ML20035D488

Forwards Jr Shetler Re California Environ Quality Act Supplemental Environ Rept for Plant.W/Svc List

ML20035D488
Person / Time
Site:	Rancho Seco
Issue date:	04/02/1993
From:	Baxter T SHAW, PITTMAN, POTTS & TROWBRIDGE
To:	Mcgranery J MCCARTHY, J.P.
References
CON-#293-13840 DCOM, NUDOCS 9304130262
Download: ML20035D488 (27)

Text

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.g ) ' u cle a h, viaG ehia 22> J itLrpwoNE (703)?907900 !2C2)663 8090 FAC$ WILE (202) 663 BSO 7 TMOM AS A BAKTER.PC April 2, 1993 James P. McGranery, Jr., Esq. 1255 23rd Street, N.W., Suite 750 Washington, D.C. 20037 In the Matter of SACRAMENTO MUNICIPAL UTILITY DISTRICT (Rancho Seco Nuclear Generating Station) Docket No. 50-312-DCOM

Dear Jim:

Please find enclosed a copy of District letter DAGM/NUC 93-074 to the NRC, March 30, 1993, entitled " California Environ-mental Quality Act Supplemental Environmental Report for the Rancho Seco Decommissioning Plan." Sincerely yours, Thomas A. Baxter Counsel for Licensee cc: (w/ encl): Service List 9304130262 930402 Ig PDR ADOCK 05000312 A-Q *j Q PDR a

%g j f ~,, .._3 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION ] In the Matter of ) ) Docket No. 50-312-DCOM SACRAMENTO MUNICIPAL UTILITY ) DISTRICT ) (Decommissioning Plan) ) (Rancho SeCo Nuclear Generating ) ASLBP No. 92-663-02-DCOM Station) ) SERVICE LIST Administrative Judge Office of the Secretary Charles Becahoefer, Esq., Chairman Attn: Docketing and Service Branch Atomic Safety and Licensing Board U.S. Nuclear Regulatory Commission U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Washington, D.C. 20555 Adjudicatory File Administrative Judge Atomic Safety and Licensing Board Dr. Richard F. Cole U.S. Nuclear Regulatory Commission Atomic Safety and Licensing Board Washington, D.C. 20555 U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Office of Commission Appellate Adjudication Administrative Judge U.S. Nuclear Regulatory Commission Mr. Thomas D. Murphy Washington, D.C. 20555 Atomic Safety and Licensing Board U.S. Nuclear Regulatory Commission James P. McGranery, Jr., Esq. Washington, D.C. 20555 1255 - 23rd Street, N.W. suite 750 i Charles A. Barth, Esq. Washington, D.C. 20037 Office of the General Counsel U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Jan Schori, Esq. General Counsel Sacramento Municipal Utility District P.O. Box 15830 Sacramento, CA 95813 0124/030 tab.93

e 4 9' $SMUD ~ SACRAMENTO MUNICIPAL UTILITY DISTRICT C P. O. Box 15830. Sacramento CA 95852-1830.1916) 452-3211 ~ AN ELECTRIC SYSTEM SERVING THE HEART OF CALIFORNIA DAGM/NUC 93-074 March 30, 1993 U.S. Nuclear Regulatory Commission Attn: Seymour Weiss Washington, DC 20555 Docket No. 50-312 Rancho Seco Nuclear Generating Station License No. DPR-54 CALIFORNIA ENVIRONMENTAL QUALITY ACT SUPPLEM ENTAL ENVIRONM ENTAL REPORT FOR TliE RANCHO SECO DECOMMISSIONING 4 PLAN Attention: Seymour Weiss Attachedisasupplement totheCalifornia EnvironmentalQuality Act(CEQA) environmental report for decommissioning Rancho Seco. This supplement discusses the newly recommended location for the Independent Spent Fuel Storage Installation. We are submitting a copy of the supplemental report for your review and comment. Should you have any comments, please provide them to the District by April 12,1993. Members ofyourstaffwith questions requiring additional information orclarification may call Bob Jones at (916)452-3211, extension 4676. Sincerely, t l A, James R. Shetler r Deputy Assistant General Manager Nuclear cc: J.B. Martin, NRC, Walnut Creek DISTRICT HEADQUARTERS O 6201 S Street, Sacramento CA 95817-1899 j i

i 4 B DRAFT SUPPLEMENT T0 f INITIAL STUDY AND ^ NEGATIVE DECLARATION: RANCHO SECO NUCLEAR GENERATING STATION DEC0l#1ISSIONING PLAN LEAD AGENCY: SACRAMENTO MUNICIPAL UTILITY DISTRICT 4 [ E CONTACT: SMUD ENVIRONMENTAL SERVICES ATTN: IRA SALETAN, MS 45 P. O. Box 15830 SACRAMENTO, CA 95852-1830 (916) 732-6207 MARCH 12, 1993

1. INTRODUCTION AND

SUMMARY

L Environmental Review Process In 1991, SMUD approved the proposed Rancho Seco Decommissioning Plan (DP) and associated Initial Study / Negative Declaration in compliance with the California Environmental Quality Act (CEQA). The Nuclear Regulatory Commission (NRC) issued SMUD a possession only license in April 1992. The DP is currently under review by with NRC approval pending. Consistent with Section 15163 of the CEQA guidelines, SMUD has prepared a draft Supplement to the 1991 Initial Study / Negative Declaration to address proposed modifications to the DP, including a newly recommended location for the Independent Spent Fuel Storage Installation (ISFSI). The report concludes that proposed changes to the DP will not cause significant adverse environmental impacts and preparation of an Environmental Impact Report is not required. The draft Supplement will be circulated for public review and comment for a 30-day period commencing March 12,1993. Persons who wish to submit comments concerning this document should do so in writing by April 12,1993 to: SMUD/ Environmental Services Attn: Ira Saletan, MS 45 P. O. Box 15830 Sacramento, CA 95852-1830 FAX: (916) 732-5238 The Supplement may be revised, incorporating responses to comments received during the public review period. The revised or final Supplement is scheduled to be presented for review and approval by the SMUD Board of Directors as early as April 15,1993. SMUD meetings scheduled to consider public testimony or formal action on the project will be publicized-through local newspaper advertisements. l Draft Initial Study / Negative Declaration Supplement PAGE 1 j Rancho Seco Decommissioning Plan March 12,1993 \\

h 1991 CEQA Initia1 Study / Negative Declaration concluded that implementadon of the DF and adopted mitigation measures would not resultin signi5 cant adverse environmental impact. The 1991 report evaluated poesntial impacts associated whh construction of as onsite fadapaadaat Spent Fuel Storass Instausdon 05F50 at a particular losadon withia the plant alas. To endoos radiation exposwo and fhciutets she runedlados and roues, SMUD is now recornmending that the 15FSI be constructed at a diftsreat location. ne draft Supplement assesses enviromaantal effects of proposed or potendal changes la the DF as described herein, primarily a change la the proposed location of the 15F5L This report Ands that all potendally significant impacts of die pet $ect would be sedened to a less than algniScant level by provialons of the DP and mitigation mensues as approved by SMUD in 1991. No now.mitigados measures as W SMUD therefore proposes to comply with CEQA 4+7: T by adopting a Negative-l Declarodon, rather than l wsparing and certifying an Environmental Inspect Report, befbre authorizing and proceedog with impistnantation of the DP u descrlhed hereia. The NRC has determined the: Woos concerning ultimens disposal of decommissioning wastes are beyond es agulatory scope of the decommissioning process and therefbee are not subject to envionmental' analysis in this coneast. Discussion of environmental impacts associatsd with waste disposal is contained in environmental damnenandas prepared by the NRC in 1988. l Earfroarqngtal Deterndnadan Based on the irierir.ation and analysis herein, SMUD Ands that ' nadi &=dans to the DP as ducribed above will not result la a potentiaDy signiA~-* adverse impact to ths environroent and preparadon of an EnvironmentalImpact Report is not required. Action by the SMUD Board of Directors to adopt this Supplement and authorias fillag of a Notice of Determinaden is recommended prior to authorizing L,'_:- : ~% of the plan modi 5 cations addressed in this Supplement. i l l l l FAGas Draft !altal Study /Nesatko Declaration Supp sment nasche seco Da---W rian - e rsk ta,tses

IL PROJECT DESCRUrrION Decommissioning is defined by the NRC as "the removal of a nuclear facility safely from service and reduction of residual radioactivity to a level that permits release of the property for unrestricted use and termination of the license" (NRC,1988). At the conclusion of the Rancho Seco decommissioning process, SMUD's license will be terminated by the NRC. The responsibility for decommissioning a commercial nuclear facility belongs to the licensee (SMUD). SMUD is responsible for implementing the DP as authorized and funding operations associated with the decommissioning process. Regulatory and policy guidance for decommissioning is the responsibility of the NRC. The NRC is responsible for ensuring that appropriate decommissioning procedures are followed to protect the health and safety of the public. Statutory authority for the regulation of commercial-nuclear acdvities is contained in the Atomic Energy Act of 1954 and the Energy Reorganization Act of 1974 as amended. According to NRC guidelines, decommissioning does not include conversion of the nuclear plant or site to alternate uses and facility or site conversion is not considered to be a decommissioning alternative. Analysis of potential alternative future onsite uses is therefore not required in this study except insofar as they affect the decommissioning process. (NRC,1988) Rancho Seco is located on a 2,400-acre site immediately south of Twin Cities Road (State Route 104) and 11 miles east of State Route 99 in a rural area of southeastern Sacramento County, as shown in Figures 1 and 2. The project site is located in an area of flat to rolling range land which has been used primarily for cattle grazing. The site includes the 320-acre nuclear plant complex and the 433-acre Rancho Seco Park and Lake complex which is currently operated as a recreadonal facility by SMUD. The plant is located in a low lying area, approximately one-half mile from site boundaries and public roadways. The site layout as revised to reflect the currently proposed ISFSI location is shown in Figure 3. I Draft Initial Study / Negative Declaration Supplement PAGE 3 Rancho Seco Decommissioning Plan March 12,1993

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1 l-4 Lidi2rstad -- In June 1988, voters within SMUD's service area approved Measure C (Ordinance 88-1), authorizing continued nuclear operations at Rancho Seco under specified conditions, including a requirement that a proposition authorizing condnued plant operations be submitted to voters and ratined by January 1990. Measure K (Ordinance 88-3) was placed on the ballot and defeated in June 1989. Following the defeat of Measure K, the plant was shut down and SMUD notined the NRC that it would seek to amend terms of its nuclear license for the purpose of decommissioning and closing Rancho Seco. By December 1989, SMUD began to implement a " protective lay-up" program for onsite systems, components, and structures to prevent or minimize the degradation or deterioration of plant systems while taking all measures necessary to protect the safety of the public and plant personnel. Spent nuclear fuel was transferred from the reactor j vessel to the spent fuel pool. Proposed Decommissionine Plan In 1991, SMUD approved the proposed DP and associated CEQA Initial Study / Negative Declaration. The NRC issued SMUD a possession only license in April 1992. The DP is currently under review by with NRC approval pending. The NRC provides several decommissioning alternatives to licensees as described in i NUREG-0586. Under the SAFSTOR alternative selected by SMUD for Rancho Seco, decontamination and removal of plant components is deferred and phased over an extended period of up to 60 years in three major phases: Cu'stodial SAFSTOR, Hardened SAFSTOR, and Deferred DECON. The nuclear facility is maintained in a dormant condition that allows for safe storage and is subsequently decontaminated to levels that could permit uses other than reactivation of the facility. An environmental surveillance program is implemented or maintained to ensure that radioactive exposure is monitored and measured and that emergency procedures are followed in response to releases that exceed prescribed limits. During the initial Custodial SAFSTOR phase of this process, the plant is secured and left largely undisturbed to assure occupational and puolic safety. Progressive decay of radioactive contaminants is allowed to occur onsite, reducing the amount of radioactive waste onsite and the hazards associated with handling this waste. I Draft Initial Study / Negative Declaration Supplement PAGE 4 Rancho Seco Decommissioning Plan March 12,1993

4 During the Hardened SAFSTOR phase, certain components and areas containing significant radioacdvity are secured to prevent intrusion or exposure. During the 3 Deferred DECON phase, remaining radioactive waste is decontaminated as feasible, removed, and transferred offsite for permanent disposal. The SAFSTOR process results in reduced radiadon levels as residual radioacdvity decays during a dormancy period of approximately 20 years, reducing occupational exposure associated with site decontamination, as indicated in the NUREG/CR-0130 study prepared for the NRC. SMUD proposes to implement Custodial SAFSTOR by 1994, Hardened SAFSTOR by 1998, and Deferred DECON between 2008 and 2011. Termination of SMUD's NRC license (10 CFR.50) is expected to occur by 2012 and site restoration would follow. Planned fuel storage operations during each phase are identified below. Custodial SAFSTOR Spent fuel will remain in the spent fuel pool (wet storage) until it is transferred to dry storage, by 1998 After procuring a transportable storage system, SMUD will place the fuel into dry storage at the onsite Independent Spent Fuel Storage Installation (ISFSI) Spent fuel will remain onsite until the U.S. Department of Energy takes possession, which is expected to occur after 1998 SMUD does not plan to decontaminate internally conta'minated plant systems during this phase of the decommissioning process Spent fuel pool will be drained and contamination stabilized after transferring fuel assemblies to dry storage Hardened SAFSTOR SMUD will maintain systems and programs useful for safely maintaining facilities onsite, including appropriate ventilation systems, the ISFSI, security, fire protection, and environmental monitoring. All other systems will be abandoned in place or sold and removed from the site. 1 Draft Initial Study / Negative Declaration Supplement PAGE 5 Rancho Seco Decommissioning Plan March 12,1993 i

Deferred DEGON SMUD has not yet developed specific plans for this phase of the decommissioning process. Detailed plans for Deferred DECON will be developed at the end of the Hardened SAFSTOR dormancy stage. Deferred DECON will be implemented following a SAFSTOR dormancy period of at least 15 years. Proposed Modifications to Decommissionine Plan The NRC has recognized that decommissioning plans will require revision "because many factors (e.g., technology, regulatory requirements, economics) will change before the license period ends" (NRC,1988). Subsequent to DP approval by the NRC, SMUD may make changes to the DP, the facility, or specified procedures without additional NRC approvals unless such changes would involve an unreviewed safety question or would require formal amendment of the license or technical specifications as provided in 10 CFR 50.59. SMUD proposes to maintain a Defueled Safety Analysis Report, which will. be revised every two years to reflect changes in the DP. The DP calls for SMUD to formally submit plan revisions to the NRC every five years. Submittals to Nuclear Regulatory Commission SMUD responded to requests by NRC staff for additional information concerning the DP in submittals dated April 15,1992, August 6,1992 and August 31,1992. The additional information SMUD has provided to the NRC in these submittals principally concerns administrative matters and does not substantially modify the DP as proposed. DP modifications discussed in these submittals are not expected to result in potentially significant adverse impact to the environment. Matters discussed in these submittals include: clarification and internal consistency of DP documents and activities e proposed license amendments and modifications to the Radiological Environmental Monitoring Program environme~ntal monitoring and maintenance and preservation of plant systems, particularly during the Hardened SAFSTOR phase Draft Initial Study / Negative Declaration Supplement PAGE 6 Rancho Seco Decommissioning Plan March 12,1993

l records of annual radioactivity releases ) e radiological characterization of plant facilides and other areas. e radiation exposure estimates decontamination'and contamination control measures and methods e waste generation and management o contingency planning if muld-purpose casks cannot be utilized as proposed or transfer of spent fuel to the ISFSI is delayed environmental impacts of decommissioning non-radioactive equipment and facilities e SMUD staff responsibilities for Rancho Seco operations e Independent Spent Fuel Storage Installation (ISFSI) Federal permanent repositories for disposal of radioacdve spent fuel are not currently available and no such repository is expected to be in place until approximately 2010. Interim storage by the U.S. Department of Energy is also not currently an option and i reprocessing facilities are not available in the U.S. In the absence of such facilities, SMUD commissioned a study of spent fuel storage alternadves by S. Levy, Inc. Based on this study, SMUD determined that above ground storage of spent fuel in dual-purpose - dry storage casks within an Independent Spent Fuel Storage Installation (ISFSI) was the most prudent alternative available and initiated design engineering for this facility. SMUD has subsequently elected to purchase an alternate spent fuel storage system known as a transportable storage system. SMUD has conducted an ISFSI site selection study of potential locations for the facility, including the radwaste storage area, a location west of the radwaste storage area, a site north of the Interim Onsite Storage Building, and a site located between the existing fence and the railroad tracks. This initial analysis identified the radwaste storage area as the preferred site, as illustrated and discussed in the original Initial Study / Negative ~ Declaration (Figdre 4). The preferred site was subsequently changed to the location of the former site construction office (known as the Bechtel building) to avoid interference. with site remediation activities. Draft Initial Study / Negative Declaration Supplement - PAGE 7 Rancho Seco Decommissioning Plan March 12,1993 p t .. - - +

i i In 1992, ShiUD staff reevaluated possible ISFSI locations to assure minimum radiation exposure to workers and future uses onsite in compliance with the NRC's ALARA ("As Low As Reasonably Achievable") occupational safety standard for radiation dose. i Accordingly, SMUD evaluated alternative locations within and outside the secured industrial area of the plant site. The recommendation of this analysis is to locate the ISFSI approximately 200 feet west of the area currently secured by the Industrial Area fence, adjacent to the Southern Pacific railroad spur, as shown in Figure 3. SMUD therefore proposes to modify the DP by changing the designated location of the ISFSI. Construction of the ISFSI is scheduled to begin in mid-1993 and be completed by the end of 1993. As currently planned, the ISFSI will be built within a fenced and secured area of approximately 2 acres on a concrete pad approximately 225 feet by 150 feet, as shown in Figure 5. ISFSI specifications are preliminary and subject to change based on the NRC review and approval process. 4 The ISFSI will contain 21 concrete horizontal storage modules (HSMs), as shown in Figure 6 and Figure 7. Each HSM will contain one dry storage canister that can hold up. to 24 fuel assemblies. SMUD also plans to purchase two multi-purpose casks to be used for moving canisters from the fuel storage building to the HSMs, transporting canisters offsite to the DOE for ultimate disposal, and providing interim backup storage of canisters onsite as needed. The maximum height of HSMs and casks will be approximately 15 feet above the concrete pad and ground level. The storage system will passively dissipate decay heat generated by the stored spent fuel through convection, thermal radiation, and conduction. Double-fencing at the perimeter of the ISFSI site will be similar to existing fencing around the central plant complex. Interior and exterior 8-foot chain-link fences, topped with razor ribbon for security, will be separated by a distance of approximately 20 feet. Use of motion detectors, cameras, onsite inspections, and signage will assure necessary site security and safety. The revised ISFSI license application to be submitted by SMUD to the NRC in mid-1993 will include a proposed decommissioning plan for this facility. Due to zero-leakage design of the storage system, no residual contamination of the ISFSI concrete pad is expected. Assuming there is no contamination, de facto decommissioning of the base pad, fence, and peripheral utility structures will occur when the last sealed canister and storage module are removed from the ISFSI. Draft Initial Study / Negative Declaration Supplement PAGE 8 Rancho Seco Decommissioning Plan March 12,1993 4 I

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1 i At the end of th_e storage period, multi-purpose casks may be used to transport the spent fuel to a permanent waste storage facility. The storage modules may also be shipped and reused, with subsequent users assuming responsibility for decommissioning. All fuel handling will occur onsite and no offsite cask transponation will be required until the fuel is transferred to DOE for disposal. The ISFSI will be licensed in accordance with the requirements of 10 CFR 72, " Licensing Requirements for the Independent Storage of Spent Nuclear Fuel and High Level Radioactive Waste." Multi-purpose casks have not yet been licensed by the NRC. To resolve licensing concerns, SMUD is supporting effons by DOE to implement a Transportable Storage System and Dry Transfer System Demonstration Program. SMUD plans to transfer all fuel assemblies to dry casks for storage by 1998. The plant's Radiological Environmental Monitoring Pogram (REMP) will be revised to provide pre-operational data for the ISFSI area and evaluate environmental impacts of the facility. The REMP provides measurements of radiation levels and radioactive materials in pathways that have the greatest potential exposure to workers and the public. Overall results of the Rancho Seco REMP are submitted annually to the NRC in the Annual Radiological EnvironmentJ Operating Report. Releases and doses associated with the ISFSI will be monitored and limited in accordance with the regulatory controls in 10 CFR 20,10 CFR 50, and 40 CFR 190. T Draft Initial Study / Negative Declaration Supplement PAGE 9 i i Rancho Seco Decommissioning Plan March 12,1993 j

4 III. ENVIRONMENTAL ANALYSIS Various studies of environmental conditions at the Rancho Seco site have been conducted since 1971. The following discussion is based on these studies and informadon provided in the DP and original Initial Study / Negative Declaration (SMUD,1991) as updated by SMUD staff. Identi5 cation and assessment of project impacts as required by CEQA is based on a comparison with current (post-shutdown) conditions, rather than pre-existing conditions which preceded the plant's shutdown in June 1989. This methodology is consistent with CEQA guidelines and the December 1990 Sacramento County Superior Court ruling in the case of Goldman v. SMUD (Sacramento County Superior Court, December 14, 1989). Environmental Imoacts and Mitigation Measures The NRC has concluded that available technology now makes it feasible to safely decommission a nuclear plant such as Rancho Seco. Potential adverse impacts associated-with decommissioning include occupational radiation exposure and radioactive waste storage. Beneficial impacts include elimination of potential problems associated with radioactively contaminated facilities and the potential reclamation of land for other productive uses (NRC,1988). The analysis in this section incorporates by reference information and findings presented in the Rancho Seco Proposed Decommissioning Plan initial Study / Negative Declaration (1991), as appropriate, including the adopted mitigation measures listed below. Adopted Mitication Measures Mitigation measures adopted by the SMUD Board of Directors concurrent with approval of the DP in October 1991 included the following: SMUD will implement all necessary and appropriate security and safety measures, including any measures required by the NRC, to minimize potential human health risks associated with exposure to hazardous materials. SMUD will perform dry weather wetting and/or paving (graveling) of heavily e traveled construction roads as needed to reduce dust emissions. Draft Initial Study / Negative Declaration Supplement PAGE 10 Rancho Seco Decommissioning Plan March 12,1993

Fuel burning equipment will be maintained in good mechanical order to reduce excessive emissions. SMUD will cooperate in the implementation of necessary road improvements and other transportation control measures to accommodate traffic associated with shipping of waste material offsite and other decommissioning activities, and to minimize traffic impacts on areas in the vicinity SMUD will comply with all applicable noise and occupational safety standards to protect workers and other persons from health effects of loud noise levels from demolition oflarge stnictures or other decommissioning activities onsite. Noise impacts will be minimized by limiting construction activities to normal working hours and providing trucks and other mechanical equipment with standard noise control devices. Implementation of the above measures would reduce potential environmental impacts of-the DP to a less than significant level. Land Use and Aesthetics Principal land uses in the vicinity of the central Rancho Seco plant complex are agriculture, recreation, and open space. The Rancho Seco site and areas in the vicinity are zoned by Sacramento County for agricultural use and predominantly used for grazing. Land southwest of Rancho Seco is designated as rural residential. The most visible plant features are the two tall cooling towers. Other structures on the site are not generally visible to those in the vicinity, including motorists on Twin Cities Road, due to site topography. The proposed ISFSI location is in an area that has been used for grazing, adjacent to the central plant complex. Construction of the ISFSI at this location would result in a loss of approximately 2 acres of pasture land. The ISFSI would be shielded from public view by site topography, which slopes upward in this area to the west and northwest. Site elevations in the vicinity of the proposed ISFSI location are shown in Figure 5. It will only be immediately and substantially visible to those working in the central plant complex. Potentiil land use and visual impacts of proposed modifications to the DP will be less than significant. 1 Draft Initial Study / Negative Declaration Supplement PAGE 11 Rancho Seco Decommissioning Plan March 12,1993

Health and Safety Principal environmental effects of decommissioning activities are radiation exposure and disposal of radioactive waste. Under the DP, radioacuve waste production will be reduced during Custodial SAFSTOR and Hardened SAFSTOR Provisions for disposal of spent fuel are subject to requirements established independently by the NRC under 10 CFR Part 60. Storage of spent fuel in ISFSIs is covered by regulations under 10 CFR Part 72 (NRC,1988). Disposal of spent fuel offsite may be at a federal geologic repository, pursuant to requirements set forth in NRC's regulation 10 CFR Part 60. Nuclear waste is classified as Class A, B, C, or above C based on radioactivity or toxicity levels. Disposal of wastes exceeding Class C is the responsibility of the federal government. DOE has offered to accept such waste for storage, pending development of disposal criteria and capacity. DOE has agreed to begin accepting spent fuel for geologic disposal by approximately 2010. SMUD plans to store all radioactive waste greater than Class C onsite until arrangements are made with DOE for ultimate disposal of this waste. The NRC has determined that issues concerning disposal of decommissioning wastes are beyond the regulatory scope of the decommissioning process and therefore not subject to environmental analysis in this context. If for any reason disposal capacity for decommissioning wastes were unavailable, Section 50.82 of the NRC regulations, as amended, authorizes the licensee to proceed with interim storage of decommissioning waste and to delay scheduled completion of decommissioning if necessary. Delay in decommissioning may result in a reduction of occupational radioactivity levels and waste volume due to radioactive decay. The ISFSI will not result in the generation of gaseous, liquid, or solid radioactive waste, and no hazardous chemicals will be used during the operation of the ISFSI. Decontamination of the multi-purpose casks will take place in the Fuel Storage Building before they are transferred to the ISFSI. Detailed descriptions of proposed decontamination and waste treatment processes are provided in Chapter 11 of SMUD's i Rancho Seco Defueled Safety Analysis Report (SMUD 1992). Exposure from the ISFSI to the nearest permanent resident will not exceed 25 millirems per year as specified in 10 CFR 72.104 and 40 CFR 190. Actual dose rates will be dependent on the number of sealed canisters in storage, degree of use, and fuel characteristics. Design specifications of the ISFSI will preclude airborne radioactive Draft laidal Study /Negadve Declaration Supplement PAGE 12 Rancho Seco Decommissioning Plan March 12,1993

releases during. fuel transfer and storage, and will provide adequate shielding to minimize a exposure. Radiation monitoring for construction workers will be performed in accordance with provisions of the Rancho Seco Radiadon Protection Program. Under a worst case scenario, in which there is total loss of the confinement barrier surrounding the storage area, it is projected that resulting doses at the site boundary would be substantially below the safety limits established in 10 CFR 72.106(b). The currently proposed ISFSI location is further from central plant facilities and work areas than the location which was originally selected. Approximate distances from occupied structures and areas which were used to estimate potential radiation exposure are shown in the Table 1. Because of greater distance from these areas and facilities, the proposed ISFSI location will reduce potential radiation exposure to site workers and increase accessibility of other facilities. For example, switchyard maintenance will not i require radiation monitoring. SMUD will implement all necessary and appropriate security and safety measures, including any measures required by the NRC, to minimize potential human health risks associated with exposure to hazardous materials. The proposed ISFSI location has been selected to meet the NRC's As Low As Reasonably Achievable (ALARA) occupational exposure standards. Adequate security will be provided at this location by fencing and site surveillance. The proposed location will also reduce constraints on future use of the plant site due to reduced radiation exposure. With full implementation of the design, operation, and maintenance standards discussed above, potential health and safety impacts of proposed modifications to the DP will be less than significant. Natural Resources and Drainage SMUD proposes to clear all vegetation from the proposed ISFSI site, which consists primarily of grassland, has been used for grazing, and has no known unique natural resource or habitat value. After the soil is replaced as necessary by suitable fill, it will be compacted and the slab will be formed using ready mix concrete. Construction of the ISFSI will increase the impermeable surface area and runoff. Runoff will be directed to the outfall south of the ISFSI site. Excavated material or fill will not be discharged into existing water bodies. No dewatering during excavation is anticipated. Drainage from spoil areas will be designed to follow natural drainage patterns. Draft Initial Study /Negadve Declaration Supplement PAGE 13 Rancho Seco Decommissioning Plan March 12,1993

Table 1 LOCATIONS TO CONDIDER FOR RADIATION DOBE EVALUATION (distances taken from C-101) O IOS BUILDING 600 FEET O MACHINE SHOP 1200 FEET O FAB SHOP 1250 YEET O IBFBI FENCE PER DRAWING O SITE BOUNDARY 1200 FEET (west) 1500 FEET (north) O CLOBE RESIDENCES 1000 hETERS (south) 1500 METERE (east) O BWITCH YARD 1100 FEET O T & R BUILDING 1800 FEET O PAP BUILDING 1900 FEET O NEAREST PUBLIC ROAD 2700 FEET ~(east) O RESERVOIR 2000 METERS (southeast) O AERATION POND 400 FEET (southeast)

f. Erosion will beJontrolled by providing drainage, controlling slope angle, and reseeding disturbed areas with grass or other ground cover as necessary and feasible. Spoil areas, used for storage during excavation, will be filled and graded to minimize potential erosion before turf cover is established. Maintenance will be performed until the turf has i stabilized to correct local areas of excessive erosion or inadequate turf cover. Fencing and security measures, including bird screens built into the HSMs, will limit site access by and potential hazards to wildlife. Elevated temperatures on and near the fuel storage modules are expected to discourage birds from roosting in this area. With full implementation of the design, operation, and maintenance standards discussed above, potential impacts of modificadons to the DP on vegetation, wildlife, and drainage will be less than significant. Accordingly, SMUD intends to file a certificate for the de minimis fee exemption in accordance with Section 711.2 of the California Fish and Game Code i and Title 14, section 753.5 of the California Code of Regulations. Air Quality Activities associated with construction of the ISFSI that are expected to cause relatively minor dust emissions include site excavadon, hauling of fill, traffic on unpaved roads, grading, and wind erosion of excavated materials. SMUD will perform dry weather wetting and/or paving (graveling) of heavily traveled construction roads as needed to f reduce dust emissions. Fuel burning equipment will be maintained in good mechanical order to reduce excessive emissions. Storage module surface temperatures may increase air temperatures in the immediate vicinity. However, it is expected that the air temperature will return to normal at a short distance from the ISFSI. Because of the relatively small and localized area that will be affected, the amount of heat that is dissipated into the environment will be relatively insignificant. With full implementation of the design, operation, and maintenance standards discussed above, effects of modifications to the DP on air quality will be less l than significant. j Transportation and Noise i Decommissioning activities that are expected to generate traffic and noise include construction of the ISFSI. Shipping of spent fuel and low-level waste during the decommissioning period may affect existing transportation systems in the site vicinity due i to increased vehicle traffic or railroad use. The proposed ISFSI location will facilitate Draft Initial Study / Negative Declaration Supplement PAGE 14 Rancho Seco Decommissioning Plan March 12,1993 4 i i 1

rail access. The distance between the plant site and the closest residence is approximately 0.5 mile. The transfer of spent fuel from the Fuel Storage Building to the ISFSI will. generate a minimal amount of noise. SMUD will cooperate in the implementation of necessary road improvements and other transportation control measures to accommodate traffic associated with shipping of waste material offsite and other decommissioning acdvities, and to minimize traf6c impacts on areas in the vicinity. SMUD will comply with all applicable noise and occupational safety standards to protect workers and other persons from health effects of feud noise levels from demolition of large structures or other decommissioning activities onsite. Noise impacts will be minimized by limiting construction activities to normal working hours and providing trucks and other mechanical equipment with standard noise control devices. With full implementation of the design, operation, and maintenance standards discussed above, potential transportation and noise impacts of modincations to the DP will be less than significant. t Public Services Existing 12 kilovolt (kV) electrical distribution lines will be used to provide power to the ISFSI. This facility will not require an ongoing water supply. Construction scrap and debris will be collected in designated areas for salvage, incineration, or burial. No sanitary waste discharges are anticipated from operation of the ISFSI. With full implementation of the design, operation, and maintenance standards discussed above, potential public service impacts of modifications to the DP will be less than signincant. 1 t Draft Inidal Study / Negative Declaration Supplement PAGE 15 Rancho Seco Decommissioning Plan March 12,1993 l _}}