ML19351F798
| ML19351F798 | |
| Person / Time | |
|---|---|
| Issue date: | 01/02/1981 |
| From: | Kreger W Office of Nuclear Reactor Regulation |
| To: | Ballard R Office of Nuclear Reactor Regulation |
| References | |
| NUDOCS 8102200187 | |
| Download: ML19351F798 (2) | |
Text
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JAN 0 21981 PEMORANDLH FOR: Ronald L. Ballard, Chief Environeental Evaluation Branch, DE FROM:
William E. Kreger, Assistant Director for Radiation Protection, OSI
SUBJECT:
CCPMENTS ON C0FMISSION IWORMATICH PAPER: STANDARDIZED ENVIRONMENTAL LICENSE CONDITIONS AND DELETION (F kATER OUALITY REQUIREMENTS FROM OPERATING POWER PLANT LICENSES We have reviewed the subject paper. as well as the Environmental Protection Plans (EPPs) for Sequoyah, Farley, Salem 2 and North Anna 2.
We have the following comments:
1.
Although the purpose of staff actions is " reducing, simplifying, and standardizing non-radiological environmental requirements", the lack of definition of "significant environmental ef fects" substantiated by l
differences and inconsistencies in the effects considered in the four EPPs that we reviewed, would seem to support a need for further attempt at characterizing, if not quantifying, "significant". Because we l
recognize the difficulty in quantifying significant effects, we believe a listing in the paper of the items already identified as "significant", in EISs and records of decisions, would help to provide a yardstick against which to measure future actions. It would serve to inforn the Commission, as well as licensees and applicants, on what issues have been identified as significant environmental ef fects.
It may also be useful to identify some ipoacts that have been judged to be insignificant, in post licensing actions, for the same reason.
2.
On page 2, you have identified the " primary goal" (paragraph 3) of the advisory committee. Shouldn't we also be concerned that we not over-burden NRC applicants and licensees with concerns that are not applied to other power generation facilities. For example, is a fossil power plant required by any statute to consider the impact of herbicide use?
If not, is the exclusion because it is not a federal construction pro-ject or a federally licensed one?
3.
When EPP is introduced on Page 4, there is no discussion of the regulatory basis for such an item, nor the regulatory authority it carries. Page 5 identifies questions that ELD has about the EPP, without answering the specific concern of ELD. It also does not address the regulaton basis f
or authority of an EPP. We think such a discussion is needed.
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The last paragraph on page 5, continued on top of page 6, tries to identify -
l a relaxation position. However, we believe it might be more obvious what j w
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is expected if it characterized the needed actions as those having environ-mental impact as great or greater than those considered in the licensing process. As an aside, we wonder what is the basis or authority, if not NEPA, for the continuing regulatory concern about environmental impact. It might be useful in your paper to state what it is, since there is talk about what it isn't (reference to NEPA, page 5, line 2 from bottom).
5.
On page 6, 5th line from the bottom, "a number of environmental statutes in addition to NEPA", are called forth without specific identification.
For an information paper, we believe it would be useful to list these statutes.
6.
On page 9, it states that NRR will not initiate routine deletion of environmental requirements from operating plants. Only those recuesting water cuality refinement deletion will be issued an EPP in replacement of an ETS. But is it the case that if all operating plants do request deletion of water quality requirements, we will have to embart on an all encompassing EPP issuance program? This possibility should be addressed and justified if approcriate.
7.
Is it possible to quantify the number and kind of licensee activities that actually have had a significant impact on the environment since the Calvert Cliffs decision? If so, it would be useful to give the Commission a cuantitative idea of how much of an activity licensee evaluations of new environmental impacts, requiring staf f review, have been and therefore are likely to be in the future.
j Thank you for the opportunity to comment. Jack Hayes, ETSB, has been instrumental in stimulating and contributing to these comments.
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William E. Xreger, Assistant Director for Radiation Protection Division of Systems Integration cc:
D. Ross W. Gammill i
l R. Bangart J. Hayes l
DISTRIBUTION:
Central File NRR Reading File RP Reading File 3
_D 1:RP 72 WEKreger
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