ML20090J958
| ML20090J958 | |
| Person / Time | |
|---|---|
| Site: | Monticello, Prairie Island  |
| Issue date: | 03/12/1992 |
| From: | Parker T NORTHERN STATES POWER CO. |
| To: | NRC OFFICE OF THE SECRETARY (SECY) |
| References | |
| FRN-56FR47016, RULE-PR-51 56FR47016-00032, 56FR47016-32, NUDOCS 9203180139 | |
| Download: ML20090J958 (23) | |
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March 12, 1992 !.i o 3
Secretary of the Conunission US Nuclear Regulatory Commission
- Washington DC 20555 Attention
- Docketing and Services 15 ranch Comments on the 10 CPR Part 51 Proposed Amet*dment and the Sutsttort f rut Documents for License Renewal Written conunents were invited to be submitted on a proposed amendment to 10 CPR Part 51 regulations as noticed in the Pederal Register, Volume 56, Number 180, dated September 17, 1991. These conanents are to be submitted by March 16, 1992. This regulation amendment will establish new requirements for envirotunental review of applications to renew operating licenses for nuclear plants. This letter forwards our comments.
The Nuclear Managottent and Resources Council (NUMARC) put together adhoc committees, of which we took part, to develop industry comments on the proposed amendment to 10 CFR Part 51 regulations and the Generic Envirotunental Impact Statement, NUREG 1437, including the supporting documents. We fully endorse the comments submitted by NUMARC and have not repeated those comments with our submittal.
Attachments 1 and 2 to this letter are mornorandums put together for us by the law firm of Shaw, Pittman, Potts and Trowbridg3. Attachment 1 discusses the use of average bounding versus upper bounding analysis in the Generic
- Environmental Impact Statement for generically evaluating individual effects when site specifie inforrnation is not available. The second attachttent discusses our position on the requirement to demonstrate the cost benefit of operating a nuclear plant rather than a coal fired plant, that contradicts existing NRC and federal case law.
Attachment 3 includes comments on information contained in the Generic Environmental Isrpact Statement that is specific to our Monticello and Prairic Island Nuclear Plants. There are also comments on the draft Regulatory Guide DG 4002 and the draft Standard Review Plan, NUREG 1429. These remarks are in response to questions that arose when we used these documents during the writing of Monticello's Environmental Report Supplement for License Renewal.
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March 12, 1992 .
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Please contact us if you have any questions or further information is required on this issue ,
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/ 1 IOM ' l Thomas H. Parker Manager j Nuclear Support Services ,
i c: tiRR Monticello Project Manager, NRC l Monticello Resident Inspector, NRC j 1
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MEM0RANDUM February 14, 1992 Comments to be Submitted on License Renewal GEIS Concerning Economic Evaluation of Alt'rnatives to Renewal of Nuclear Plant Operati License These comments are intended to be-submitted on the proposed revisions to Part 51 addressing the requirement that a nuclear plant license renewal applicant demonstrate that it is cost-beneticial to operate a nuclear plant rather than a coal-powered plant.
The proposed rule sets forth the requirements for complying with NEPA in connection with consideration of operating license renewal of a nuclear power plant. The proposed amendment at issue is 5 51.53(c)(3)(ii)(J), which would require the license renewal applicant to demonstrate that "[t]he replacement of equivalent generating capacity by a coal-fired plant has no dem-onstrated cost advantage over the individual nuclear power plant license renewal." Such a requirement would force a license-renewal applicant to engage in an economic cost-benefit analysis of an alternative to the proposed action.
Under federal case lav, (aln alternative which vould result in similar or_ greater (environmental) harm need not be dis-cussed." Sierra g_1,ub v. Morton, 510 F.2d 813, 825-(Sth Cir.
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J 1975). See also Massachusetts v. Andrus, 594 F.2d 872, 885 (1st Cir. 1979); Natural Resources Defense Council v. SEC, 606 F.2d 1031, 1054 (D.C. Cir. 1979); Citizens' Committee Acainst Inter-state Route 675 v. Lewis, 542 F. Supp. 496, 540 (S.D. Ohio 1982); i Trinity Episcopal School Corp. v. Harris, 445 F. Supp. 204, 221 (S.D.N.Y. 1978). A coal-fired plant is not environmentally pref-erable to a nuclear plant; therefore, a proposed rule which would force a license renewal applicant to engage in an economic !
cost-benefit analysis of an environmentally inferior alternative clearly contradic*.s federal case law.
Moreover, an economic consideration of an alternative is not required by NEPA. There is no such directive in the Act itself, nor a case which interp..cs NEPA to require such an analysis of an alternative:
While the consideration of pertinent alternatives requires a weighing of numerous matters, such as economics, foreign relations, national security, the fact remains that, as to the-ingredient of possible adverse environmental impact, it is the essence and thrust of NEPA_that the pertinent Statement serve to gather in one place a discus-sion of the relative environmental impact of alternatives.
Natural Resources Def ense Council v. Morton, 458 F.2d 827, 834 (D.C. Cir. 1972) (emphasis added). Any economic analysis of an alternative is clearly beyond the scope of the Act and an inter-ference with its objective. ,
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In addition. NRC adjudicatory decisions make clear that NEPA is concerned with environmental alternatives, not economic alter-natives: "But if there are no preferable environmental alterna-tives, such cost-benefit balancing does not take place. Mani-festly, nothing in NEPA calls upon us to sift through environmen-tally inferior alternatives to find a cheaper (but dirtier) vay of handling the matter at hand . . . . In short, as far as NEPA is concerned, cost is important only to the extent it results in an environmentally superior alternative." Consumers Power Co.
(Hidland Plant, Units 1 and 2), ALAB-458, 7 NRC 155, 162-63 (1987). See also Dairviand Power Cooperative (La Crosse Boiling Water Reactor), LBP-82-58, 16 NRC 512 (1982); Cincinnati Gas and Electric Company (William H. Zimmer Nuclear Station), LBP-80-24, 12 NRC 231 (1980); Public Service Electric and Gas Company (Salen Nuclear Generating Station, Unit 2),. DD-80-17, 11 NRC 596 (1980);
Vircinia Electric and Power Company (North Anna Nuclear Power
' Station, Units 1 and 2), ALAB-584, 11 NRC 451 (1980).
This line of NRC cases sets forth in clear, unambiguous _
1 terms the Commission's position that NEPA requires a hard_ look at environmental impacts. If an environmentally superior alterna-tive does not exist, economics should not be discussed. Because a coal plant is not environmentally preforable to a nuclear
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plant, the EIS is prohibited from addressing the economic
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t In conclusion, a rule which requires a nuclear plant license renewal applicant to demonstrate that it is cost-benefleial to operate a nuclear plant rather than a coal-fired plant directly contradicts existing NRC and federal case law. Furthermore, the requirement of such an economic analysis misconstrues the purpose
- of NEPA and may very well subvert the objective of the Act itself. We therefore respectfully ask the Commission to recon-sider its proposed rule in light of. the potential litigation if such a rule is promulgated.
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MEM0RANDUM February 6, 1992 Average-bounding vs Upper-bounding Analysis !
SUMMARY
_AND BACKGROUND in anticipation of applications from nuclear power plants to renew their operating licenses, the Nuclear Regulatory Commission (NRC) has proposed revisions.to its license renewal regulations.
56 Fed. Reg. 47,016 (1991). The proposed rulemaking is supported by a generic environmental impact statement (GEIS) which dis-cusses 104 potential environmental effects of license renewal, ,
covering all known or reported types of impacts related to refur- .
bishment and continued operation of nuclear. power plants..
site-specific and plant-specific information is employed where available to form conclusions on each impact and its severity.
Where specific information on each plant is not available to the NRC, representative or case study information is evaluated.
These comments address whether it is necessary for the NRC to conservatively-bound its impact analysis when generically evalu-ating individual effects for which site-specific information is not available. The upper-bounding methodology employed in the Gels in several sections goes beyond what_is required by the National Environmental Policy Act (NEPA), 42 U.S.C. S 4321-4370 (1988). The GEIS uses conservative, upper-bounded estimates in
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Its analysis of the impacts of radiation doses to the public and to refurbishment workers, in its selection of case study plants for socioeconomic impacts, in its evaluation of the offects cf cooling tower operation on crops and ornamental vegetation, and in several other instances. Instead, estimates based on repre-sentative or average-bounded effects should be used to properly reflect the scientific probabilities of the environmental impacts of license renewal.
The NRC is not required by the case law to use conservative and extreme impact analysis methods in environmental impact statements it prepares. NEPA requires that federal agencies pre-pare a detailed statement disclosing the environmental and other impacts of a proposed action. 42 U.S.C. S 4332-(1988). The preparation of this environmental impact statement (EIS) is a procedural requirement; NEPA does not mandate particular results, merely that an agency take a "hard look" at the effects on the environment that will be caused by the proposed action. Kleoce
- v. Sierra Club, 427 U.S. 390, 410, 96 S. Ct. 2718, 2730 (1976).
Agencies need not discuss every conceivable alternative to a pro-posed _ action, but should be guided by a " rule of reason," and they are not required to probe remote or speculative consequences of a proposed action. Vermont Yankee v. Natural Resources Defense Council, 435 U.S. 519, 551, 98 S. Ct. 1197, 1216 (1978) b
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t (citing Natural Resources Defense Council v. Morton, 458 F.2d 827, 837 (D.C. Cir. 1972)). Similarly, NEPA does not require that an EIS evaluate "vorst-case" scenarios, but simply the rea- 1 sonably foreseeable significant adverse effects of the proposed action. Robertson v. Methow Valley Citizens Council, 490 U.S.
332, 354-355, 109 S. Ct. 1835, 1848 (1989).
Neither the NRC's regulations implementing NEPA,1 nor the regulations of the Council on Environmental Quality (CEQ) imple-menting NEPA,2! require the NRC to us2 :onservatively bounded-impact analysis.1/ CEQ regulations require agencies to include sufficient detail in an EIS to allow a decisionmaker to make an informed decision. 40 C.F.R. S 1502.1 (1991). In the face of incomplete or unavailable information, however, agencies are required only to evaluate reasonably foreseeable significant adverse effects, bounded by a rule of reason and supported by credible scientific evidence. 51 Fed. Reg. 15,620 (1986) 1/ 10 C.F.R. 5 51 (1991).
2/ 40 C.F.R. 55 1500-1507 (1991).
2/ The NRC's policy is to be voluntarily-guided by CEQ's regu-lations, subject to certain conditions. 10 C.F.R. 5 51.10.
(1991). CEQ regulations have been adopted in part or in whole by many other agencies and courts have held that CEQ's regulations are entitled to substantial deference. Andrus
- v. Sierra Club, 442 U.S. 347, 358; 99 S. Ct. 2235, 2341 (1979).
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(codified at 40 C.F.R. 51502.22 (1991)). Similarly, NRC regula-tions impose no additional requirements justifying more conserva-tive analysis. NRC regulations require consideration of major points of view concerning the environmental impacts of a proposed action. 10 C.F.R. 5 51.71(b) (1991). Neither set of regulations requires the type of analysis performed iri several instances in the GEIS. 10 C.F.R. 5 51.71'b) (1991).
The NRC's approach in the GEIS does not follov established NEPA case law or regulations. The NRC, when it lacks site-specific information for each plant for each impact may under the law choose a sample of plants-that represent average values for each impact and form its conclusions on that basis, rather than choosing extreme examples. In some instances the NRC has followed these strictureb. In evaluating groundwater impacts, the GEIS employs four representative subsets-of settings where groundwater is an issue-and evaluates only plants where potential groundwater problems have been-identified.. GEIS at 4-11. In evaluating the socioeconomic impacts of license renewal-on the work force, the NRC developed tables lwith mean (average) employment statistics to guide its determinations of the degree of impact. Tables 2-3, 2-4, GEIS at 2-25. In several instances, however, the NRC employs an upper-bounded, conservative analysis of the impact of license renewal on a particular environmental 4
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feature. For example, the GEIS conservatively bounds the activi-ties that would be required at a majority of plants to complete refurbishment, GEIS at 2-27 Likewise, the NRC uses a conserva-tive, admittedly overestimating formula to calculate the average radiation dose to the public and to refurbishment workers. GEIS at 2-22, 3-41. Such an approach is not required by NEPA. The implementing regulations and NEPA case law suggest a more-sensi-ble and efficient approach.
THE NRC IS AUTHORIZED TO USE GENERIC RULEMAKING TO DETERMINE THAT SOME SPECIPIC RISKS NEED NOT BE ASSESSED IN INDIVIDUAL PROCEEDINGS The NRC has made use of generic rulemaking before, and these procedures have been endorsed by the courts. CEQ authorize this practice in its regulations.1/ Such an approach saves agency time and resources and allows both officials-and the public to focus on the important aspects of the decision at the appropriate time in logical, manageable pieces. The NRC has, in the case of new regulations for license renewals, chosen to evaluate the effects of regulatory change generically. Several factors make this possible: the effects of continued operation are discernible from historic data, the same. time frame and regulatory safeguards i/ 40 C.F.R. 5 1502.4(c) (1991).
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apply to all license renewals, and many of the circumstances and consequences of renewal are amenable to generic analysis.
Nothing in the regulations or case lav require an agency to use upper-bounded estimates in its impact analysis when it deter- -
mines that generic assessment is meaningful and efficient.
Rather, disclosure of the impacts of the action based on an aver-age value is sufficient for NEPA, even under generic rulemaking authority.
Provided that generic analysis is appropriate, the methods chosen in specific instances by the NRC must be given deference by the courts; the NRC is not required to exceed these standards to win approval of its EIS. The Supreme Court upheld the NRC's generic rule-making ability in Baltimore Gas & Electric Co. v.
Natural Resources Defense Council, 462 U.S. 87, 103 S. Ct. 2246
(.983). In that case, the NRC had determined that uncertainties about the disposal of nuclear vaste were not sufficient to affect a licensing decision for any plant and promulgated Table S-3: con-taining this generic determination. In reaching its generic con-clusion, the NRC enveloped all plants into a single category'and evaluated the generic effects of the fuel cycle and disposal of nuclear vaste. The Supreme Court reversed the Court of Appeals- ,
holding that the rulemaking is permissible because it is s
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reasonable and not arbitrary and capricious for the NRC to assume that zero releases would occur from, and that all political and technical problems would be resolved in the search for, a parra-nent federal repository for nuclear waste. The case thus upholds the NRC's determination that although uncertainties exist, for these limited purposes it is permissible to base its evaluation of impacts on the assumptions the Commission believes the probabilities favor. 462 U.S. at 95; 103 S. Ct. at 2251 (c'iting 44 Fed. Reg. 45,369 (1979)).E#
NEPA's disclosure requirements do not dictate the form or methodology of an agency's environmental statements. Rather, those decisions remain firmly with the agency. In Vermont Yankee
- v. Natural Resources Defense Council, 435 U.S. 519, 98 S. Ct.
1197 (1978), the Supreme Court - overruling the Court of Appeals
- held that the identification of generic safety concerns in a technical advisory committee report used by the Licensing Board did not require further elucidation to satisfy NEPA. Rather, the 1/ Important in the Court's decision were considerations that the NRC carefully considered and acknowledged the uncertain-ties involved, but used'its expertise to determine that they could be resolved. Further, the NRC took a-generally con-servative approach balancing over-pessimistic conclusions in the Table with the possibly over-optimistic zero release -
conclusion-and used the Table for the strictly limited pur-pose of precluding review of fuel cycle effects during the operating license stage.
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Court discussed the limited role of judicial review and the high l
degree of deference appropriately given to agencies when making j i
decisions about technical matters within the realm of their spe-cial expertise. The Court made clear that reviewing courts are not free to impose additional procedural requirements on the rulemaking process if the lead agency involved does not choose to do so. Vermont Yankee, 435 U.S. at 545-546, 98 S. Ct. at 1212-1213. See also 3altimore Gas, 462 U.S. 87, 103, IO3 S. Ct.
2246, 2255 (1983) ("(A) reviewing court must remember that the Commission is making predictions, within its area of special expertise, at the frontiers of science. When examining this kind of scientific determine; ion, as opposed to simple findings of fact, a reviewing court must generally be at its most deferen-tial.")
In individual instances in the GEIS the NRC may rely on the reasoning of Baltimore Gas and Vermont Yankee and evaluate the risks that the NRC believes the probabilities and the-best scien-tific evidence indicate are likely impacts, according to its own procedures. The GEIS is already a conservative documant overall.
Its purpose is to evaluate the impacts of refurbishment and a twenty-year period of renewed operation for nuclear power plants that have been in operation for years or decades. The NRC has i available to it extensive representative information and
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operating histories that make-it possible to reliably predict which scenarios are likely to occur and the extent of the envi-ronmental impact of each. All of the plants that may apply for license-renewal - with~a sole exception - vere the subject of complete' environmental impact statements before they were licensed.
So long'as an agency complies with the rulemaking-provisions i
of the Administrative Procedure Act, S U.S.C. 5 553 (1988), and its statutory duties, courts may not require _the agency to insti-tute additional procedural requirements, such_as the-use of overly cautious analysis methodologies. Generic _rulemaking is an efficient, responsible, and appropriate 1 methodology well within the purview of the NRC. When a generic rulemaking discusses.
Individual impacts it need only discuss'those reasonably' foresee-able significant adverse impactsLor the-major points of view on the issue. It is not required to dwell on extreme-or? remote potentialities.
TIE NRC SHOULD EVALUATE THE MAJOR POINTS OF VIEW OR-REASONABLY FORESEEABLE SIGNIFICANT ADVERSE IMPACTS OF-LICENSE RENEWAL; " WORST-CASE" ANALYSIS IS NOT REQUIRED The NRC's approach in several; instances in the GEIS.is to-employ worst-case analysis in11 s. discussions of particular:
impacts. By employing extreme rather thansaverage values the NRC 9-
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focuses on unlikely and unrepresentative possible impacts, whi:n are not applicable to most plants and which according to credible scientific evidence are not likely to occur at all. This is in effect supplying vorst-case analysis and this is not required.
The NRC, for example, in evaluating socioeconomic impacts through seven case study plants chooses Indian Point to represent the upper bounds becauso: "Of all U.S. nuclear power plants, Indian Point has the highest combination of population density and prox-imity to urban centers . . . ." GEIS at 3-6. Wolf-Creek was similarly chosen because it is one of the lowest such combina-tions. A more reasonable selection would draw case study plants with values in the middle range, that better represent the bulk of nuclear plants subject to license renewal. Similarly, in evaluating impacts of cooling tower operation on surface water use, the GEIS provides detailed information on Limerick Generat-ing Station and the Palo Verde Nuclear Generating Station because they, almost uniquely, offer worst-case analysis of competing water use conflicts. The NRC dwells on the potential effects.of these unique situations despite its conclusion that existing state or federal water use permits are adequate-to deal with the issue. GEIS at 4-24, 4-25.
Worst-case analysis, tormerly required in CEQ regulations, was withdrawn by CEQ in 1986 and the withdrawal upheld by the 1
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U.S. Supreme Court. 51 Fed. Reg. 15,619 (1986), as codified in 40 C.F.R. S 1502.22 (1991); Robertson v. Methov Valley citizens Council , 490 U.S. 332, 109 S. Ct. 1835 (1989). The NRC did not adopt this requirement into its regulations implementing NEPA and has never been bound by it. Limerick Ecolooy Action v. U.S.
Nuclear Reculatory Commission, 869 F.2d 719, 743 (3d Cir. 1989).
In retracting the vorst-case analysis requirement from its regulations, CEQ stated that worst-case analysis is "an unproduc-tive and ineffective method of achieving those goals; one which can breed endless hypothesis and speculation." 51 Fed. Reg. at 15,620. The Supreme Court in upholding CEQ's amendment to its regulations noted that substantial deference was appropriate because there appeared to have been good reason for the changes in the regulations. Robertson v. Methow Valley, 490 U.S. at 355-356, 109 S. Ct. at 1848. The vorst-case requirement had been seriously criticized, the amendment vas designed to better serve the functions of an EIS, and the-old rule appeared to distort the decisionmaking process by overemphasizing highly speculative harms. The Court agreed that CEQ had sufficient reason to amend the provision. Id.
4 Instead of worst-case analysis, CEQ regulations now provide that agencies must disclose the fact.of incomplete or unavailable
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information, acquire that information if reasonably possible, and evaluate reasonably foreseeable significant adverse impacts even in the absence of complete information.6/ The agency is required to do this evaluation " based upon theoretical approaches or research methods ganerally accepted in the scientific community."
40 C.F.R. 5 1502.22(b) (1991). CEQ believed this approach pro-vided a "viser and more manageable approach" and would better-inform both the public and agency decisionmakers. 51 Fed. Reg.
at 15,620. Even if CEQ regulations were binding upon the NRC, they do not require overly conservative or pessimistic or remote possibilities to be analyzed; in fact, the regulations intention-ally disavow this type of analysis and suggest more reasonable and productive means. The NRC's regulations require consider-ation of major points of view aoout the potential effects of the proposed action.7/ " Major" is not synonymous with "every con-ceivable" or " remote."
5/ CEQ defines " reasonably foreseeable" to include potential impacts that have a low probability of occurring, but cata-strophic consequences, provided that analysis of these impacts is supported by credible scientific evidence, not based on pure conjecture, and within the rule of reason. 40 C.F.R. 51502.22(b) (1991).
2/ "To the extent sufficient information is available the draft environmental impact statement vill include consideration of major points of view concerning the environmental impacts of the proposed action and the alternatives, and'contain an analysis of significant problems and objections raised...."
10 C.F.R. 5 51.71(b) (1991).
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Neither should analysis of remote and speculative conse-quences be required in an EIS, Case law makes it quite clear that agencies should be guided by a rule of reason in performing all aspects of EIS analysis. Vermont Yankee v. Natural Resources Defense Council, 435 U.S. 519, 555, 98 S. Ct. 1197, 1215 (1978)
("To make an impact statement something more than an exercise in frivolous boilerplate the concept of alternatives must be bounded by some noting of feasibility." Fan Luis Obispo Mothers For Peace v. Nuclear Reculatorv Commission, 751 F.2d 1287, 1300 (D.C.
Cir. 1984); vacated in part on other arounds, 789 F.2d. 26 (D.C.
Cir. 1986); cert, denied, 479 U.S. 923, 107 S. Ct. 330 (1986),
( ~i s a number of courts have held, Environmental Impact State-ments need not address 'rer.ote and highly speculative conse-quences.' Under this well-established ' rule of reason,' agencies need not discuss in detail events whose probabilities they .
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believe to be inconsequentially small."); Limerick Ecolocy )
Action v. U.S. Nuclear Reculatory Commission, 869 F.2d 719, 739 (3d Cir. 1989) ("It is undisputed that NEPA does not require con-sideration of remote and speculative risks.").
l CONCLUSION As the NRC is aware, for all but one of the plants that may seek license renewal, a_ complete EIS has been published which
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- I disclosed in detail site-specific impacts that could be antici- _
pated from plant operatlon. The GEIS is addressing the continua-tion of these existing operations.- Acting conservatively, the
! NRC has decided that NEPA still requires that full disclosure be j made of the potential environmental impacts of the renewal of i
- nuclear power plant operating licenses. Nothing, however, in the statute, the regulations, or case lav require the NRC to be i
- extremely conservative both irt choosing to reevaluate these
- impacts and in selecting the vorst-case impacts for the details i of the EIS.
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t ATTACHMENT 3 Page 1 COMMENTS TO NRC DOCUMENT PAGE COMMENT CHANGE 10 CFR Part $1 Page 47031 Urder the category A Clean Water Act 316Lal Proposed Rule Table B 1 Aquatic Ecology (for determination is required Federal Register plant with once through for heat shock, head dissipation systems) heat shock, it states an appro' . Clean Water Act 31C determination is rc saired which is a typographical error.
Draft Regulatory Page 16 It states that if both Change the sentence in the Guide DG.4002 316(a) and 316(b) Draft Regulatory Guide to documents.are available, read, "If the required item C may be omitted, documents are available, This does not agree with . items B, C and D may be the Environmental omitted."
Standard Review Plan (NUREG-1429) which eliminates the information required by items B, C and D if the 316(a) and 316(b) are available.
Draft Regulatory Page 27 The requirements of the Change Regulatory Guide to Guide DG 4002 Draft Reg. Guide and the read that "If information Standard Review Plan do_ provided in A and B Standard Review Page C-21 not match. If items A indicate that the nuclear Plan NUREG-1429 and B of the Regulatory power plant is in a medium Guide are met, only item or high population area C is omitted. The and not in an area where Standard Review Plan growth control measures omits items C through G, .that limit housing Also, the Draft development are in effect, Regulatory Guide contains -items C through H may be item H which the Standard -omitted." Item H should Review Plan-does not, also be added to the SRP list of items.
Draft Regulatory Page 30 The Draft Regulatory In the Standard Review Guide DG-4002 Guide requires under item Plan,-add an item I to the I that the magnitude of list of items that need to Standard Review Page C-45 potential-impact on be discussed if a Plan NUREG-1429 health from shock-hazard demonstration that the be discussed if item A is high-voltage transmission not met. The SRP has no lines meet the National discussion of review cf Electric Safety Code can't impact on health, be met.
ATTACRMENT 3 Page 2 COMMENTS TO NRC mr DOCUMENT PAGE COMMENT CMANGE Generic Page 7-7 Northern States Power's The decommissioning work Environmental Section Pathfinder plant went completed on the Impact Statement 7.2.3 through the process of Pathfinder plant could be NUREG-1437 removing and shipping its discussed in this section, vesrel last summer as It will continue to have a part of its byproduct license.
decommissioning.
GEIS NUREG 1437 Page 7-8 The Pathfinder plant is Change to read Sioux Table 7.1 located by Sioux Falls, Falls. S.D.
line 16 South Dakota CEIS NUREG-1437 Page A 41 The Monticello Nuclear Change "30 miles" to "35 Line 2 Plant is located 35 miles miles",
from Minneapolis GEIS NUREG-1437 Page A-41 The amount of land Change "1325 acres" to Line 26 Northern States Power "2150 acres".
owns at the Monticello site is 2150 acres.
4 GEIS NUREG-1437 Page A-41 The 1990 census Minneapolis 1990 census Lines 29 information is available found it to have a and 40 so it should be used to population of 3(8,380, show populations. The 1990 population within a 50 mile radius of the Monticello Plant is estimated at 2,240,000.
CEIS NUREG-1437 Page A-41 The land that the Change ' Nearby Features' Line 33 Monticello Nuclear Plant to read "The business is located on was annexed district of Monticello s to the town of about-2 miles SE."
Monticello.
GEIS NUREG-1437 Page A-52 The 1990 census Minneapolis 1990 census Line 30 information is available found it to have a so it should be used to population of 368,380, show populations.
GEIS NUREG-1437 Page A-52 The land use within 5 Change the words Line 33 miles of the Prairie " vegetable canning" to Island Plant would be " agricultural."
better described as dairy farming and agricultural.
GEIS NUREG-1437 Page A-52 The Prairie Island Change ' Nearby Features' Line 34 Nuclear Plant site was- to read "The business annexed to the town of district of the town of Red Wing. Red Wing is about 6 miles SE."
ATTACHMENT 3 Page 3 COMMENTS TO NRC DOCUMENT PAGE COMMENT CHANGE GEIS, NUREG 1437 Page H 15 The Net MWe given for Change the $25 MWe to the Line 5 Monticello Nuclear Plant amount of 536 MWe.
is not 525 MWe.
CEIS, NUREG 1437 Page H-15 The value of 14,200 hours0.00231 days <br />0.0556 hours <br />3.306878e-4 weeks <br />7.61e-5 months <br /> it has been estimated that Line 9 given for replacement the amount of replacement power for Monticello is power required above the 6 too large, weeks needed for refueling will be less than 2000 hours0.0231 days <br />0.556 hours <br />0.00331 weeks <br />7.61e-4 months <br /> for Monticello.
CEIS, NUREG 1437 Page H-15 The value for Re-evaluate the use of the Line 6 refurbishment at the Monticello cost data from Morticello Plant is the Sandia National approximately 4 times Laboratories report, larger than found in SAND 88-7095, " Cost Savings recent calculations of from Extended Life Nuclear refurbishment costs. Plants".
GEIS, NUREG 1437 Page H 22 It is not clear if the Clarify if the value of Line 19 value of $20 per kW(e) $20 per kW(e) is for the increased acceptable for use in regulatory costs can be calculating the operation used as a standard for- cost maximum using the the operational cost equation on Page H-29. If maximum calculation or if not, what is that number a new value for each based on?
plant must be found.
CEIS, NUREG.1437 Page H-28 What is considered to be A description of what goes Lines 9 operations, maintenance into the operations and and 11 and capital costs can maintenance and capital vary between utilities, costs should be included so that it is standardized for users of this tabic.
FERC Form 1 information may be a good source.
GEIS, NUREG 1437 Page H-29 lt is difficult to assess A detailed description of Line 14 the source of each of the the derivation of this values in the equation equation should be given used to calculate the to increase the operational cost maximum. _ understanding of the-factors that are included when this equation is used.
I 1