ML20083D146
| ML20083D146 | |
| Person / Time | |
|---|---|
| Issue date: | 08/31/1991 |
| From: | NRC OFFICE OF NUCLEAR REGULATORY RESEARCH (RES) |
| To: | |
| References | |
| NUREG-1440, NUREG-1440-DRFT, NUREG-1440-DRFT-FC, NUDOCS 9109300064 | |
| Download: ML20083D146 (33) | |
Text
t NU R EG-1440 Regu a~:ory Ana ysis 0:? Proaosec Amencmen~:s ~:0 Regu ations Concerning ~::ae Environmental Review :for Renewa~ 0:? Nuclear Power Plant Opera:ino Licenses b
Draft Report for Comment U.S. Nuclear Regulatory Commission OfTice of Nuclear Regulatory Research August 1991 y =cg n
s U
G
AVAILABILITY HOTICE Availability of Reference Materials Cited in NRC Publications Most documents cited in NRC publications will be available from one of the f ollowing sources:
1.
The NRC Public Document Room 2120 L Street, NW., Lonar Level, Washington, DC 20555 2.
The Supenntendent of Documents U.S. Government Pnnting Office, P.O. Box 37082.
Washington, DC 20013-7082 3.
The National Technical Information Service, Springfield. VA 22161 Although the listing that follows represents the majority of documents cited in NRC publica-tions, it is not intende d to be exhaustive.
Referenced documents available for inspection and copying for a fee from the NRC Public Document Room include NRC correspondence and internal NRC memoranda; NRC oulletins, circulars, information notices, inspection end investigation notices; licensee event reports; vendor reports and correspondence; Commission papers; and applicant and licensee docu-ments and correspondence.
The following documents in the NUREG series are available f or purchase from the GPO Sales Program; formal NRC staff and contractor reports, NRC-sponsored conference proceed-ings, and NRC booklets and brochures. Also available are regulatory guices, NRC regula-tsons in the Code of Feoeral Regulations and Nuclear Regulatory Commission Issuances.
Documents available from the National Technical information Service include NUREG-series reports and technical reports prepared by other Federal a0encies and reports prepared by the Atomic Energy Commission, forerunner agency to the Nuclear Regulatory Commission.
Documents available from pubhc and special technical libraries include all open literature items, such as books, joumal articles, and transactions. Feueral Register notices. Federal and State legislation, and congressional reports can usually be obtained from these libraries.
Documents such as theses, d:ssertations, foreign reports and translations, and non-NRC conference proceedings are available for purchase from the organization sponsoring the pubhcation cited.
Single copics of NRC draft reports are available free, to the extent of supply, upon wntten request to the Office of Administrat:on, Distnbution and Mail Services Section, U.S Nuclear Repu!atory Commission, Washington, DC 20555.
Copies of industry codes e Standards umd in a substantive manner in the NRC regulatory process are mainta;ned n'. the NRC Library, 7920 NortoN Avenue, Bethesda. Maryland, for use by the pubhc. Codes and standards are usual!y cocynghted and may be purchased from the ong:nating organdation or, it they are American Nationa' Standards from the Amencan National Standards Institute,1430 Broadway, New York, NY 10018.
NUl(IIG-1440
~
Regulatory. Analysis of Proposed Amendments to Regulations Concerning the Environmental Review for Renewal of Nuclear Power Plant Operating Licenses Draft I{C)) Ort for Comment Manuscript Cosapleted: July 1991 Date Published: August 1991 Division of Safety issue llesolution OITice of Nuclear Itegulatory itescarch U.S. Nuclear Regulatory Commission Washington, DC 20555 e =.
a j
\\.....
ABSTRACT This regulatory analysis provides the supporting information for a proposed rule that will amend the Nuclear Regulatory Commission's requirements for environmental review of applications for renewal of nuclear power plant operating licenses. Af ter considering various options, the staff ider.tified and analyzed two major alternatives.
Alternative A is to not amend the regulations and to perform environmental reviews under the existing regulations. Alternative B is to assess, on a generic basis, the environmental impacts of renewing the operating license of individual nuclear power plants, and define the issues that will need to be further analyzed on a case-by-case basis.
The findings of this assessment are to be codified in 10 CfR Part bl.
The staff has selected Alternative B as the preferred alternative.
NUREG 1440 Draft for Comment iii
TABLE OF CONTENTS Page Abstract iii Acknowledgements vii 1.0 DISCUSSION OF THE ISSUE 1
2.0 OBJECTIVES OF THE PROPOSED RULEMAKING 4
3.0 ALTERNATIVES 5
3.1 Alternative A - No Rulemaking 6
3.2 Alternative B - Undertake Rulemaking to 10 CFR Part 51 to Generically Address Environrental Impacts Potentially Resulting from Nuclear Power Plant License Renewal 6
4.0 COSTS 7
4.1 Cost Basis 8
4.2 Alternative A Cost Impacts 10 4.2.1 Industry Costs 12 4.2.2 NRC Costs 13 4.2.3 Total Alternative A Implementation Costs 13 4.3 Alternative B Cost Impacts 13 4.3.1 Industry Costs 15 4.3.2 NRC Costs 16 4.3.3 Total Alternative B Implementation Costs 17 4.4 Incremental Impacts Associated with the Adoption of Alternative B 17 4.5 Sensitivity Studies 19 4.5.1 Regulatory Development Costs 19 4.5.2 Sensitivity to Environmental Report and EIS/EA Preparation Efforts 21 4.6 Impacts on Other Requirements 22 4.7 Constraints 22 5.0 DECISION RATIONALE 24 REFERENCES 25 1
l NUREG 1440 Draft for Comment v
j
LIST OF FIGURES AND TABLES Page Figure 1 Number of License Renewal Applications per Year 11 Table 1 Implementation Costs for Alternative A 12 Table 2 Implementation Costs for Alternative B 15 Table 3 Incremental Impacts Associated With the Adoption of Alternative B 18 Table 4 Overall Costs Associated With License Renewal Environmental Impact Evaluations and Reviews, 5% Discount Rate 21 Table 5 Sensitivity of Cost Savings to ER and EIS/EA Preparation Efforts, 5% Discount Rate 23 Draft for Comment NUREG 1440 vi
ACKNOWLEDGEMENTS i
Science and Engineering Associates, Inc. provided technical assistance in the conduct of this regulatory analysis.
The principal contributors from Science and Engineering Associates, Inc. were Messrs. Robert Clark, i
Frank W. Sciacca, and Gilbert L. Zigler.
NUREG 1440 Draft for Comment vii
1.0 DISCUSSION OF THE ISSUE
'lhe Nuclear Regulatory Commission (NRC) proposes to issue amendments to its regulations in 10 CFR Part 51 to codify the results of a generic environmental evaluation of the impacts associated with the license renewal of individual nuclear power plants.
The results of this evaluation are contained in the draft Generic Environmental Impact Statement (GEIS) (NbdG-1437).
Exp &ience has shown that for certain environmental and safety issues, rulemaking can yield a number of societal benefits of direct or indirect importance, such as:
(1)
Enhanced stability and predictability of the licensing process by providing regulatory criteria and requirements in discrete genet it areas on matters that are significant in the review and approval of license applications.
(2)
Enhanced public understanding and confidence in the integrity of the licensing process by bringing out for public participation important generic issues that are of concern to the agency and to the public.
(3)
Enhanced administrative efficiency in licensing by removing, in whole or in part, generic issues from staff review and adjudicatory resolution in individual licensing proceedings and/or by establishing the importance (or lack of importance) of various safety and environmental issues to the decision process.
(4)
An overall savings in the utilization of resources in the licensing process by the utility industry, those of the public whose interests may be affected by rulemaking, the NRC, other federal agencies, and State and local government.
Operating licenses for the earliest commercial nuclear plants will begin to expire in the year 2000.
The utility industry, Department of Energy (DOE) and the NRC have hegun laying the groundwork for license renewal that will permit the continued safe and reliable speration of many licensed nuclear power plants well beyond their original 40-year license terms.
Many NUREG 1440 Draft for Comment I
l
~
~_
]-
i electrical utilities have expressec interest in renewing their currently held
[
operating licenses.
The NRC_ understands that the f irst two applications for license renewal
[
will be submitted in 1991-1992. Or the basis of discussions with licensees i-and industry representatives, i,P.c anticipates that a significant percentage of j
existing plants will submit applications for renewing their operating license F
_10 to 20 years before the license _is scheduled to expire.
The NRC has issued a proposed rule,10 CFR Part 54, " Requirements for Renewal of Operating Licenses for Nuclear Power Plants" (55 Fed. Reg. 29043, July 17,1990), that would establish the requirements that an applicant for renewal of a nuclear
]
-power pisnt operating license mun meet, the information that must be l.
submitted to the NRC for review so_that the agency can determine whether these requirements have in fact been met, and the application procedures.
In addition to the procedural and technical rulemaking under 10 CFR Part 54, the NRC is pursuing a ser rate rulemaking on 10 CFR Part 51 to
~
generically address potential environmental impacts from renewal of the operating license f individual nuclear power plants.
This rulemaking defines potential environmental impacts that need to be addressed in submittals to the NRC for review as.a part of the appilcation for license renewal of individual nuclear power plants.
The NRC has concluded that there has been sufficient experience with
_ ower plant operation, maintenance, refurbishment, and associated l
p environmental impacts to predict the types and magnitude of environmental effects that may arise from renewal of operating licenses and the resulting extended plant operation.
As a part of the rulemaking, a GEIS has been prepared to assess which environmental impacts may occur, under what circumstances, and their possible level of 'significence (Ref.1).
Results thus far indicate the feasibility of
~
categorizing-anvironmental impacts as.follows:
Category 1.
A generic conclusion on the impact can be reached for all
- af fected - pl ants.
Category 2.
A generic conclusion on the impact can be reached for plants that fall within defined bounds.
4 NUREG 1440 Draft for Comment 2
-t-
--r, o
Category 3. The environmental impact must be evaluated in each individual license renewal application.
A generic conclusion on the impact was not I
reached for any af fected plants.
in addition, the results of the GEIS and changes to Part 51 provide the bases for a license renewal supplement to Regulatory Guide 4.2, " Preparation of Environmental Raports for Nuclear Power Stations."
The NRC has sought the views of the public, industry, and other federal agencies in preparation fc-this rulemaking.
An advance notice of proposed rulemaking (ANPR) entitled, " License Renewal for Nuclear Power Plants:
Scope of Environmental Effects" (55 Fed. Reg. 29964, July 23, 1990), was issued.
The advance notice outlined the proposed scope of environmental impacts to be addressed, and also identified alternatives for codification in Part 51.
Conments were reque too and the following questions were asked:
1.
's a generic environmental impact statement, or an environmental
- mssment, required by National Environmental Policy Act (NEPA) to
, Jpport this proposed rulem3 king, or Can the rulemaking be supported by a technict.1 study?
2.
Whet alteraative forms of codifying the findings of the generic environmental impact statet 1t shculd be considered?
3.
What activities as',ociated with license renewal will lead to environmental impacts? By what mechanism will they lead to impacts?
4.
Uhat topical areas should be covered in the generic environmental impact statement? Ebould the proposed outline be supplemented or restructured?
5.
For each topical area, wnat are the specific environmental issues that should be addressed?
6.
For each topical area, and each specific issue, what information and data are required to perform generic analyses? Where do the infarmatien and data exist?
7.
For each topical area, and each specific issue, what criteria should be used to judge the significance of the environmental impact?
NUREG 1440 Draft for Comment 3
6.
For each topical area, and each specific issue, what is the potential for successful generic analysis?
9.
What length ol extended operating time can reasonably be addressed in the proposed rulesaking? lo what extent is it possible to reach generic f
conclusion abot the environmental impacts which would be applicable to plants having renewed operating licenses expiring in the year 2030, or i
2040, or 20507 In summary, 29 comments were received: 19 supported the rulemaking, 7 supported it. with qualifications, and 3 opposed it.
An industry group with i
r
[
support from 16 utilities recommended using a generic nvironmental survey as a preferred technical method.
The NRC cJnsidered all of *.he comments and recommendations 1n developing the proposed amendments to part 51, the GEIS, the supporting guidance of Regulatory Guide 4.2, and an Environmental Standard Review Plan (ESRP), NUREG-1429.
I 2.0 OBJECTIVES OF THE PROPOSED RULEMAKING The proposed changes to 10 CFR part 5) will enable the NRC to achieve the following objectives, o
.To simplify the preparation of the environmental report by
. defining the potential generic and specific environmental impacts that must be addressed, o
To improve the efficiency in the NRC's review by removing such generic potential environmental impacts that pose no signi1icant impact to the environment from staff review and adjt.dicatory l
resolution in individual license renewal ~ pr'oceedings, o
To permit the use of an environmental assessment (EA) and a finding of no signif, cant impact (FONSI).
This rulemaking would reduce resource requirements when the information presented in an applicant's environmental report demonstrates that there are no significant I
i NUREG 1440 Draft for Comment 4
i
1 environmental impacts associated with the limited set i
of issues that are assessed.
o Tu identify generic environmental impacts for public participation to achieve understancing and resolution, so that individuhl plant license renewal proceedings will be more efficient.
If most of these objectives are realized, tnere should be an overall savings in the utilization of resources by the public, the utility industry, the f4RC and other federal agencies, and State and local governments.
3.0 AL'ERNATIVES In considering alternatives to the proposed rulemaking for Part 51, the f4RC staff has taken into consideration its past experience with environmental impact statements (EISs), environmental assessments (EAs), generic environmental impact statements (GEISs), generic environr.ent al sur!eys (GESs),
and a detailed review of the public comments on proposed Part 51.
A wide spectrum of possible options were considered.
For example:
1.
no rulemaking 2.
use of a GEIS as basis for proposed amendments to Part 51 3.
use of a GES as basis for amending Part 51 4.
a categorical exclusion for license renewal 5.
establishment of an S-3 type table / chart (551.51) for license renewal 6.
possible combinations of the above On review of these possible options, it was concluded that although the use of the GES (option 3) might eliminate certain publication, review, and NEPA scoping requirements, these marginal advantages were not considered sufficient to outweigh the perceived disadvantage of whether such a non-NEPA document would be able to sustain legal challenges.
In the case of option 4, it was not deemed possible to make the necessary finding that each unit that may apply for license renewal would not have some significant effect on the NUREG 1440 Draft for Comment 5
environment. Option 5 was proven to be impractical since all future environmental impacts of license renewal at individual unit sites were not amenable to gercric assessment now. With the determination to remove options 3, 4, t.nd 5 from consideration, option 6 was no longer deemed reasonable because the remaining options (1 and ?) are viewed to be mutually exclusive.
Accordingly, the remaining options vere judged to provide two reasonable alternatives that could be used to sdequately characterize the costs and benefits of the proposed action to aaend Part $1.
3.1 ALTERNATIVE A - NO RULEMAKING.
1his alternative is a continuation of the current 10 CfR Part 51 regulations that require license renewal applicants to submit to the NRC a comprehensive update to their environmental report (ER).
The whole range of environmental issues related to operation of each Unit and any incremental changes related to extended operation under the terms of license renewal would be addressed.
The NRC staff would have to review this supplement to the ER and prepare a draft EIS that addressed all environmental impacts associated with the extended operation of the unit under the terms of a renewed license.
1his would be done in accordance with hS51.70
'nd 51.71.
Requests for comments on the draf t EIS in accordance with h651.73 ana 51.74 would be required.
1his would be %Ilowea by the issuance of a final EIS and an opportunity for hearing would also be provided for each individual unit's license renewal EIS.
3.2 ALTERNATIVE B - UNDERTAKE RULEMAKING TO 10 CFR PART 51 TO GENERICALLY ADDRESS ENVIRONMENTAL IMPACTS POTENTIALLY RESULTING FROM NUCLEAR POWER PLANT LICENSE RENEWAL.
This alternative limits the er.virnnmental impact issues that must be addressed on a plant-specific basis.
Environmental impact issues that can be addressed in a generic sense would not have to be analyzed on a plant-specific basis.
Rather, these environmental issues and findings associated with license renewal would be treated generically, and this generic treatment would form the basis for a rule change to 10 CFR Part 51 to limit the scope of issues that would need to be consideind in individual applications for license
- renewal, Alternative B would require the review and comment periods for the GEIS as required for the draft EIS under Alternative A.
However, on NUREG 1440 Draft for Comment 6
conclusion of this process, no further analysis or public comment would be required on the findings of the GEIS in individual unit environmental reviews, Category 1 issues would not be addressed.
Licensees would, however, address all Category 2 and Category 3 issues.
The GEIS is projected to limit environmental review activity at the time of individual plant license renewal. Alternative B reduces the effort needed by licensees to prepare their license renewal environmental report (ER) update.
It also reduces the effort needed by the NRC to review the updated [R and to prepare either a EA or an LIS for only a limited number of issues.
If the staff determines publication of a plant-specific draf t EIS is necessary, it would follow the same procedures as in Alternative A including an opportunity for hearing, but would consider a narrower set of issues.
The major difference associated with this determination is that the EA would not require both a draft and final version or consideration of public comments in between.
The EA could result in a finding of no significant impact (f0NSI) or a deterraination that an Els is required.
The cost of an LA and a FONSI will be less than that of an EIS.
However, the following cost estimates are for a full EIS (Alternative A) and a limited EIS ( Alternative B), thus resulting in conservatively low estimates of the savings of implementing Alternative B.
4.0 COSTS This section discusses the cost impacts of the two alternatives identified in Section 3.0.
The two alternatives given above will impact costs to both industry and the NRC associated with license renewal environmental evaluations. Other than cost implications, there are no consequences associated with this proposed rulemaking action.
The environmental documents that must be generated, whether based on the no-action alternative er the approach taking advantage of generic findings, must provide equivalent protection to the environment. Any actions taken as a result of these assessments, therefore, are assumed to be the same for either approach.
That is, the plant configuration and operation into the license renewal period, and the resulting impacts to the environment, would be the same under either alternative. Any changes in plant structures, systems, and components, or in NUREG 1440 Draft for Comment 7
operating parameters would be primarily driven by th( review process tequired by 10 CfR part 54, lhere would be no difference in environmental risk for any plant between the two alternatives, and there would be no difference in radiological exposure associated with either routine operation or accidents.
Therefore, enly cost consequences are applicable, and only these are considered in this analysis, lhe following discussions develop the costs for each approach, and estimate the incremental impacts (savings) associated with the adoption of Alternative B.
4.1.
COST BASIS The cost evaluations for the Part 51 regulatory analysis assune that the effort required to prepare a comprehensive license renewal update to a plant's ER would be roughly comparable to, or at least not greater than, the of f ort required for the update provided at the operating license (OL) stage of a plant's licensing process.
t4UREG-0499, " Preliminary Statement on General Policy for Rulemaking to improve fluclear f'ower Plant Licensing" (Ref. 2),
estimates that such efforts at the OL stage were as follows:
Licensee Efforts for OL Stage ER 5,000 to 15,000 person-hours l4RC Review and EIS Efforts 2,000 to 4,000 person-hours The f4RC efforts cited were those associated with the review of the applicant's ER update, and the preparation of the environmental impact statement for the pl ant.
They include ef forts of both f4RC contractors and f4RC staff.
Both the industry and I4RC effort estimates include allowance for hearings.
The efforts required to perform the equivalent activities for license renewal purposes are estimated to be at about the midpoint of the range cited above for the ER and EIS generated at the OL stage of the original plant licensing.
This estimate is thought to be soniewhat conservative since plants seeking license renewal will have actual environmental impact data to draw upon from the initial construction and operation experience.
Also, ongoing licensee and government agency assessments of nuclear plant environmental f40 REG 1440 Draft for Comment 8
impacts could possibly reduce the effort needed to produce both an ER update for license renewal and the related NRC review efforts.
llowever, the benefit of such information is difficult to quantify a priori, and such information may not be available for all plants.
The efforts associated with the generation of a license renewal ER update, its review by the f4RC, ac.d the generation of the updated EIS for that plant are estimated to be as follows:
Licensee License Renewal ER Update 10,000 person-hours NRC Review and EIS Efforts 3,000 person-hours These estimates are thought to be reasonably representative of what might occur.
There will undoubtedly be considerable varirtion in the effort required from one plant to the next.
The sensitivity of the cost impacts to possible variations in the plant-specific efforts required are addressed in Section 4.5.
The costs associated with generating and reviewing license renewal ERs are based on the following labor rates.
They are taken from f4RC's generic cost estimating guidelines (Ref.3), and the case rates are suitably escalated to reflect 1991 dollars.
Licensee Labor Rate (1991$, fully Burdened)
$49.30/ person-hour NRC Labor Rate (1991$)
$47.90/ person-hour lhe industry rate represents fully burdened cost.
The rate shown assumes that a combination of utility staff and contractors or consultants prepares the ER The NRC hourly rate shown above reflects incremental costs associated with rulemaking actions.
As such, it assumes that certain of NRC's overhead costs are fixed, and would not change because of the proposed rulemaking, in actuality, license renewal is likely to require the hiring of additional liRC staff, and to some extent NRC overhead costs could increase, for the purposes of this analysis, these overhead costs are not included.
The effect of this approach is to understate the cost savings associated with the proposed alternative B.
NUREG 1440 Draft for Comment 9
The draft Gels encompasses 118 commercial nuclear power generating units in the United States.
This excludes Grand Gulf Nuclear Station Unit 2, Perry Nuclear Plant Unit 2, and Washington Nuclear Project Units 1 and 3, whose construction has been indefinitely suspended, lhe 118 units are owned by 52 electric utilities and are located at 74 plant sites, lhis same reactor population, minus Rancho Seco and Shoreham units, were considered as potential applicants for license renewal.
Since multiple unit / plant sites will have to apply separately for each unit, 116 units / plants were assumed to represent the potential number of applications for license renewal that should be considered for the calculation of industry-wide costs.
4.2 ALTERNATIVE A COST IMPACTS Alternative A, as noted above, is the "no rulemaking" option.
Existing regulations regarding environmental assessments must be followed.
These current regulations require that a comprehensive ER update and supplemental EIS be produced for each plant proposed for license renewal.
All environmental issues would have to be addressed.
Table 1 summarizes the cost impacts to both the nuclear industry and to the NRC.
The consequences considering the reactor populatior, as a whole depend on the number of plants for which license renewal is sought.
In lable 1 the costs are given as a fraction of the current plant population applying for license renewal.
The table also shows costs as a function of discount rate.
Rates of 0%, 5%, and 101 are used to cover the practical range of possibilities for the foreseeable future.
For each combination of reactor population fraction applying for license renewal and discount rate, separate values are presented for industry costs, NRC cost, and total costs (combined industry and NRC).
Table 1 displays implementation costs only.
Considerations of development cost impacts are addressed in Section 4.5.
The costs displayed in Table 1 are based on the assumption that applications for license renewal will typically be submitted 12 years before the expiration of the original 40-year license.
This assumption is consistent with the time profile used in NURfG-1362 (draf t), " Regulatory Analysis for Proposed Rule on Nuclear Power Plant License Renewal" (Ref.4).
The exceptions NUREG 1440 Draft for Comment 10
to this assumption apply to the license renewal lead plants, Yankee Rowe, a I
pressurized water reactor (pWR, and Monticello, a boiling water reactor (liWR).
The current licenses for these two plants expire in the years 2000 and 2011, respectively, lhe cost analysis performed here assumed that the Yankee submittal for license renewal would be made in 1991, and that for Monticello would be 1992.
The assumption was also made that both Yankee and Monticello would be in 1992. The assumption was also made that both Yankee and Monticello would be among the plants applying f or license renewal, regardless of the fraction of the plant population to actually do so.
The use of discount rates other thar. 04 requires a time profile of license renewan applications.
Although the actual time profile of applications is unknown, profile used is shown in iigure 1.
The plot shows the number of license renewal applications submitted per year assuming that each submittal is made 12 years before the 40-year license expiration date.
For the cases in which less than 100% of the plants seek license renewal, the further assumption was made that the number of applications submitted in any given year would be proportionally reduced compared to the nun,ber shown in figure 1.
Since the Yankee and Monticello applications are assumed for all scenarios, and :;ince these applications occur in the near future, the costs displayed in Table 1 are not quite proportional to the percentage of plants applying for license renewal.
Changes in the time profile of applications will result in dif ferent present values of cost but does not significantly affect the relative cost of Alternative A compared to Alternative l!.
i 12 "
f10 a
8 i
E 0'
6 4-2 o
1990 1995 2000 2005 2010 2015 2020 20?5 figure 1. Number of ticenselfenewal Applicalions per Year
=
14UREG 1440 Draft for Comment 11
Table 1 Implementation Costs for Alternative A (Cost in 10' 1991 $)
Percent of Reactor Population Discount Rates Applyino_fgrlic.fme RcMsl 0%
h%
IM Industry Costs 25 15.0 8.6 5.8 50
' ).1 16.3 10.6 100 57.?
31.0 20.2 NRC Costs 25 4.4 2.5 1.7 50 8.5 4.7 3.1 t
100 16.7 9.2 5.9 Total Costs 25 19.4 11.1 7.5 50 37.6 21.0 13.7 100 73.9 40.8 26.1 4.2.1 INDUSThY COSTS The licensee's effort needed to prepare a comprehensive, updated ER on any individual plant for which an application for l':ense renewal is submitted is estimated to be 10,000 person-hours.
At $49.30/ person-hour, this results in an estimated cost of about $493.000 per plant in 1991 dollars.
Table 1 indicates that industry costs associated with the preparation of ERs under Alternative A could be as high as $57 million.
This assumes that all 116 plants in the current population (dces not include Rancho Seco and Shoreham) apply for license renewal.
Projected costs decrease rapidly with increasing discount rates.
This occurs because the license renewal applications, and their associated environmentai assessments, are spread out over a considerable period of time.
NUREG 1440 Draft for Comment 12
4.2.2 NRC COSTS As noted in Section 4.1, NRC's ef forts associated with the review of license renewal [Rs and the generat ion of plant (ISs is est imated to be about 3000 person-hours per plant under Alternative A.
This equates to NRC labor costs of about $144,000 per plant.
Table 1 presents estimates of NPC costs when considering the overall reactor population that may apply for license renewal.
The NRC (osts associated with Alternative A implement ation are estimated to be as much as
$17 million or as little as $2 million, depending on the number of relicensing applications received and processed and on the discount rate assumed.
4.2.3 TOTAL ALTERNATIVE A IMPLEMENTATION COSTS The totals shown in Table 1 indicate that the combined cost to both industry and the NRC are estimated to be in the range of about $7 million to
$74 million.
The values displayed for the SI discount rate are judged to be most realistic, and for this scenario the costs range f rom about $11 million to $41 million.
4,3 ALTERNATIVE B COST IMPACTS The draf t GEIS groups all of the various potential environmental impacts into 104 issues, it classifies each such issue according to the three categories noted in Section 1.0.
Of the 104 environmental impact issue groupings evaluated in the draft GELS, many are of potential consequence only for certain types of plants.
A maximum of 97 issue groupings would have to be addressed for any individual plant.
Key parameters establish the number of issue groupings pertinent to a given nuclear plant include, the type of cooling system and the ultimate heat sink.
The draft GELS identified 24 license renewal environmental impact issues that fell into Categories 2 and 3.
These are the issue groupings that all plants which make license renewal applications could address, or which could be addressed by all such plants whose impacts might fall cutside of the bourids evaluated in the GELS, On the NUREG 1440 Draft ior Lomment 13
other hand, more than eighty 80 issues are addressed on a generic basis (Category 1), and need not be addressed in individual license renewal applications.
The computation of Alternative B costs, therefore, involved evaluating the number of non-generic issues associated with the different types of nuclear plants.
A review of the Category 2 and 3 areas indicates that several apply only to certain types of plants.
For example, in aquatic ecology three Category 2 issues apply only to plants with once-through heat dissipation systems and another three apply only to plants with cooling pond heat dissipation systems.
This analysis is based on the simplifying assemption that each aw'icant for license renewal will expend effort on 22 issues on a plant-specific basis.
Given the number of issues to be addressed on a plant-specific basis, cost consequences associated with Alternative B can be assessed for individual plants and for the industry as a whole.
This requires that assumptions be made about the cost of addressing each plant-specific issue.
for the current assessment, cost per area was established simply by dividing the total offort needed to perform a comprehensive assessment by the maximum number of issues addressed in such an effort, in reality, of course, each environmental issue will require an evaluation involving either more or less than the average effort.
The effort required will depend on the complexity of the issue, and for a particular issue will likely vary from one plant t,o the next.
While issue-specific complexity could have been assessed, and labor ef forts adjusted accordingly, this approach would introduce additional uncertainties into the evaluation and was not used in this analysis.
The NRC's costs associated with the review of the licensee's ER submittal, and the preparation of the corresponding EIS or EA, were estimated in a manner analogous to the development of licensee costs.
NRC's labor effort per issue was established on the basis of the estimated effort needed to conduct a comprehensive rev.ew of full scale ER, as discussed in Section 4.1.
Table 2 summarizes the estimated cost impacts to both industry and the NRC associated with the implementation of Alterr.ative B.
As with Table 1 for Alternative A, costs are shown for three discount rates and for three NUREG 1440 Draft for Comment 14
different fractions of the light-water-reactor power-plant population seeking license renewal.
lotal imp'cinentation costs are also shown.
Table 2 Implementation Costs for Alternative B (Cost in 10' 1991 $)
Percent of Reactor Population Discount Rates ApphintioLLintisLRemwa1 Q%
E%
1Q%
Industry Costs 25 4.8 3.0 2.3 50 8.6 5.1 3.6 100 16.3 9.3 6.2 NRC Costs 25 1.4 0.9 0.7 50 2.5 1.5 1.0 100 4.7 2.7 1.8 Total Costs 25 6.2 3.9 3.0 50 11.1 6.6 4.6 100 21.0 12.0 8.0 4.3.1 INDUSTRY COSTS As noted in Section 4.1, the licensee's effort needed to prepare a comprehensive, updated ER on any plant for which an application for license renewal is subr.itted is estimated to be 10,000 person-hours.
Considering a maximum of 97 issues to be addressed in a comprehensive effort, this yields an average of slightly more than 103 person-hours per issue.
This per-issue effort, coupled with the estimate that each plant will have to addi'ess 22 plant-specific issue areas, yields estimates of industry costs.
For the industry as a whole, assuming 116 plants apply for license renewal, and for NUREG 1440 Draft for Comment 15
1 1
the " average" plant offort associated with Alternative B, the results are as l
follows:
Total Industry Cost (Undiscounted 19915)
$16 million Average Plant Cost (Undiscounted 1991$)
$134,000 The average plant costs given here do not factor in the costs incurred by the lead plants, lhe industry costs noted above assume that the two lead plants, Yankee and Monticello, will not benefit from the proposed Part 51 rulemaking, and that both plants will have to prepare comprehensive ERs.
The costs for their efforts are assumed to be $493,000 per plant, and these costs are reflected in the $16 million quoted for the total industry cost.
Also, this industry total cost assumes that all 116 plants in the reactor population apply for license renewal.
1he costs are undiscounted, that is, they do not reflect the time spread over which these expenditures are likely to occur, The Alternative 1 consequences to industry as a whole depend on the number of facilities for which license renewal is sought, lhe values presented in Table 2 indicate that costs to industry under Alternative B are estimated to range from as little as $2.3 million to more than $16 million, depending on the scenario considered.
The costs displayed in lable 2 are based on the same set of assumptions used to define Alternative A consequences.
They assume that, except for the Yankee and Monticello plants, license renewal applications will typically be submitted 12 years before the expiration of the original 40-year license.
1he time profile of number of applications per year shown in figure 1 was used to develop Table 2.
4.3.2 NRC COSTS Section 4.1 noted that the NRC's effort to review a comprehensive license renewal ER and prepare the attendant EIS is estimated to require on the order of 3000 person-hours.
On the basis of a total of 97 issues that would be addressed in a comprehensive effort as discussed previously in NUREG 1440 Draft for Comment 16
Section 4.3, this gives an average ef fort of slightly more than 30 person-hours per-issue area.
NRC's potent ial overall expendit ures f or indust ry-wide relicensing (R reviews are estimated below.
Per-plant average expenditures are also noted.
10tal Pot ntial NRL Cost (Undiscounted 19915)
$4.7 million NRC Average Per-Plant Cost (Undiscounted 19915) 539,000 lable 2 gives NRC costs associated with the adoption of Alternative B.
Costs are displayed on the basis of the percentage of the reactor plant population seeking i ncense renewal and en alter nat Ive discount rates.
4.3.3 TOTAL ALTERNATIVE D IMPLEMENTATION COSTS The totals shown in lable 2 indicate that the Alternative B combined impienentation ccst to both industry and the NP.C is estimated to be in the range of about $? million to $21 million.
lhe lower figure correspond < to a small f raction of the reactor population pursuing license renewal together with a high (10%) discount rate.
The high figure corresponds to all plants seeking license renewal and OX discount rate.
lhe values displayed for the $t discount rate are judged to be most realistic, and f or this scenarm the costs range from about $4 million to $12 million.
4.4 INCREMENTAL IMPACTS ASSOCI ATED WITH THE ADOPTION Of ALTERNATIVE B Nuclear plant license renewal, if it is pursued, will require t hat applicants assess potential environmental impacts associated with extended plant life.
This requirement can be met with either Alternative A, the no--
rulemaking alternative, or Alternat ive B whic h reduces t he number of envitonmental issues that must be addressed on a plent-specific basis.
the proposed changes to 10 CfR Part bl. and as represented by Alternative B, can significantly rcduce the burden on both industry and the NRC regarding the preparation and review of environmental report updates associated with license renewal and the preparation of the llS/l A.
lhe draf t Gilh indicates that, of NUREG 1440 l) raft for Comnent 17
I the total issues that must be addressed, the majority can be addressed on a generic basis.
The proposed changes to 10 CfR part 51 would limit those license renewal environmental issues which need to be considered on a plant-specific basis and, therefore, would result in significant cost savings to both industry and the NRC.
Table 3 summarizes these estimated cost savings.
Overall industry savings are estimated to rangr> from about $41 million for a high percentage of the plant population seeking license renewal and a low discount rate to about $3 million if few plants apply and a high discount rate prevails.
Savings to the NRC attributable to the adoption of Altornative D ranges from about $12 million to about $1 million over the range of conditions noted. The combined savings to both industry and the NRC ranges from about
$53 million to $4 million.
Table 3 Incremental Impacts Associated With the Adoption of Alternative B (Cost in 10' 1991 $)
Percent of Reactor population Discount Rates Discount Rates Applying __foLLi_conse_ Renewal QY.
S'i
_ _ J QT._
Industry Costs 25
(-)l0.2
(-)5.6
(-)3.5 50
(-)20.5
(-)ll.2
(-)7.0 100
(-)40.9
(-)22.3
(-)l4.1 NRC Costs 25
(-)3.0
(-)l.6
(-)l.0 50
(-)5.9
(-)3.3
(-)2.1 100
(-)ll.9
(-)6.5
(-)4.1 Total Costs 25
(-)l3.2
(-)7.2
(-)4.5 50
(-)26.4
(-)l4.5
(-)9.1 100
(-)S2.9
(-)28.8
(-)18.2
(-) Denotes cost savings NUREG 1440 Draft for Comment 18
4.5 SENSITIVITY STUDIES This section discusses the effects of two different elements that can be considered in defining costs of the two alternatives, lhe first considers the effects of NRC's regulation development costs.
The second considers the effects of the base level of effort required to prepare and review the necessary environmental impacts documentation.
4.5.1 REGULATORY DEVELOPMENT COSTS 1he NRC has expended considerable resources in the development of the proposed thrnges to 10 CFR Part 51.
lhese resources include the efforts needed to develop the proposed changes, prepare the draft GEIS, and perform related actions, lhe proposed rule will also require the development of a regulatory guide for the preparation of updated license renewal environmental reports.
Similarly, an environmental standard review plan must be developed to assist the NRC in its review of the ERs submitted with license renewal applicaticns.
NRC development ef forts are also associated with Alternative A, which is the continuation of current requirements, in the absence of the proposed changes to 10 CFR part 51, an updated license renewal environmental report regulatory guide is still needed, as is an updated environmental standard review plan for the review of these environmental documents submitted by applicants.
Estimates of NRC's regulatory development ef forts and costs associated with both Alte native A and the proposed Alternative B are as follows:
Item Alternative A Alternative B NRC Professional Staff Effort 14 staff months 88 staff months Staf f Cost,1991$
$116,000
$730,000 Contractor Assistance, 1991$
$1,150,000
$3,800,000 Totals, 1991$
$1,270,000
$4,530,000 NUREG 1440 Draft for Comment 19
I The major distinction between the dev(lopmental costs of Alternatives A and B, aside from their absolute size, is that A's costs are yet to be incurred whereas D's, for the most part, are already sunk Because Alternative A's developmental costs are still outstandi g they are an appropriate consideration in this regulatory analysis.
Daly if A is selected will developmental costs on the order of $1 million be expended.
Thus, the incremental cost to proceed with A is $1 million. Alternatively, if B were chosen, the incremental impact would be considerably smaller because most of its developmental expenditures are sunk costs and as such are no longer relevi.nt.
That is, the sunk costs exist independent of our ultimate decision and, therefore, they are not incremental irrpacts that can be attributed to Alternative B.
That portion of B's developmontal costs that are still outstanding are relevant but are projected to t;e smaller than A's developmental costs.
However, to stay on the conservative side, the staff assumes they are equivalent and thus the cost implications of NRC developmental costs are assumed to be neutral in this regulatory analysis.
In order to see if these sunk cost s would have any ef fect on the bottom line conclusions, a sensitivity study was performed that includes the sunk costs.
Table 4 shows the impact on costs when the expenditures for NRC's regulation development are included in the assessment.
The values shown are based on a 5% discount rate.
Separate sets of figures are shown for Alternative A, Alternative B, and the differences between Alternative B and Alternative A.
The higher development costs of Alternative B are more than offset by the savings possible by implementing the proposed changes to 10 CfR Part 51.
With the 5% discount rate, the savings range from about $4 million to aoout $26 million, depending on the number of plants seeking license renewal.
At lower discount rates the savings increase fo. Alternative B relative to Alternatise A.
E',en under the conditions of a small f raction (25%) of the reactor population applying for liunse renewal and a higher discount rate (~10Z), Alternative B remains less costly than Alternative A, including consideration given to the greatcr regulation development casts of Alternative B.
NUREG 1440 Draft for Comment 20
Tabic 4 Overall Costs Associated With License Renewal Environmental Impact Evaluations and Reviews 5% Discount Rate (10' 1991 $)
Incremental Costs Percent of Reactor Population Alterrutive Alternative Alt, B j
._Jpplying for License R9Aeyal
_A_
B-
._Rclatlys_to_Alti.]
l Industry Costs i
25 8.6 3.0
(-)S.6 50 16.3 5.1
(-)ll 2 100 31.6 9.3
(-)22.3 25 2.5 0.9
(-)1.6 50 4.7 1.5
(-)3.3 100 9.2 2.7
(-)6.5 NRC Development Costs 1.3 4.5 3.2 Total Costs 25 12.4 8.4
(-)4.0 50 22.3 11.1
(-)l1.2 100 42.1 16.5
(-)25,6
(-) Denotes cost savings i
4.5.2 SENSITIVITY TO ENVIRONMENTAL REPORT AND EIS/EA PREPARATION EFFORTS l
Section 4.1 noted that there is uncertainty in the level of effort required for licensees to prepare an ER supplement to accompany their license renewal submittals.
Similarly, the level of effort to be_ expended by the NRC in the review of these submittals and the attendant preparation of the EIS for each lant are also somewhat uncertain, lhe reference level of effort assumed for the licerisee to prepare an ER for Alternative A was 10,000 person-hours, and the corresponding WRC review and EIS/EA preparation effort was 3,000 person-hours.
By taking full advantage of existing ERs and the environmental impact data collected over the years of plant operation,_ licensee ef forts
_ could possibly be considerably less than the base effort assumed.
Similarly, larger efforts are also possible.
For applications for which a FONSI is NUREG 1440 Draf t for Comment 21 l
supportable, it is likely that a lower level of effort may be necessary of applicants as well as the liRC.
The sensitivity of the cost results to the level of ef fort required to prepare and review the necessary environmental impact documents was explored.
Table 5 shows the results of this sensitivity siudy.
lhe savings attributable to the adoption of Alternative B relative to Alternative A are shown for the reference case, and for cases based on 0.5 and 1.5 times the reference level effort.
The cost savings vary directly with the base level of effort required except for the consideration of regulation development costs.
The development costs are assumed to remain fixed, regardless of the base LR/EIS/EA preparation efforts assumed.
As indicated in Table 5, the cost savings possible by adopting Alternative B decrease if the labor ef fort is lower than that assumed for the reference case, and they increase if a higher labor effort is assumed.
4.6 IMPACTS ON OTHER REQUIREMENTS The proposed 10 CFR PLrt 51 will have no effect on other flRC programs.
There will be a benefit in the implementation of 10 Cf R Part 54, " Requirements for Renewal of Operating Eicenses for fluclear Power Plants," but no other interactions.
Since this rulemaking applies specifically to fiRC licensees, no impact on other government agencies or State programs is foreseen.
4.7 CONSTRAINTS Since the lead time for applications for license renewal can be to 20 years, there will be no constraint to implementation arising from scheuuling.
The time allowed for public participation through the advance notice of proposed rulemaking (ANPR) and the publication of a proposed rule for comment should ensure that policy, institutional or legal considerations that arise will be resolved before issuance of tha final rule change.
Enforceability of the amended 10 CFR Part 51 will be no different than enforcement of the regulations of the existing 10 CFR Part 51.
Since publication of the final rule, no enforcement problems have been experienced.
It should be noted, NUREG 1440 Draft for Comment 22
however, that this rulemaking schedult. may not significantly benefit the two lead plants (Yankee Rowe and Monticello) which will submit applications in 1991 and 1992.
1he extent of any benefits cannot be quantified for these lead plants, even though the information developed thus far will be used to support the staff's environmental findings for each plant.
Table 5 Sensitivity of Cost Savings to ER and EIS/EA Preparation Efforts, 5% Discount Rate (10' 1991 $)
i Incremental Costs of Alternative B Relative to Alternative A Percent of Reactor Population-0.5 x Base Base 1.5 x Base Apphing_fgr_Ltcenic_ Renewal Caw Cne-E ne___
Industry Costs 25
(-)2.8
(-)S.6
(-)8.4 50
(-)5.6
(-)ll.2
(-)l6.8 100
(-)11.2
(-)122.3
(-)33.5 NRC Costs 25-(-)0.8
(-)l.6
(-)2.4 50
(-)).7
(-)3.3
(-)b.0 100
(-)3.2
(-)6.5
(-)9.8 NRC Development Costs 3.2 3.2 3.2 Total Costs 25
(-)0.4
(-)4.0
(-)7.6 50
(-)4.1
(- ) 11 -. 2
(-)18.6 100
(-)ll.2
(-)25.6
(-)40.1
(-) Denotes cost savings
'!1UREG 1440 Draft for Comment 23 s.,._m
,m....
..__,..,._...-._.,-._.__....._.......-...,,,,__,,.-,,=_,,.___.m,~.
,_.._,... _._ _ _ _ _.,.. _.,___. __.=..._.-...
5.0 DECISION RATIONALE Adoption of the proposed rule would minimize the costs associated with evaluating the environmental impacts caused by extending the operational licenses of commercial nuclear poner reactors.
Thcre are no other impacts associated with the adoption of the proposed rule.
The adoption of the proposed rule is estimated to result in substantial cost savings to both the nuclear industry and to the fiRC Savings are anticipated because the rule change would reduce the license renewal environmental impact issues that need te be addressed on a plant-specific
- basis, lhe proposed change to 10 Cf R part 51 would reduce or eliminate duplication of effort among license renewal applicants in addressing those environrnental issues f or which a generic conclusion can be reached on the acceptability of the impacts f or all af fected plants.
Overall industry savings are estimated to range from a high of about $41 million to about $3 million, depending on the percentage of the plant population seeking license renewal and the discount rates applicable.
Cost savings to individual applicants for license renewal are estimated to be about $360.000.
Total liRC savings due to the adoption of Alternative B range from about $1 million to about $12 million over the range of conditions noted.
Considering the costs to both indust ry and the liRC, the total cost savings with Alternative B ranges from $5 r.;illion to 13 million, With the usa of the 5% discount rate, judged to be the most r<alistic scenario, the savings ranges from $7 million to $29 million.
On the basis of the findings of this analysis, the staff has selected Alternative B cs the preferred approach.
liUREG 1440 Draft for Comment 24 i
O REFERENCES 1.
NUREG-1437, Vols. I and 2 (draf t for comment), " Generic Environmental Impact Statement for License Renewal of Nuclear Plants," U.S. Nuclear Regulatory Commission, August 1991.
2.
NUREG-0499, " Preliminary Statement on General Policy for Rulemaking to improve Nuclear Power Plant Licensing," U.S. Nuclear Regulatory Commission, December, 1978.
3.
NUREG/CR-4627, Rev. 1, " Generic Cost Estimates:
Abstracts from Generic Studies for Use in Preparing Regulatory impact Analyses," U.S. Nuclear Regulatory Commission, February 1989.
4.
NUREG-1362 (draf t for comment), " Regulatory Analysis for Proposed Rule on Nuclear Power Plant License Renewal," U.S. Nuclear Regulatory Commission, July 1990.
NUREG 1440 Draft for Comment 25 ll
V $ NLK Li A84 0 t UUL AIott y ( OMuinet.N
, e t t h.n I 45 >y gg t n NMC f Osand 3 s*,
UC.7 ""i.* *.'..*T,' 'l", "*'
f.3 not_
unam BlullOGRAPHIC DAT A SHEET g g.,) p g u
a,.n.mn,, n, s r,r.~
T lill t Atsu !.U8 7 41( t Regula1 Dry An.ll)31 s of Proposed Amendment s 10 Regul 3tiOns r.oncerning the Environment al Review fo^ keneal of Nuclear
)
o Au "noni triu."t o Power Ilant Operating liCDnses
]
~
'M' "K' W
~
4 Draf t Report for Comnent
- t. l i f t (if 640091 b AVIHUP(M b'Qul a t fif y
/. I' t M 100 t Ov i D I o "a. t.,.... p.mi e r t u e o e u iNb, ww.A N iz A nun - N Au ( A n o A o 09 t ss ", = *c, -. o.
o,.
., a e i u.,
....w,.,, o.,
.. m
,,.a.<
u...
onb
,,... m o..
o Division of Safety issue Resolution Of' ice of fJuclear Regulatnry Resnarch U.S.
wclear Regulator y Commission Wasnington, DC 20555 s e i.m.
eo, p, m 4
- t p.. w,s et e., o p.,,.. U A % e., #% a.so,, (
n.
o 9 SPONh0 H tN'., D AG ANil AllON _ N Av t t. NU Aoo M i SS,,# f. Ar r,s
%w...t. '
oner,es kngt wss !
Division of Safety issue Resolution Ofilce of Nuclear Regulatory Research U.E. Nuclear Regulatory Commission Wathington, DC 20555 to sveet t ut N1 Aww Nott s 11 Aish1 H A(.1 # Ao.o,es, e, *w This regulatory analysis provider, the supporting inf ormtion f or a proposed rule that will amend the Nuclear Regulatory Commission' requirements for environmental review licenses.
After con-of applications for renewal of nuclear power plant operatin]
sidering various options, tha staf f identified and analyzed two major alternatives Alternative A is to not amend the regulations and to perf nra environmental revie'.o Alternative B is to assess, on a generic basis, the under the existing regulations.
iridividual nuclear power environmental impacts of renewing the operating license oi plants, and define the issues that will need to be further analyzed on a case-by case The The findings of this assessment are to be codified in 10 CFR Part 51.
ba si s.
staf f has selected %1ternative B as the preferred alternative.
I o-..,mo,,-...,
u u, wo ov oi s- > o r s, o.,
.. _ r.... ~,
..,..,_,....., ~,,,_,,,
unlimited license renewal
~
nuclear power plant
'2'_" ";,'. ' " ' * "" "* _
<"-s->
environmental protection unclassified regulatory impact analysis
,, ~,,,,,,
0..
}
1S NUY16t H 06 F Abt d t ti t' Hill httC f DRM 335 f/ 489)
-~
I 1
51 THIS DOCUMENT WAS PRINTED USING RECYCLED PAPER
i AUGUST 1991 REGULATORY AN ALYSIS OF PROPOSED A%1ENDN1ENTS TO REGULATIONS CONCERNING Tile S L Rtir-l+48 EMIRONNIENTAL REVIEW FOR RENEWAL OF NCCLEAR POWER PLANT OPERATING LICENSES j
I i
5 1
lN$
3 s:
ol
'b :3 ' fl E
! "2
?
iI
-s
!!2
'l
!!E II k
i z
O E
50 2$
5 ss us O N eM.
wO,;
c3 Y
Tw
<y D
%~
c o, 4 p
'O f Y S$
o<o m
w _,4 *-
$2 C33 92 20=
U$b 5
C 5
0 4-a w
.a O
3z