ML20058F956
| ML20058F956 | |
| Person / Time | |
|---|---|
| Site: | Yankee Rowe |
| Issue date: | 10/18/1990 |
| From: | Denise Edwards YANKEE ATOMIC ELECTRIC CO. |
| To: | NRC OFFICE OF THE SECRETARY (SECY) |
| References | |
| FRN-55FR29964, RULE-PR-51 55FR29964-00007, 55FR29964-7, NUDOCS 9011090244 | |
| Download: ML20058F956 (5) | |
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lf.3 October 18, 1990 SPS90-173 FYC 90-018 i
Secretary of the Commission U.S. Nuclear Regulatory Comission Washington, DC 205555 Attention:
Docketing and Service Branch i
Subjects License Renewal for Nuclear Power Plants Scope of Environmental Effectc Advanced Notice of Proposed Rulemaking (55FR29964)
Dear Sirt Yankee Atomic Electric Company (Yankee) appreciates the opportunity.to comment on this proposed rule regarding environmental effects of license renewal for commercial nuclear power plants.
Yankee is the owner and operator.
of the first plant that will chronologically require a renewal license.
Yankee Nuclear Power Station is also the lead PWR plant selected by the Department of Energy and the Clectric Power Research Institute to demonstrate the validity of the license renewal proceso.
Furthermore, Yankee's Nuclear Services Division provides engineering and licensing services to other nuclear power plants in the northeast, including Vermont Yankee, Maine Yankee, and I
Seabrook.
Yankee has been an active participant in the NUMARC/NUpLEX Working Group since its inception and is gener&lly supportive of the comments that NUMARC has filed in response to the questions posed in the advance notice.
Enclosed with this letter are specific responses by Yankee on these questions. Where appropriate we have specifically endorsed the NUMARC response as consistent with our views.
In addition to those responses, we wish to highlight the following items for consideration.
As noted in answer to Question 1, we believe that a generic environmental survey is the appropriate mechanism to address environmental issues for the purposes of this rulemaking.
We believe that both the NRC and the industry have experience with this particular type of process and that it provides the best way to catalogue the wide variety of environmental impacts pertinent to license renewal.
l 9011090244 901018 PDR PR 51 55FR29964 PDR 1
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1 United States Nuclest Regulatory Commission October 18, 1990 Attention:
Docketing and Service Branch page 2 We believe that the proposed outline in the advance notice is inconsistent with the fundamental concept of the license renewal rulemaking.
That is continuation of the current licensing basis.
License renewal is based on the continuation of maintenance, surveillance, and replacement. of equipment under practices that are currently in existence at all operating plants.
Augmentation of these practices needed to address the aging of critical equipment during the renewal term are being shown by the lead plants to be r
incremental in nature. No major modifications are anticipated to occur at a specific point in time and solely as a result of license renewal. Thus, the environmental impacts of. modifications associated with license renewal.should not differ from the environmental impacts of activities currently underway at all operating Plants. -Since these impacts have already been shown to be minimal, special treatment of the subject for license renewal seems inappropriate.
Further, because of this, the socioeconomic inpacts of license renewal could reasonably be expected to be equally benign.
The reduction of emphasis in these two areas should cause a restructuring of the proposed outline.
We appreciate the opportunity to comment on this advance notice.
We look forward to progress in the process and an opportunity to comment further when a proposed rule is available.
Very truly yours.
D. W. Edwards Director of Industry Affairs DWE/dhm/WPP76/224 Attachment P
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o A,ttachment 1 Response to Question 1 Yankee believee that the rulemaking can be supported by the technical study option. This, we believe, is equivalent to a generic environmental study in which the environmental effecta associated with license renewal could be catalogued as a set of enveloping conditions.
We believe this is preferable to an environmental impact statement because the development of such a document by the staff would constitute an extensive undertaking Which, in the final analysis, probably could not bound all plants for'all issues. NUMARC has provided further support for this choice in their response.
Response to Question 2 The findings of the GES should be codified by classifying the environmental impacts of license renewal as follows:
1.
Those environmental impacts that are either not relevant to license renewal or are insignificant.
For these ingacts, the Commission should make a finding in the rule to that effect, and give the rationale for the finding that each of those issues need not be addressed by the applicant in the environmental report ("ER") or by the NRC in an EA or EIS similar to the codification in Section 51.23 and section 51.53 in the existing part 51.
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2.
Those environmental impacts that are not site-or plant-specific and can be addressed generically for all site and plant characteristics.
For these impacts, the Commission should evaluate the impacts generically in the rule and require that these impacts be incorporated in the applicant's ER, as in Section 51.51 of the existing regulations.
3.
Those environmental impacts that are site-and/or plant-specific, but can be addressed generically for site and plant characteristics within certain ranges or within an " envelope" of site and plant 4
characteristics.
For these impacts, the Commission should describe the impacts generically in the rule together with the envelope of site and plant characteristics under which these generic descriptions are valid.
4.
)Those environmental impacts, if any, that are site-and/or plant-specific and are not otherwise resolved, will require explicit assessment in the applicant's ER and in the NRC's EA or EIS.
l Given the vast body of information developed in previous licensing activities and the operational data which has been compiled, it should be possible to restrict the number of issues which would fall into class 4 to few if any.
Response to Question 3 NUMARC has provided the NRC with a generic environmental report (CER) that characterizes and quantifies the potential environmental impacts that may result from plant license renewal.
The GER was prepared in accordance with
. Wpp?6/224
s (Continued) the format provided in NRC Regulatory Guide 4.2 (" Reg Guide 4.2"), modified as needed to reflect the potential impacts from plant license renewal.
The NRC staff is urged to review this report and identify any perceived needs for clarification or amplification.
Response to Question A We believe the proposed outline for the generic environmental document should be revised. As pointed out in our cover letter, and the NUMARC response to j
this question, the outline appears to provide undue emphasis on modification.
1 These should have no more significant environmental impacts for license renewal than current activities during maintenance outages at operating plants. Also the intention to address decommissioning of nuclear facilities appears to be unnecessary.
NUREG-0588 of August 1988 provides sufficient evaluation of the environmental impacts of decommissioning.
If decommission!ng is discussed at all in this document it would seem that the staff should scknowledge. that in the period of deferment of decommissiot.ing enabled by license renewal that technical advances could likely be expected which would result in reduction to the environmental impacts sited in NUREG-0588.
Response to Question 5 Yankee believes that the NUMARC Ceneric Fnvironmental Report (GER) which has been provided to the Commission identifies the specific environmental issues that should be addressed.
Staff review and comments on this submittal can serve as the basis for further discussions with NUMARC concerning any amplifications or clarifications of this report.
Response to Question 6 s
The NUKARC CER provides the necessary information and data to perform the generic analyses.
Response to Question 7 NEPA imposes no specific requirements for measuring or judging the significance or insignificance of environmental impacts, leaving to each Federal Agency the responsibility for determining impact significance or establishing criteria of significance versus insignificance.
In our judgment, the question of determining impact significance must be accomplished in the same manner as the NRC arrives at the conclusion that a facility provides adequate protection to the public health and safety.
In the supplementary information accompanying the publication of the June S. 1988 revision of the NRC's backfit rule (53FR20603), the NRC noted:
" Commission's rules and regulations are ultimately based on unquantified. and, as we note below, presently unquantifiable ideas of what constitutes " adequate protection." WPp?6/224 i
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, i (Continued)
"Nonetheless, even in the absence of a useful and generally applicable definition of " adequate protection," the Commission can still make sound judgments about What " adequate protection" requires, by relying upon expert engineering and scientific judgment, acting in the light of all relevant and material information."
"Rather than proceeding by an almost ministerial application of " objective criteria," the Commission must fashion a series of case-by-case judgments into a well-reasoned and factually well-supported body of decisions which, acting as reasoned precedent, can control and guide the Commission's exercise of the discretion granted it by Congress in precisely the way in which common-law precedents control and guide the common law judge's exercise of his or judgment."
It is our belief that it was the same type of process which was utilized in reaching the initial decisions concerning the significance and acceptability of specific environmental impacts whet; plants were initially licensed remains valid for the purpose of license renewal.
In fact, given the precedents which have been established and the significant body of operational data which has been accumulated, reasonable judgments of the significance of environmental impacts should be more readily accomplished than was the case in original licensing assessments.
Response to Question 8 We believe that the NUMARC response to Question 8, particularly Table 1, provides a structure under which the impacts associated with license renewal would be treated in a generic rule.
Response to Ouestion 9 We support the NUMARC response regarding the length of operating time that could reasonably be addressed in the proposed rulemaking.
As NUMARC pointed out, we are dealing with existing plants with as many as_ twenty to thirty years of monitoring data.
It is our experience that, quantifiable impacts can be predicted with reasonable certainty for a period twice as long as the period for which the data are available.
Hence, in many areas predictions to 2040 or 2050 can be made for quantifiable environmental impacts.
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-3 WPp76/224