plant and explored alternatives, sometimes considering 9
Level 3, but mostly not considering it, because, in general, 10 the Level 3 is not necessary to explore alternatives.
So if 11 that's responsive to the NEPA issue.
i 12 MR. GILLESPIE:
Yes.
I'm trying.to get'a reason why.
~
13 we don't:have to do a Level 3 PRA, because if you do it, we've 14 got to review it.
~
15 MR. RASIN:
I'm Bill Rasin with NUMARC.
Let me.say a 16 couple words about that.
I think with regard to the IPEs, that g
17~
will certainly provide some valuable input.
I don't think that 18=
you will see an approach that takes a standard systematic list i
L 19 of alternatives and deals with all of them.
That's not the l
l 20 purpose of IPE.
21 I would remind you, though, that the NRC has some
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22 very extensive studies on which a lot of money was spent, and
-23 that's NUREG 1150.
The industry has done and submitted to the 24 NRC a lot of work under the IDCOR program, and while we had
()
1 25 differences with some of the technical details with that, the
[-
33 fai 1
conclusions were amazingly similar with regard to many of the 1
i
.2 very specific alternatives that one looks at in the NEPA
~ ~
3 process.
4-I would just urge you to make maximum use of that 5
information from both your studies and industry's and.put it to 6:
use rather than looking to supplement it.
7 I'll make one final observation.
We.seem to have 8
been able to deal with the severe accident question in the NEPA 9
setting for many years before we all knew that we were smart 10.
enough to do Level 3 PRAs.
So I don't think it's all of a 11
. sudden a requirement just because we have a new technique that 12 now it has to be applied.
13 I believe those studies, in the past, were done 14 pretty well and have stood up pretty well.
l 15 MR. CLEARY:
I know there are a number of 16
. representatives from state agencies here.
If any of you are so 17
' motivated, we certainly would appreciate any observations or 18~
comments that you might contribute to this dialogue at any 19 time.
Don't feel you have to jump up now, but anytime during 20 the session.
'21' Are there any further contributions from the floor,
- 2:2 any observations or questions that we haven't probed or 23 different perspectives on what has been discussed?
TO 24
[No response.)
V 25 MR. CLEARY:
I guess it's quite evident what happens
3 4
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V-34 i
L-1 now.< We're going to size up_how the other= sessions are going
)
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, b
~ 2 and if they're all finishing early, we'll take'a close look at.
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- 3 accelerating the' program.
We're adjourned.
4 (Whereupon, at 9:40 a.m., Session 8 was adjourned.)
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REPORTER'S CERTIFICATE
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This-is to certify that the attached proceed-f ings before the United States Nuclear Regulatory Commission L
in the matter oft NAME OF PROCEEDING:
Session 8 Public Workshop-DOCKET NUMBER:
Reston, VA PLACE.0F PROCEEDING:
were held ar herein appears, and that this is the original transcript thereof for the file of the United States Nuclear Regulatory Commission taken by me and thereafter reduced to typewriting by me or under the direction of the court report-ing company, and that the transcript is a true and accurate. record of the foregoing proceedings.
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Kevin Mahoney Official Reporter Ann Riley & Associates, Ltd.
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i REVIEW OF ENVIR005tENTAL EFFECTS i
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NRC SNOULD PERFORM AN ENVIRONMENTAL ASSESSMENT SPECIFICALLY TO j'
SUPPORT-THE LICENSE RENEWAL RULEMAKING.
l l
FEDERAL ACTIoM IS IMPLEMENTATION OF AEA.
i SCOPE NEED.ONLY. ADDRESS IMPACTS OF'THE RULEMAKING.
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CAN BE DONE IN SAME TIME FRAME AS THE RENEWAL RULE (I.E.,
l 5/90 DRAFT 4/91 FINAL)
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0 AN EIS FoR LICENSE RENEWAL IS PROBABLY UNNECESSARY.
i AN EA IS THE APPROPRIATE FIRST STEP.
NIMARC STUDY SUGGEST NO-SIGNIFICANT ENVIRONMENTAL IMPACTS.
HLW CONFIDENCE FINDINGS FOR RENEWAL ARE CURRENTLY BEING ADDRESSED.
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NRC SHOULD CHANGE 10CFR51.20(s)(2) TO PERMIT AN ENVIRONMENTAL l
ASSESSMENT FOR INDIVIDUAL LICENSING ACTIONS.
i 1.ICENSEE FILING WILL MERELY BE AN UPDATE OF: EXISTING REPORTS.
l CONSISTENT WITH THE PRELIMINARY REGULATORY PHILOSOPHY AIS l
APPROACH..
NIMARC STUDY CONCLUDED IMPACTS NOT SIGNIFICANT.
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A PARALLEL ENVIRONMENTAL ASSESSMENT TO ADDRESS THE FULL SCOPE OF ENVIR0pW4 ENTAL ISSUES IS NEEDED TO SUPPORT ISSUANCE OF RENEWAL
.f LICENSES.
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COUNCIL ON ENVIROpe4 ENTAL QUALITY GUIDELINES PERMIT TIERING OF f
ASSESSMENT RESULTS FOR INDIVIDUAL FILINGS.
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RESOLUTION OF' ISSUES MUST BE BALANCED AGAINST SCHEDULAR NEED TO SUPPORT ISSUANCE OF RENEWED LICENSES.
i j
SURVEY CAN BE COMPLETED IN TIME TO SAVE STAFF RESOURCES ON i
ALL PLANTS.
STAFF RESOURCES ON LEAD PLANT LITIGATION WILL BE REOUIRED.
j UNLESS'NRC'S SCHEDULE FOR NEPA RULEMAKING ACCOMMODATES LEAD j
PLANT ISSUANCE OF SERS i
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THE CONCURRENT ENVIRONMENTAL ASSESSMENT AND PART 51 RULEMAKING--
l MUST NOT CONSTRAIN ISSUANCE OF THE LICENSE RENEWAL' RULE (10CFR50) l OR REVIEW OF LEAD PLANT APPLICATIONS.
l LICENSE RENEWAL RULE MUST BE FINAL IN MAY 1991 sEFORE LEAD I
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MINOR CHANGE To PART 5120(s)(2) COULD BE COMPLETED IN MAY 1991.
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HEAT DISCHARGES.
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ROUTINE RADIOLOGICAL EMISSIONS - GASEOUS, LIou1D AND SOLID.--
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RADIOLOGICAL EMISSIONS DuE-.TO ACCIDENTS.
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6.
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l l
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CONSTRUCTION AT THE PLANT SITE.
I ADDITIONAL INITIATORS WERE NOT IDENTIFIED.
j IMPACTS OF PLANT CONSTRUCTION WERE TREATED IN CONTEXT OF PLANT' l
MODIFICATIONS-SIMILAR TO CURRENT OPERATION.
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RESULTING CNANGE IN RISK SMALL IN COMPARISON WITN VARIABILITY BETWEEN PLANTS'AND OVERALL UNCERTAINTY.
llON RADIOLOGICAL RELEASES OF NO SIGNIFICANCE.
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IMPACTS ESTIMATED USING GENERIC DATA AND CONSERVATIVE i
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O AVAILABLE EXPERIENTIAL KNOWLEDGE'AND STUDIES ARE IDENTIFIED IN THE NUMARC STUDY AND DATA WILL BE PROVIDED IN WRITTEN CODG4ENTS.
O CONTINUED OPERATION OF EXISTING POWER PLANTS WOULD NOT PRODUCE ENVIRONMENTAL EFFECTS-DIFFERENT FROM THOSE EXPERIENCED DURING THE l
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COMPREHENSIVE EA TO ADDRESS GENERIC ISSUES SHOULD BE DONE SEPAltATELY,.
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INITIALLY, EA EFFORTS SHOULD FOCUS ON MEETING RULEMAKIllG SCNEDULE -
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