ML20091C919

From kanterella
Jump to navigation Jump to search
Regulatory Analysis for Proposed Amendments to Regulations for the Environmental Review for Renewal of Nuclear Power Plant Operating Licenses.Draft Report for Comment
ML20091C919
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 9108080039
Download: ML20091C919 (82)


Text

_ _ _ _ _ _ _ _ _ _ _

ENCLOSURE 4 NUREG-1440 t

. REGULATORY ANALYSIS FOR PROPOSED AMENDMENTS TO REGULATIONS FOR THE ENVIRONMENTAL REVIEW FOR RENEWAL OF NUCLEAR POWER PLANT OPERATING LICENSES:

DRAFT FOR COMMENT 7

August 1991 U.S. Nuclear Regulatory Commission OUice of Nuclear Regulatory Research

\\

e 910B000039 r710031 I>UR O

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. After considering various

, gi, options, the staff identified 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<ase basis. The findings of this assessment are to be codified in 10 CFR 51. The staff has selected Alternative B as the preferred alternative.

^ ~ ^ ' ^ ~ ~ ' ' ' ~ ~ ~ ^ '

TAllLE OT CONTENTS Section P8Se 1.0 DISCUSSION OF THE ISSUE 1

2.0 OBJECTIVES OF THE PROPOSED RULEMAKING 3

3.0 ALTERNATIVES 4

4.0 COSTS 6

4.1.

COST BASIS 6

4.2 ALTERNATIVE A COST IMPACTS 8

4.2.1 INDUSTRY COSTS 10 4.2.2 NRC COSTS 10 4.2.3 TOTAL ALTERNATIVE A IMPl.EMENTATION COST 5 10 4.3 ALTERNATIVE B COST IMPACTS 10 4.3.1 INDUSTRY COSTS 12 4.3.2 NRC COSTS 13 4.3.3 TOTAL ALTERNATIVE B IMPLEMENTATION COSTS 13 4.4 INCREMENTAL IMPACTS ASSOCIATED WITH THE ADOPTION OF ALTERNATIVE B 13 4.5 SENSITIVITY STUDIES 14 4.5.1 REGULATORY DEVELOPMENT COSTS 15 4.5.2 SENSITIVITY TO ENVIRONMENTAL REPORT AND EIS/EA PREPARATION EFFORTS 17 4.6 IMPACTS ON OTHER REQUIREMENTS 17 4.7 CONSTRAINTS 17 5.0 DECISION RATIONALE 18 REFERENCES 20 i

LIST OF T1 CURES AND TABLES Page Figure 1 Number of License Renewal Applications per Year 9

6 Table 1 Implementation Costs for Alternative A (Cost in 10 399j $)

9 6

Table 2 Implementation Costs for Alternative B (Cost in 10 1991 $)

12 Table 3 IncrementalImpacts Associated With the Adoption of Alternative B 6

(Cost in 10 3991 g) j4 Table 4 Overall Costs Associated With License Renewal Environmental Impact 6

Evaluations and Reviews (10 19915) 5% Discount Rate 16 Table 5 Sensitivity of Cost Savings to ER and EIS/EA Preparation Efforts 6

(10 1991 $)5% Discount Rate 18 ii 1

ACKNOWLEDGEMENTS Science and Engineering Associates, Inc. provided technical assistance in the conduct of this regulatory analysis. The pt neipal contributors from Science and Engineering Associates,Inc. wcre Messrs. Robert Cark, Frank W. Sciacca, and Gilbert L Zigler.

iii

f 1.0 DISCUSSION OF TiiE ISSUE 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 (CElS)(NUREC-1437). Experience has shown that for cette 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 generic 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 beensing 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 impor'mce) of vanous 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, and other Federal agencies, State and local government.

Operating licenses for the earliest comrnercial nuclear plants will begin to expire in the year 2000. *lhe utility industry, DOE and the NRC have begun laying the groundwork for license renewal that will permit the continued safe and reliable operation of many licensed nuclear power plants well beyond their origirol 40-year license terms. Many electrical utilities have expressed interest in renewal of their currently held operating licenses for an additional penod of time.

The NRC understands that the first two applications for license renewal will be submitted in 1991 1992. Based on discussions with licensees and industry representatives NRC anticipates that a significant percentage of existing plants will submit applications for renewal of their operating license 10 to 20 years prior to their expiration. The NRC has issued a proposed rule, 10 CFR 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 plant operating license must meet, the information that must be submitted to the NRC for review so that the agency can determine whether these nquirements haw in fact been met, and the application procedures.

1 l

In addition to the procedural and technical rulemaking under 10 CFR Part 54, the NRC is pursuing a separate rulemaking on 10 CFR Part $1 to generically address potential environmental impacts from renewal of the operating license of individual nuclear power plants. This rulemaking defines potential environmentalimpacts that need to be addressed in submittals to the NRC for review as a part of the application for license renewal of individual nuclear power plants.

- ne NRC has concluded that there has been sufficient experience with power plant operation, maintenance, refurbishment and associated environmental impacts to predict the types and magnitude of emironmental 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 significance (Ref.1).

Results thus far indicate the feasibility of categorizing envircamental impacts as follows.

Category 1.

A generic conclusion on the impact can be reached for all affected plants.

Category 2.

A generic conclusion on the impact can be reached for plants that fall within defined bounds.

Category 3.

The environmental impact must be evaluated in each individual license renewal application. A generic conclusion on the impact was not reached for any affected plants.

In addition, the results of the study and changes to Part 51 provides the bases for a license renewal supplement to Regulatory Guide 4.2

  • Preparation of Environmental Reports for Nuclear Power Stations.*

The NRC has sought the views of the public, industry, and other Federal agencies in preparation for this rulemaking. An advance notice of proposed rulemaking (ANPR) entitled,

" License Renewal for Nuclear Power Plants: Scope of Erwironmental Effects," (55 Fed. Reg. 299M, July 23,1990) was issued. De advance notice outlined the proposed scope of environmentalimpacts to be addressed, and also identified alternatives for codification in Part 51. Comments were requested and the following questions were asked:

1. Is a generic environmental impact statement, or an environmental assessment, required by NEPA to support this proposed rulernaking, or can the rulemaking be supported by a technical study?

2.

What alternative forms of codifying the findings of the generic environmental impact statement should be considered?

3. What activities associated with heense renewal will lead to environmental impacts?

By what mechanism will they lead to impacts?

2

4.

What topical areas should be co tered in the generic environmental impact statement?

Should the proposed outline be si pplemented or restructured?

5. For each topical area what 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 irJormation and data exist?

7.

For each topical area and each specific issue what uiteria should be used to judge the significance of the environmental impact?

8.

For each topical area and each specific issue what is the potential for successful generic analysis?

9.

What length of extended operating time can reasonably be addressed in the proposed rulemaking? To what extent is it possible to reach generic conclusion about the environmental impacts which would be applicable to plants having renewed operating licenses expiring in the year 2030, or 2040,20507 in summary,29 comments were received,19 supported the rulemaking,7 supported it with qualifications, and 3 opposed it. An industry group with support from 16 utilities recommended using a generic environmental survey as a preferred technical method. All of the comments and recommendations have been considered by the NRC in the development of the proposed amendments to Part 51, the GEIS, the supporting guidance of Reg. Guide 4.2, and an Environmental Standard Review Plan (ESRP), NUREG-1429, 2.0 OBJECDVES OF THE PROPOSED RULEMAKING The proposed changes to 10 CFR Part 51 will enable the NRC to achieve the following objectives.

To simplify the preparation of the environmental report by defining the potential genene and specific environmental impacts that must be addressed.

To improve the efficiency in the NRCs review by removing such generic potential environmental impacts that pose no significant impact to the environment from staff review and adjudicatory resolution in individuallicense renewal proceedings.

To permit the use of an environmental assessment (EA)and a finding of no significant impact (FONSI). This rulemaking would reduce resource requirements when the information presented in an applicant's environmental report ccmonstrates that there are no significant environmental impacts associated with the limited set of issues that are a:sessed.

3

To 14rtify generic environmental impacts for public participation to achieve unc.cntanding and resolution, so that heanngs for individual plant EISs will be more efficient.

If most of these objectives are realized, there should be an overall savings in the utilization of resources by the public, the utility industry, the NRC and other Federal agencies, and state and local governments.

3.0 ALTERNATIVES In consMering alternatives to the proposed rulemaking fer Part 51, the NRC staff has taken into consideration its past experience with emironmental impact statements (EISs), environmental assessments (EAs), generic environmental impact statements (GEISs), generic environmental surveys (CESS), 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 CE!S 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.

Establish an S 3 type table / chart ($51.50) for license renewal 6.

Possible combinations of the above.

On review of these possible options,it was concluded that although the use of the CES (option 3) might eliminate certain publication, review and NEPA scoping requirements, these marginal advantages were not considered sufficient to outweigh the perecived 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 environment. Option S was proven to be impractical since all future environmental impacts of license renewal at individual unit sites were not amenable to generic assessment now. With the determination to remove options 3,4, and 5 from consideration, option 6 was no longer deemed reasonable because the remaining options (1 and 2) are viewed to be mutually exclusive. Accordingly, the remaining options were judged to provide two reasonable alternatives that could be used to adequately characterize the costs and benefits of the proposed action to amend Part 51.

Ahernative A - No Rulemakino This alternative is a continuation of the current 10 CFR 51 regulations that require !icense renewal applicants to submit to the NRC a comprehensive update 4

l

l l

to their Environmental Report (ER). The whole range of environmental issues related to operation of each unit and any incremental changes related to extended operabon 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 environmentalimpacts associated with the extended operation of the unit under the terms of a renewed license. This would be donein accordance with 551.70 and 51.71. Requests for comments on the draft EIS in accordance with 551.73 and 51.74 would be required. This would be followed by the issuance of a final EIS and an opportunity for hearing would also occur for each individual unit's license renewal EIS.

Alternative B Undertake Rulemaking in10 CFR Part 51 to Generically Address EnvironmentalImnacts Potentially Resulting From Nuclear Power Plant Licente Renewal. This altemative limits the environmental impact issues that must be addressed on a plant-specific basis. Environmental impact issues that can be addressed in a generic sense, and for which findings of acceptability for all affected plants could be made, 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 51 to limit the scope of issues that would need to be considered 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 conclusion of this process, no further litigation would be necessary or permitted on the findings of the GEIS in individual unit emironmental 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. Altemative B reduces the effort needed by licensees to prepare their license renewal emironmental report (ER) update. It also reduces the effort needed by the NRC to review the updated ER and to prepare either a draft EA or an EIS for only a limited number of issues. If the staff determines publication of a plant-specific draft 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 draf t and final version or consideration of public comments in between. The EA could result in a finding of no significant impact (FONSI) or a determination that an EIS is required. In the event of a FONS1, the cost benefit balanemg conclusion reached in the GEIS and codified in Part 51 would not be reassessed. The cost of an EA and 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 savmgs of implementing Alternative B.

5

o 4.0 COSTS This section discusses the cost impacts of the two alternatives identified in Section 3. The two alternatives delineated 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 rulemakir.3 action. He environmental documents which must be generated, whether based on the no-action alternative or the approach taking advantage of generic g

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 erwironment, would be the same under either alternative. Any changes in plant structures, systems, and components, or in operatir.g parameters would be primarily driven by the review process required by 10 CFR Part 54. There 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. Derefore, only cost consequences are applicable, and only these a e considered in this anzlysis.

The following discussions develop the costs for each approach, and estimate the 4

incremental impacts (savings) associated with the adoption of Alternative B.

4.1.

COST B ASIS The cost evaluations for the Part 51 regulatory analysis assume 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 effort required for the update provided at the Operating License (OL) stage of a plant's licensing process. NUREG-0499,

  • Preliminary Statement on General Policy for Rulemaking to improve Nuclear Power Plant Licensing? (Ref. 2) estimates that such efforts at the OL stage were as follows:

Licensee Efforts for OL Stage ER 5000 to 15000 person-hours NRC Review and EIS Efforts 2000 to 4000 person-hours.

The NRC efforts cited were those associated with the review of the applicant's ER update, and the preparation of the EnvironmentalImpact Statement for the plant, hey include efforts of both NRC contractors and NRC staff. Both the industry and NRC effort estimates include allowance for hearings.

ne efforts required to perform the equivalent activities for license renewal purposes are estimated to le at about the midpoint of the range cited above for the ER and EIS generated at the 6

OL stage of the original plant licensing. His estimate is thought to be somewhat 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 impacts could possibly reduce the effort needed to produce both an ER update for license renewal and the related NRC review efforts. However, the benefit of such infonnation 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 NRC, and the generation of the updated EIS for that plant are estimated to be as follows:

Licensee License Renewal ER Update 10000 person-hours NRC Review and EIS Efforts 3000 person hours, nese estimates are thought to be reasonably representative of what might occur. There will undoubtedly be considerable variation in the effort required from one plant to the next. Thc 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 NRCs generic cost estimating guidelines (Ref. 3), and the base rates are suitably escalated to reflect 1991 dollars.

Licensee labor rate (1991$, fully burdened) 549.30/ person-hour NRC labor rate (1991$)

547.90/ person-hour The industry rate represents fully-burdened cost. The rate shown assumes that a combination of utility staff and contractors or consultants prepare the ER.

The NRC hourly rate shown above reflects incremental costs associated with rulemaking actions. As such,it assumes that certain of NRCs overhead costs are fixed,and would not change becsuse of the proposed rulemaking. In actt.ality license renewal is likely to require the hiring of additional NRC 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.

The draf t CEIS er. compasses 118 commercial nuclear power generating units in the United k

States. This excludes Crand Gulf Nuclear Station Unit 2, Perry Nuclear Plant Unit 2, and Washington Nuclear Project Units 1 and 3, whose construction has been indefinitely suspended, are excluded. The 118 units are owned by 52 electric utilities and are located at 74 plant sites. This same reactor population, minus Rancho Seco and Shoreham units (whose operation in the future is 7

.=-

very unlikely), 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 COSTIMPACTS Altemative A, as noted above,is the "no rulemkaing" option. Existing regulations regarding erwironmental assessments must be followed. Rese current regulations require that a comprehensive ER update and supplemental EIS be produced for each plant proposed for license renewal. All environmentalissues 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 population as a whole depend on the number of plants for which license renewal is sought. In Table 1 the costs are given as a fraction of the current plant population applying for license renewal. ne table also shows costs as a function of discount rate.

Rates of 0%,5%, and 10% 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 cosa only. Considerations of desclopment cost impacts are addressed in Section 4.5.

De costs displayed in Table 1 are based on the assumption that applications for licensa renewal will typically be submitted twelve years prior to the expiration of the original 40-year license. This assumption is consistent with the time profile used in NUREG 1362 (draft),

" Regulatory Analysis for Proposed Rule on Nuclear Power Plant License Renewal,"(Ref. 4) ne exceptions to this assumption apply to the License Renewal lead Plants, Yankee Rowe, a pressurized water reactor (PWR), and Monticello, a boiling water reactor (BWR). ne current licenses for these two plants expire in the years 2000 and 2011, respectively, ne cost analysis performed here assumed that the Yankee submittal for license renewal would be made in 1991, and that for Monticello would be in 1992. he assumption was also made that both Yankee and Monticello would be among the plants applying for license renewal, regardle:s of the fraction of the plant population to actually do so.

The use of discount rates other than 0% requires a time profile of license renewal applications. While it is not known what the actual time profile of applications will be, the profile used is shown in Figure 1. The plot shows the number of heense renewal applications subnutted per year assuming that each submittal is made 12 years before the 40-year license expiration date. For the cases where 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 8

I proportionately reduced compared to the number shown in Figure 1 Since the Yankee and Monticello applications are assumed for all scenarios, and since 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 different present values of cost but does not significantly affect the relative cost of Alternative A compared to Alternative B.

i 14 12-

{10-ii{

8-E 7

6-t y

4-E 2-Il.l i.

I I

I I.

oi 1

1990 1995 2000 2005 2010 2015 2020 2025 Year Figure 1. Number of License Renewal Applications per Year Table 1 Implementation Costs for Alternative A 6

(Cost in 10 1991 $)

Percent of Reactor Population Discount Rates Arcivine fo+ Liceme Renewal Cv"e M

1CY",

Industry Costs 25 %

15.0 8.6 5.8 50%

29.1 16.3 10.6 100 %

57.2 31.6 20.2 NRC Costs 25 %

4.4 2.5 1.7 50%

8.5 4.7 3.1 100 %

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 9

I

\\

4.2.1 INDUSTRY COSTS The licensee's effort needed to prepare a comprehensive, updated ER on any individual I

plant for which an application for license renewal is submitted is estimated to be 10,000 person-hours. At $4930/ 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. Bis assumes that all 116 plants in the current population (does 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 erwironmental assessments, are spread out over a considerable period of time.

4.2.2 NRC COSTS As noted in Section 4.1, NRC's efforts associated with the review of license renewal ERs and the generation of plant EISs is estimated 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 NRC costs when considering the overall reactor population that may apply for license renewal. The NRC costs associated with Alternative A implementation are estimated to be as much as $17 million or as little as $2 million, depending on the number of relicensing applications receivad and processed and on the discount rate assumed.

4.2.3 TOTAL ALTERNATIVE A IMPLEMENTATION COSTS ne 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. De values displayed for the 5%

dis:ount rate are judged to be most realistic, and for this scenario the costs range from about $11 million to $41 million.

4.3 ALTERNATIVE B COSTIMPACTS The draft CEIS groups all of the vanous potential environmental impacts into one-hundred four (1(M) issues. It classifies each such issue according to the three categones noted in Section 1.0.

Of the one-hundred four emironmental impact issue groupings evaluated in the draf t CElS. many are of potential consequence only for certain types of plants. De maximum number of issue groupings that would have to be addressed for any individual plant is ninety-seven (97). Key parameters that establish the number of issue groupings pertinent to a given nuclear plant include, among others, the type of cooling system and the ultimate heat sink. De draft CEIS identified twenty-four (24) license renewal environmental impact issues that fell into Categones 2 and 3. These are 10 t

I.

the issue groupings that could potentially be addressed by all plants for which license renewal

- applications are made, or by all such plants whose impacts might fall outside of the bounds evaluated in the CElS. On the other hand, more than eighty (80) issues are addressed on a generie 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 ase dated 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 assumption that each applicant applying for license renewal will expend effort on twenty two 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 as to the cost of addressing each plut-specific issue. For the current assessment, cost per area was established simply by dividing the total effort 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 which involves 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 to the next. While issue-specific complexity could have been assessed, and labor efforts adjusted accordingly, this approach would introduce additional uncertainties into the evaluation and was not used in this analysis.

The NRCs 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. NRCs labor effort per issue was established based on the estimated effort needed to conduct a comprehensive review of a 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 Alternative B. As with Table 1 for Alternative A, costs are shown for three discount rates and for three different fractions of the light water reactor power plant population seeking license renewal. Total implementation costs are also displayed.

11

. Table 2 Implementation Costs for Alternative B (Cost in 10'19915)

Percent of Reactor Population Discount Rates i

Aceh4ne for Ueenw Renewal ~

E E

IM

. 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 submitted is estimated to be 10,000 person-hours. Based on a maximum of ninety-seven (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 address twenty two plant specific issue areas, yields estimates of industry costs. For the industry as a whole, assuming 116 plants apply for license renewal, and for the " average" plant effort associated with Alternative B, the results are as follows:

Total Industry Cost (undiscounted 1991$)

516 million Average Plant Cost (undiscounted 19915)

$134,000.

The average plant costs given here do not factor in the costs incurred by the lead plants.

The industry costs noted above assume that the two lead plants, Yankee and Montice!!o, 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, Alsoithis industry total cost assumes that all 116 plants in the reactor population apply for license renewal. The costs are undiscounted,i.e., they do not reflect the time spread over which these expenditures are likely to occur.

12

The Alternative B consequences to industry as a whole depend on the number of facilities for which license renewal is sought. The 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 Table 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 twelve years prior to the expiration of the original 40 year license. The time profile of number of applications per year shown in Figure 1 was used to develop Tabic 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. Based on a total of ninety seven issues that would be addressed in a comprehensive effort as discussed previously in Section 4.3, this gives an average effort of slightly more than 30 person-hours per issue areas. NRC's potential overall expenditures for industry-wide relicensing ER reviews are estimated below. Per plant average expenditures are also noted.

Total Potential NRC Cost (undiscounted 19915)

S4.7 million NRC Average Per Plant Cost (undiscounted 19915)

$39,000.

Table 2 gives NRC costs associated with the adoption of Altemative B. Costs are displayed based on the percentage of the reactor plant population seeking license renewal and on alternative discount rates.

4.3.3 TOTAL ALTERNATIVE B B1PLEMENTATION COSTS The totals shown in Table 2 indicate that the Alternative B combined implementation cost to both industry and the NRC are estimated to be in the range of about $3 million to $21 million.

The lower figure corresponds to a small fraction 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 0% discount rate. The values displayed for the 5% discount rate are judged to be most realistic, and for this scenario the costs range from about $4 million to $12 million.

4.4 INCREMENTAL SIPACTS ASSOCIATED %T111 THE ADOITION OF ALTERNATIVE E Nuclear plant license renewal, if it is pursued, will require that applicants perform an assessment of potential environmental impacts associated with extended plant life. This requirement can be met with either Alternative A, the no-rulemaking alternative, or Alternative B 13

s which reduces the number of environmentalissues that must tr essed on a plant-specific basis.

The proposed changes to 10 CFR Part 51, and as represented by rnative B, can significantly reduce the burden on both industry and the NRC regarding the preparation and reviev' of environmental report updates associated with license renewal and the preparation of the EIS/EA.

The draft GEIS indicates that, of 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 range from about 541 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 due to the adoption of Alternative D range from about $12 million to about $1 million over the range of conditions noted. The combined savings to both industry and the NRC range from about $53 million to $4 million.

Table 3 Incrementalimpacts Associated With the Adoption of Alternative B s

(Costinlo 3993 $3 Percent of Reactor Popalation Discount Rates Aeplyine int Liceme Renewal 0%

M 10%

Industry Costs 25 %

(-)10.2

(-)5.6

(-)3.5 50%

( 12 0.5

(-)11.2

(-)7.0 100 %

(-)4 0.9

(-)22.3

(-)14.1 NRC Costs 25 %

(-)3.0

(-)1.6

(-)1.0 50%

(-)5.9

(-)3.3

(-)2.1 100 %

(-)11.9

(-)6.5

(-)4.1 Total Costs 25 %

(-)13.2

(-)7.2

(-)4.5 50%

(-)26.4

(-)14.5

(-)9.1 100 %

(-)52.9

(-)28.8

(-)18.2

(-) Denotes cost savings 4.5 SENSITIVITY STUDIES This section discusses the effects of two different elements that can be considered in defining costs of the two alternatives. The first comiders the effects of NRC's regulation development costs.

14

i 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 DEVEl.OPMENT COSTS The NRC has expended considerable resources in the development of the proposed changes to 10 CFR Part St. These resources include the cfforts needed to develop the proposed changes, prepare the draft GEIS, and perform related actions. The proposed rule will also require the development of a Regulatory Guide for the preparation of updated license renewal em fronmental

. reports. Similarly, an Environmental Standard Review Plan must be developed to assist the NRC in its review of the ERs submitted with license renewal applications.

NRC development efforts 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 efforts and costs associated with both Alternative A and the proposed Alternative B are as follows:

Alternative A Alternative B NRC Professional Staff Effort 14 staff months 88 staff months Staff Cost,19915 5116,000

$730,000 Contractor Assistance,19915

$1,150,000 53,800,000 Totals,19915

$1,270,000 54,530,000 The major distinction between the developmental costs of Alternatives A and B, aside from their absolute size,is that A's costs are yet to be incurred whereas B's, for the most part, are already sunk. Because Alternative A's developmental costs are still outstanding they are an appropriate consideration in this regulatory analysis. Only 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 develcpmental expenditures are sunk costs and as such are no longer relevant.

That is, the sunk costs exist independent of our ultimate decision and, therefore, they are not incremer.talimpacts that can be attributed to Alternative B. That portion of B's developmental costs that are still outstanding are relevant but are projected to be smaller than A's developmental costs. However, for conservatism, 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 15

order to see if these sunk costs would have any eifeet 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 NRCs 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. *Ihe higher development L,sts of Alternative B are more than offset by the savings possible by implementing the proposed changes to 10 CFR Part $1. With the 5% discount rate, the savings range from about $4 million to about $26 million, depending on the number of plants seeking license renewal. At lower discount rates the savings increase for Alternative B relative to Alternative A. Even under the conditions of a small fraction (25%) of the reactor population applying for license renewal and a higher discount rate (-10%) Alternative B remains less costly than Alternative A, including consideration given to the greater regulation dc felopment costs of Alternative B.

Table 4 Overall Costs Associated With License Renewal -

Environmental 1mpact Evaluations and Reviews 8

(10 19915) =

5% Discount Rate Incremental Costs Percent of Reactor Population Alternative Alternative Alt. B Avnhing for I hense Renewal A

E Relative to Alt. A Industry Costs 25 8.6 3.0

(-)5.6 50 163 5.1

(-)11.2

'100 31.6 9.3

(-)22.3 NRC Costs -

- 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

(-)11.2 100 42.1 16.5

(-)25.6

(-) Denotes cost savings 4.5.2 SENSITIVTIY TO ENVIRONMENTAL REPORT AND EIS/EA PREPARATION EFFORTS 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 16

o

\\

effort to be expended by the NRC in the review of these submittals and the attendant preparati of the EIS for each plant is also somewhat uncertain. The reference level of effort assumed for the licensee to prepare an ER for Altemative A was 10,000 person hours, and the corresponding review and EIS/EA preparation effort was 3,000 person-hours. By taking full advantage o ERs and the environmental impact data collected over the years of plant operation,it is possib that licensee efforts could be considerably less than the base effort assumed. Similarly larger efforts are also possible. For applications for which a FONS! is supportable,it is l that a lower level of effort may be necessary of applicants as well as the NRC.

The sensitivity of the cost results to the level of effort required to prepare and review the necessary emironmentalimpact documents was explored. Table 5 shows the results of this sensitivity study. The savings attributable to the adoption of Alternative B relative to Alternative A are shown for the reference case, and for cases ba ed on one-half and 1.5 times the reference level of effort. The cost savings vary directly with the base level of effort requi for the consideration of regulation development costs. The development costs are assumed to re fixed, regardless of the base ER/EIS/EA preparation efforts assumed. As indicated in Table 5 the cost savings possible by adopting Alternative B decrease if the labor effort is lower than that assumed for the reference case, and they increase if a higher labor effort is assumed.

4.6 1MPACTS ON OTHT_R REQUIREMENTS The proposed 10 CFR Part 51 will have no im act on other NRC programs. There will be a positive benefit in the implementation of 10 CFR Pi

  • Requirements for Renewal of Operating 1.icenses for Nuclear Power Plants / but no other int

...ons. Since this rulemaking applies specifically to NRC 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 up to 20 years, there will be no constraint to implementation arising from scheduling. The time allowed for public participation through the ANPR and the publication of a proposed rule for comment should assure that no policy, institutional or legal considerations that arise will be resolved before issuance of the 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 51. Since publication of the final rule, no enforcement problems have been experienced. It should be noted, however, that this rulemaking schedule may 17

Table 5 Sensitivity of Cost Savings to ER and EIS/EA Preparation Efforts 6

(10 3993 $)

5% Discount Rate Incremental Costs of Alternative B Relative to Alternative A Percent of Reactor Population 0.5 x Base Base 1.5 x Base Apph4ng for t_lecme Renewal rw rw rw Industry Costs 25

(-)2.8

(-)5.6

(-)8.4 50

(-)5.6

(-)11.2

(-)16.8 100

(-)11.2

(-)122.3

(-)33.5 NRC Costs 25

(-)0.8

(-)1.6

(-)2.4 50

(-)1.7

(-)3.3 (15.0 100

(-)3.2

(-)6.5

(-19.8 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

(-)11.2

(-)25.6

(-)40.1

(-) Denotes cost savings not significantly benefit the two lead plants (Yankee Rowe and Monticello) who will subnut applications in 1991 and 1992. The extent of any benefits cannot be quantified for these lead plants, even though the information developed thus far will be used to support the staffs environmental findings for each plant.

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 power reactors. There 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 NRC. Savings are anticipated because the rule change would reduce the license renewal environmental impact issues that need to be addressed on a plant specific basis.

The proposed change to 10 CFR Part 51 would reduce or eliminate duplication of effort among license renewal applicants in addressing those environmental issues for which a generic conclusion can be reached on the acceptability of the impacts for all affected plants. Overall industry savings are esumated to range from a high of about $41 million to about $3 million, depending on the 18 l

4 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 NRC 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 industry and the NRC, the total cost savings with Alternative B range from $5 million to $53 million. With the use of the 5% discount rate, judged to be the most realistic scenario, the savings range from $7 million to $29 million.

Based on the findings of this analysis, the staff has selected Alternative B as the preferred approach.

19

.......- _ _. _.. _ _ _... _ _. _. _ _ _. _... _ _. _ _ _ _.... _ _. _ _ _.. ~. _. _.

2 4

i.

i REFERENCES -

'=

i i:.

- 1. NUREG-1437,

  • Generic Environmental Impact Statement for License Renewal of Nuclear Power Plants,* US. NRC, August 1990.

-1

]

2. NUREG 0499, " Preliminary Statement on General Policy for Rulemaking to Improve Nuclear
Power Plant Licensing,' December,1978.
3. NUREG/CR 4627, Rev.1," Generic cost Estimatesi Abstracts From Generic Studies for Use in -

Preparing Regulatory impact Analyses," US. NRC, December 1988.

f I'

4.

NUREG-1362 (draft for comment)," Regulatory Analysis for Proposed Rule on Nuclear Power Plant License Renewal," July,1990, t

4 I

I i

r 20

ENCLOSURE 5 DG-4002 NUREG-0099 Regulatory Guide 4.2 Revision 2 Supplement No. 1 GUIDANCE FOR THE PREPARATION OF SUPPLEMENTAL ENVIRONMENTAL REPORTS IN SUPPORT OF AN APPLICATION TO RENEW A NUCLEAR POWER STATION OPERATING LICENSE:

DRAFT FOR COMMENT AUGUST 1991 U.S. NUCLEAR REGULATORY COMMISSION l

l-I DRAFT: JUNE 19,1991 l

1 This page has been lett blank intentionally.

i I

TABLE OF CONTENTS EDH2 A.

INTRODUCTION 1

B.

GENERAL GUIDANCE TO APPLICANTS 3

C.

STANDARIi FORMAT AND CONTENT OF SUPPLEMENTAL ENVIRORMENTAL REPORTS Il Chapter 1.

Plant Refurbishment, Operation, and Maintenance 11 1.1 Refurbishment 11 1.2 Operation and Maintenance Under License Renewal 11 Chapter 2.

Review of NEPA Issues 13 2.1 Heat Shock, Impingement, and Entrainment Effects on Fish and Shnllfish 14 2.2 Effects of Cooling Ponds on Groundwater Quality 16 2.3 Groundwater Use Conflicts 18 2.4 Effects of Refurbishment on Important Plant and Animal Habitats 19 2.5 Effects of Refurbishment on Surface Water Quality 21 2.6 Effects of License Renewal on Housing 22 2.7 Electric Shock from Transmission Line Induced Currents 24 2.8 Health Effects of Thermophilic Organisms 26 2.9 Low-Level Radioactive Waste Storage and Disposal 27 2.10 Demonstration of Cost Advantage of License Renewal 29 2.11 Threatened or Endangered Species 30 2.12 Transportation Impacts of Refurbishment 31 Chapter 3.

Assessment of Overall Benefit Cost Determination 35 REFERENCES APPENDIX A-1 l

i

This pc." has been left blank intentionally.

4 I

~,.

I l

b 11

1 2

3 4

A.

INTRODUCTION 5

6 The National Environmental policy A9t (NEPA) of 1969 (Public 7

Law 91-190, 83 Stat. 852) is implersented by the NRC pursuant 8

to regulations contained in 10 CPR 51.

Applications for 9

license renewal for nuclear power plants submittod under 10 10 CPR 54 must include, in response to 10 CFR 51, assessments of 11 a number of specific NEPA issues.

12 13 This document suoplements Regulatory Guide 4.2, Revision 2, 14

" Preparation of Environmental Reports for Nuclear Power 15 Stations," UUREG-0099, July 1976.

Regulatory Guide 4.2 16 details the information that should be included in an 17 application for a construction permit regarding the 18 environmental impact of construction and operation of the 19 proposed plant and associated f acilit ies.

This document 20 supplements Regulatory Guide 4.2 by nescribing information the 21 NRC staff needs from a supplemental environmental report (ER) 22 for license renewal.

By using the format in this guide, 23 applicants can help ensure the completeness of the information 24 provided, assist the NRC staff and others in locating the 25 information, and help reduce the time needed for the review 26 process.

Where identical conditionn exist and no substantial 27 changes in environmental impact can be identified, the 28 applicant may incorporate, by reference, any information 29 previously submitted to the NRC, or records of decisions 30 previously prepared.

31 32 Amendments to 10 CFR 51 reduced the scope of the environmental 33 review and the level of detail required for renewal of an 34 operating license from that required at the initial licensing 35 stage.

The reduced environmental review resulted from the 36 preparation of NUREG-1437, a Generic Environmental Impact

./

Statement (GEIS) that reviewed all NEPA issues for the nuclear 38 power plants that may be candidates for license renewal.

The 39 U.S. Nuclear Regulatory Commission (NRC) amendments to 10 CFR 40 51 for license renewal include a generic assessment of the 41 impact of all potential NEPA issues that may be associated 42 with the renewal of the operating license of an individual 43 nuclear power plant.

The environmental review for license 44 renewal of an individual nuclear power plant is restricted-to 45 those issues not resolved generically.

For license renewal, 46 the focus of the review, in both the GEIS and the individual 47 plant assessments, is on the impacts associated with up to 20 48.

additional years of plant operation and any refurbishment 49 necessary for that additional period.

50 51 The GEIS identifies changes to plants and their operations 52 that could result under 10 CFR 54; assesses tne potential 53 impacts of implementing these changes; assesses the pote-tial 54' impacts of operating the plants for up to an additiona) T 55 years; and compares these impacts with those of the i

1

l I

alternative means for generating electricity.

These findings 2

have been codified in the NRC's environmental protection 3

regulations, 10 CFR 51.

4 5

After docketing a license-renewal application and receiving an 6

applicant's supplemental ER, the NRC staff will prepare an 7

Environmental Assessment (EA) on the limited set of potential 8

environmental issues specified in 10 CFR 51.

If after 9

reviewing the applicant's supplemental ER and conducting any 10 independent reviews it believes necessary, the staff finds no 11 significant environmental impacts associated with any of the 12 issues, the NRC will issue a Finding of No Significant Impact 13 (TONSI).

The environmental revleu would be complete at that 14 point.

However, if the staff finds significant adverso 15 impacts that would preclude the issuance of a TONSI, the NRC 16 would have to prepare a supplemental environmental inpact 17 statement (EIS).

18 19 UUREG-1429, " Environmental Standard Review Plan for the Review 20 of License Renewal Applications for Nuclear Power Plants,"

21 provides guidance for the NRC staff's review of supplemental 22 ERs submitted by applicants.

The primary purpose of 23 NUREG-1429 is to ensure the quality and uniformity of staff 24 reatiews and to ensure that these reviews are focused on those 25 NEPA concerns associated with license renewal.

NUREG-1429 is 26 avsilable to licensees, the public, and other parties, and 27 provides information about the regulatory process and the 28 review of environmental issues associated with license 29 renewal.

30 31 After considering the individual issues, the NRC staff would 32 ovaluate in the EIS whether the findings would overturn the 33 Commission's conditional generic determination on the benefits 34 and costs of renewing an individual nucionr power plant 35 operating license.

This conditional determination, codified 36 in 10 CFR 51, Subpart A, Appendix B, states that the renawal 3'

of an_ operating license for up to 20 years should have uccrued 38 benefits that outweigh the economic, environmental, and social 39 costs of license renewal.

Table B.1 of 10 CFR 51, Subpart A, 40 Appendix B, summarizes the findings on all environmental 41 issues covered by the GEIS.

42 43 2

I


.------_---__-----------_-.-._.----.---.-----_-------___--.-_-w

1 2

B.

GENERAL GUIDANCE TO APPLICANTS 3

4 This guide identifies the information needed by the staff in 5

its assessment of the potential environmental effects of 6.

renewing the operating license of a nucicar power plant and 7

establishes a format acceptable to the staff for its o

presentation.

Use of the format of this guide will help 9

ensure the completeness of the information provided, will 10 ascist the NRC staff and others in locating the information, 11 and will aid in shortening the time needed for the review 12 process.

Conformance with this format, however, is not 13 required.

An environmental report with a different format will be acceptable to the staff if it providos an adeyunte 14 15 basis for the findings requisite to the issuance of a license 16 or permit. However, because it may be more difficult to locate 17 needed information, the staff review time for such a report 18 may be longer, and there is a greater likelihood that the 19 staff may regard the report as incomplete.

20 21 The NRC encourages applicants to incorporate by reference 22 lengthy, detailed information from environmental reports, 23 final environmental statements, environmental assessments, 24 safety-assessment reports, and the GEIS for license renewal.

25 However, such information and findings should be summarized in 26 sufficient detail to minimize the need for a reviewer to refer 27 to the cited documents.

The absence of such summaries would 28 lengthen the review tino and increase the likelihood that the 29 staff would regard the report as incomplete.

30 31 In preparing supplemental environmental reports, applicants 32 should be familiar with the requirements of 10 CFR 51, with 33 the GEIS, which provides the analysis and conclusions codified 34 in 10 CFR 51, and with PG 4.2, Revision 2.

Through 35 consultation with the appropriate federal, state, and local 36 agencies, the applicant should also be familiar with 37 applicable requirements that may affect the consideration of 38 various issues codified in 10 CFR 51.

The GEIS establishes 39 the bounds and significance of potential environmental impacts 40 at 118 light water nuclear power plants.

This includes 113 41 plants with operating licenses as of June 30, 1992, plus 42 Bellefonte Units 1 and 2, Comanche Peak Unit 2, and Watts Bar 43 Units 1 and 2.

All NEPA issues that may be of concern to the 44 NRC in its review of an application for renewal of an 45 operating license are assessed.

The secpe of those issues 46 reflects the potential effects of plant refurbishment 47 associated with license renewal, up to an additional 20 years 48 of plant-operation, and possible changes:in the plant's 19 environmental setting.

All of the issues identified were 50 combined into 104 issues.

For each type of impact, generic 51 findings encompassing as many nuclear power plants as possible 52 were made.

53 I

54 Findings on each of the 104 issues were placed in a framework l

55 of three categories as follows:

3 l

Category 1:

A generic conclusion on the impact has 1

a been reached for all affected nuclear power plants.

3 Category 28 A generic conclusion on the impact has 4

5 been reached for affected nuclear power plants that 6

fall within defined bounds.

7 Category 3:

A generic conclusion on the impact was 8

9 not reached for any nuclear power plant.

80 18 Findings were also made on the significance of impacts for 13 each of the issues.

13 "Small" impacts are so minor that they neither 14 a5 warrant detailed investigation nor consideration of

-16 mitigative actions when such impacts are negative.

17 18

" Moderate" impacts are likely to be clearly evident

+

19 and usually warrant consideration of mitigation 30 alternatives when such impacts are negative.

38 23 "Large" impacts involve either a severe penalty or 33 a maior benefit and mitigation alternatives are 34 always considered when such impacts are negative.

25 36 Small impacts result in a finding of no significant impact 27 (FONSI) by the NRC staff.

Moderate and large impacts are 38 considered significant.. Commitments made in a license renewal 29 application may enable a FONSI to be made if implementing such 30 commitments would reduce moderete impacts to small impacts.

38 33 Appendix A-1, a reproduction of Table B.1 from 10 CFR 51, 33 summarizes all issues and the generic findings on their 34 categories and the icvel of impact.

Of the 104 issues for 35 which findings were made, 80 were categorized as Category 1.

3G These 80 issues require no further treatment.

The staff 37 categorized 22 issues as Categcry 2; these require further 38 analysis in each application.

The first step of the analysis 39 is to examine certain plant, site, or community 40 characteristics to determine if bounding conditions are met.

41 If these conditions are met, no further analysis is required.

42 If they are not met, further analysis is required.

Two issues 43 were categorized as Category 3; they must be assessed in every 44 license-renewal application.

Figure 1.1 summarizes the entire 45 process.

Chapter 2 provides guidance on the analysis required 46 for the 22 issues in Category 2 cnd the two issues in 47 Category 3.

48 49 Table 1.1 lists the Category 2 and Category 3 issues from 50 Appendix A-1, and identifies the sections of the GEIS 51 (NUREG-1437) in which these issues are treated.

52 4

Table 1.1 Category 2 ' and Category 3 Environmental Issues F

r Name i frora Table B-1 Location in Chapter 2.

Annendtr'B 10 CFR 51 Of thlm Doc===nt h ation in crTE BENEFITS l

Avoided costs 2.10 Demonstration of Cost

9. -;. 5 Econcmic Analysis Advantage cf License 7.3.5 Economic impacts

[

a.-evtl r!

e I

' COSTS Refurbishment 2.10 Demonstration of Cost 9.4.5 Economic Analysis Advantage of License 7.3.6 Economic impacts Renewal tn

[

ruel 2.10 Demonstration of Cost 9.4.5 Economic Analysis f

Advantage of License 7.3.6 Economic impacts Renewal

[

L Operation & maintenance 2.10 Demonstration of Cost 9.4.5 Economic Analysis Advantage of License 7.3.6 Economic impacts j

Renewal j

d i

ENVIRONMENTAL IMFACTS

[

Effects of refurbishment on 2.5 Effects of Refurbishment 3.4.1 Surface Water i

surface water quality on Surface Water Quality

[

.. l t

h Entrainment of fish and.

2.1 Heat Shock, Impingement, 4.2.3.1.2 Entrainment of Fish

[

shellfish early life stages and Entrainment Effects and Shellfish j

(once-through. cooling) en Fish and Shellfish 1

i I

f

Name from Table B-1 I,ocation in Chapter 2 Annandim E 10 CFR 51 Of

  • him Doc *- nt Location in CETE Impingemant of fish and 2.1 Heat Shock, Impingament, 4.2.3.1.3 Impingement of Fish shelltish and Entrainment Etfects and Shellfish on Fish and She11 fish Heat shock 2.1 Heat Shock, Impingemant, 4.2.3.1.4 Heat Shock and Entrainment Effects on Fish and Shellfish Impingement.of fish 2.1 Heat Shock, Impingament, 4.4.4 Aquatic Ecology (cooling pond cooling) and Entrainment Effects on Fish and Shelltish i

i Entrainment of fish early 2.1 Heat Shock, Impingement, 4.4.4 Aquatic Ecology life stages (cooling pond and Entrainment Effects l

cooling) on Fish and Shellfish i

t Heat shock (cooling pond 2.1 Heat Shock, Impingament, 4.4.4 Aquatic Ecology

[

cooling) and Entrainment Effects on Fish and Shellfish I

i Groundwater use conflicts 2.3 Groundwater Use 4.2.2.1 1 Potable and Service (potable and service water-Conflicts Water l

operation) 6 i

I I

l

I

+

1 l

f Name from Table B-1 Location in Chapter 2 Anomarilw B 10 Cnt 51 Of thim Doc- -nt Location in CRTM l

l-Groundwater use conflicts 2.3 Groundwater Use 4.2.2.1.2 Operational l

(water pumped for Conflicts Dewatering Systems dewatering-oparation)

Groundwater use conflicts 2.3 Groundwater Use 4.2.2.1.4 Use of Groundwater (Ranney wells-cperation)

Conflicts for Cooling Tower Makeup Groundwater quality 2.2 Effects of Cooling Ponds 4.4.3 Groundwater degradation (cooling ponds-on Groundwater Quality operatin) i

~4 1

i Refurbishment impacts 2.4 Effects of Refurbishment 3.6 Terrestrial Ecology i

(terrestrial resources) on Important Plant and Animal Habitats 1

i i

l Threatened or endangered 2.11 Threatensi or Endangered 3.5 Aquatic Ecology species Species 3.6 Terrestrial Ecology 4.'2.1.1 Environmental Statutes i

Microbiological organisms 2.8 Health Effects of 4.3.6 Human Health j

(public health-operation)

Thermophilic Organisms i

Electromagnetic fields, 2.7 Electric Shock from 4.5.4.1 Acute Effects acute effects (electric Transmission Line j

shock-operation)

Induced Currents 4

6 i

[

i.

1 i

l Name fross Table B-1 Location in Chapter 2 i-Annandir B 10 CFR $1 Of thin Doo nt Lot-ation in CETM

[

i i

Housing. Impacts of 2.6 Etfects of License 3.7.2 Housing j

returbishment Renewal'on Housing i

i i

Housing impacts of license 2.6 Effects of License 4.7.2 Housing renewal term Renewal on Housing 4

L Transportation impacts of 2.12 : Transportation Impacts 3.7.4.2 Transportation i

refurbishment of Refurbishent Low-level radioactive waste 2.9 Low-Level Radioactive 6.3.2 On-Site Storage i

storage Waste Storage and Disposal i

i, Low-level radioactive waste 2.9 low-Level Radioactive 6.3 3 Disposal and LLW i

i disposal Waste Storage and Corepacts Disposal

i I

i i

t

\\

[

h i

7 t

t i

i u

4 l

]

i I

Fut not of NEP A lespos

)

trem Taide & 1, to CF R Part $1

}

g F9f toch leeue.

)

r I

se No is No APP caws y,

se lesue Cle664a lasue Class 40

  1. h "*"'8' P'* "' '8 Category Cawpory of Cologory withei bounos 1?

37 inauet Yes Yes No 9

Samue Has been Cons oerts' Gerorcahy. Do Not Ao&ess jr p

laeve en Supplemental Eneronnentat Report J Devemp g

NEPA las,e Assestownt U

Dewemrw impact U

is Wa

' Prepare yes Adew No 8"c8uo' '",',o'mai on in Mstigation Alematives eM hr gupp

,,ng,,

& Mitgason Plan Erwponnwntat Report 8or Each lar.ue 8,",

U p

Anatyre Combinebon Cor**' IS$w' include Wormason m 69pp6enwntal of teswes en Anatytis of lot Changes to NE PA NEPA Cost Beret:t Erwitonmental Report CoM benefit Satance Salance -

r 3

hcluoe intormsbon en C

Suppiernantal Erwronnental Repori V

J Figure 1.1 NEPA issues Flowchart L

l-j.-

9

--s,W-/gwe,-.gFri 1.*reww.-wy-g.+

q.g-ggv.-w,-.7%,y#,

g-.y-y--+y-gwww-gg,ggyyyi,,p m w,

-p,*,g,sy-..mpr-ehY a4e----pri-one-Tw -D A4*amWw-Sma--

7

-M's"*WNh-'Alewe

'e D

_ - _ _ -.. _ -.... _.. -. ~ -

1 This page has been left blank intentionally.

10

1 C.

STANDARD TORMAT AND CONTENT OF 2

SUPPLEMENTAL ENVIRONMENTAL REPORTS 3

4 5

CHAPTER 1.

PLANT REFURBISHMENT, OPERATION, AND MAINTENANCE 6

7 License renewal may necessitate modifications to a plant, its 8

operations, and its procedures for administrative control.

9 Chapter 1 of a uupplemental environmental report should 10 describe those activities that will be taken to prepare the 11 plant for operations under license renewal, and describe any 12 changes in operation and maintenance that will take place 13 during the renewal term.

The information provided should focus on modifications directly affecting the environment or 14 15 affecting plant effluents that affect the environment.

Such 16 information should be provided in sufficient detail to give a 17 clear understanding of the sources of environmental effects 18 that must be covered in Chapter 2.

19 20 1.1 REFURBISHMENT 21 22 Plant modifications and refurbishment activities undertaken 23 for license renewal should be generally characterized in this 24 section.

These activities may be compared to refurbishment activities that occur durin 25 under the current license. g regularly scheduled plant outages 26 Applicants should follow the 27 informational requirements in Chapter 2 to determine the 28 cmphasis and level of detail needed in describing plant 29 modifications.

Major refurbishment outages associated with 30 license renewal and extended operation should be characterized 31 with regard to duration; change in on-site labor force; 32 affected systems; affected structures and components; and 33 description of the land-use for parking, laydown areas, 34 structures, or any other construction activities.

In the 35 context of this guidance, major refurbishment outages are 36 those that last considerably longer than a refueling outage, 37 and are generally comparable to or longer than an outage for 38 replacing a steam generator.

39 40 1.2 OPERATION AND MAINTENANCE UNDER LICENSE RENEWAL 41 42 This section should generally characterize the changes in 43 plant operating practices, inspections, maintenance 44 activities, and in administrative control procedures during 45 the renewal term.

This description should include changes 46 relevant to the issues addressed in Chapter 2.

Applicants 47 should follow the requirements in Chapter 2 to determine the 48 emphasis and level of detail needed in describing plant 49 operations.

50 21

_ _ _. _. _ _ ~

1 This page has been left blank intentionally.

O l

l l

1 12 l

1 2

CHAPTER 2.

REVIEW OF NEPA ISSUES 3

4 The GEIS analyzes a range of environmental issues for license 5

renewal and reaches conclusions on their impact.

Table B-1 of 4

10 CFR 51 provides findings for each of 104 National 7

Environmental Policy Act issues associated with license 8

renewal.

The supplemental environmental report submitted as 9

part of each license renewal application is required, under 10 5 51.53(c), to address each of the Category 2 and Category 3 11 environmental issues identified in Table B-1 of 10 CFR 51.

12 For convenience, Table B-1 is reproduced as Table A-1 in the 13 appendix to this Regulatory Guide.

14 15-Table 1.1 of thir Regulatory Guide contains the category 2 and 16 Category 3 issues from Appendix B of 10 CFR 51, and identifies 17 the section of the GEIS and of this chapter where each issue 18 is addressed.

It should be noted that the twenty-two 19 Category 2 issues in Table A-1 are consolidated into 10 of the 20 12 topics treated in Chapter 2.

Treatment of each of the 21 Category 2 and category 3 issues should be progressively more 22 detailed, depending on whether a demonstration can be made on 23 bounding and depending on the level of impact.

The suggested 24 level of detail for the issue-specific environmental 25 assessments is summarized below.

26 27 A.

Catecorv 2 issues 28 29 1)

If the issue given in 5 51.53 (c) (3) (ii) is 30 demonstrated to be within the bounds then no 31 further analysis is required.

32 33 2)

If the issue is outside the given bounds then an 34 assessment of the environmental impact is required.

35 36 B.

pateaory 3 issues 37 3B Applicants must provide an assessment of the impact 39 (5 51.53 (c) (3) (iii)).

40 41 C.

Catecorv 2 and Cateaorv 3 issues 42 43 When an assessment indicates an adverse moderate or large 44 impact, the assessment should describe the mitigation 45 measures that will be used.

46 47 D.

The supplemental ER is required to evaluate whether the 48 overall cost-bonefit balance determination in Appendix B 49 of 10 CFR 51 is changed by the individual plant-specific

~

50 assessment (5 51. 53 (c) (4 )).

.51 13

1 The remainder of this chapter provides specific guidance for 2

each environmental issue identified as either a Category 2 or 3

Category 3 issue in Table B-1.

The issues in Sections 2.1 4

through 2.12 should be addressed in the supplemental 5

environmental report.

)

6 4

7 2.1 HEAT SHOCK. IMPINGEMENT, AND (NTRAINMENT ETTECTS ON FISH 8

AND SHELLFISH 9

10 10 CFR 51.53 (c) (3) (ii) (A) requires that the supplemental 11 environmental report demonstrate that 12 13 "The nuclear power plant uses only cooling towers for 14 primary condenser cooling or that the license renewal 15 applicant holds current Clean Water Act 316(b) 16 determinations and if necessary a 316(a) variance 17 pursuant to 40 CFR Part 125 or equivalent State permits.

18 If no such demonstration can be made, an assessment of 19 the impact of the individual plant license renewal on 20 fish and shellfish resources resulting from heat shock 21_

(Clean Water Act 316(a)) and impingement and entrainment 22 (Clean Water Act 316(b)) must be provided."

23 24 This Category 2 issue is a combination of six related items 25 described in Sections 4.2.3.1.2, 4.2.3.1.3, 4.2.3.1.4, and 26 4.4.4 of the GEIS.

The purpose of this section is to provide 27 guidance for preparing the applicant's assessment of license 28 renewal impacts on the aquatic environment and biota at and in 29 the vicinity of the site.

30 31 Impingement and entrainment are cooling system intake-related 32 effects that are considered by EPA or state water quality 33 permitting agencies during the development of National 34 Pollutant Discharge Elimination System (NPDES) permits and 35 Clean Water Act 316(b) determinations.

Applicants holding 36 approved 316(b) determinations need not nddress entrainment or 37 impingement.

Applicants without approved 316(b) 38 determinations should describe the reasons why such a 39 determination has not been made, provide an assessment of the 40 character and magnitude of any entrainment and impingement 41 problem, and describe actions taken to resolve the problems.

42 43 The potential for heat shock is also a factor in NPDES 44 permitting.

Under the Clean Water Act, applicants must comply 45 with state mixing zone criteria and thermal discharge limits 46 or, if unattainable, obtain site-specific variances.

These 47 site-specific variances take the form of Clean Water Act

-48 316(a) demonstrations.

Applicants having approved 316(a) l 49 demonstrations need not evaluate heat shock in their 50 application.

Applicants not meeting required limits and 51 without an approved 316(a) variance should describe the 52 reasons why a variance has not been granted, provide an 53 assessment of the character and magnitude of the heat shock 54 problem, and describe actions taken to resolve the problem.

55 14 l

l l

1 2

INFORMATION AND ANALYSIS CONTENT 3

4 The types of data and f.nformation to be submitted will be 5

affected by site-and plant-specific factors, and the degree 6

of detail should be modified according to the anticipated 7

magnitude of the impacts.

The following data or information 8

and analyses should be provided.

9 10 A.

A description of the condenser cooling system.

If the 11 condenser cooling system uses only cooling towers for 12 heat dissipation and neither a 316(a) variance nor a 13 316(b) determination is required, no further information on this issue need be provided.

Otherwise, the applicant 14 15 must provide copies of a current 316(a) variance and/or a 16 316(b) determination, as required.

If the required 17 documents are available, item C may be omitted.

If 18 either of these documents is required, but not available, 19 further evaluation of the issue should be provided.

20 21 B.

Recent data and information on the site and vicinity :

i 22 23 1.

Location and va.'.ue of the commercial and sport 24 fisheries for both finfish and shellfish.

25 26 2.

Distribution and abundance of "important"2 species 27 of fish or shellfish and identification of critical 28 life support areas such as spawning areas, nursery 29 grounds, feeding areas, Wintering areas, and 30 migration routes.

31 32 3.

Presence-of endangered or threatened species of 33 fish or shellfish and their habitat preference.

34 Also fishery restriction efforts being undertaken 35.

or planned by Federal and State agencies.

36 37 C.

Estimates of the amount and effect of impingement of fish 38 and shellfish and entrainment of fish and shellfish in 39 early life stages.

Of particular concern are effects on 40 1

For the purpose of reviewing this issue inclusion of 41 waters within a five mile radius defines " vicinity."

42 2

For the purposes of these environmental reviews a 43 species of fish or shellfish is "important" if a 44 specific causal link can be identified between the 45 proposed project and the species and if one or more of 46 the following criteria applies (a) the species is 47 commercially or recreationally

valuable, (b) the 48 species is threatened or endangered (Pub. Law 93-205, 49 87 Stat. 884), (c) the species affects the well-being 50 of some important species within criteria (a) or (b),

51 or (d) the species is critical to the structure and 52 function of the ecological system.

15

1 threatened or endangered species and on restoration 2

efforts for anadromous fish.

Also provide estimates of 3

the magnitude of the impact for those important species 4

of fish and shellfish having commercial or recreational 5_

value that are affected.

These estimates may be 6

expressed in terms of dollars, lost opportunity for l

7 recreational pursuits, percent reduction in harvest, 8

percent loss of habitat, or other appropriate 9

quantifiers.

If impacts are adverse, the applicant 10 should identify actions that can be taken to mitigate the 11 impacts and should describe specific plans for 12 mitigation, if any.

13 14 D.

The effect of heat shock on species of fish and 15 shellfish, provide estimates of the amount and effect of 16 impingement of fish and shellfish and entrainment of fish 17 and shellfish in early life stages.

Of particular 18 concern are effects oli threatened or endangered species 19 and on restoration efforts for anadromous fish.

If 20 impacts are adverse, the applicant should identify 21 actions that can be taken to mitigate the impacts and 22 should describe specific plans for mitigation, if any.

23 24 2.2 EFFECTS OF COOLING PONDS ON GROUNDWATER OUALITY 25 26 10 CFR 51.53 (c) (3) (ii) (B) requires that the supplemental 27 environmental report demonstrate thatt 28 29 "The nuclear power r! ant is not located at an inland site 30 or does not have cooling ponds.

If no such demonstration 31 can be made, an assessment of the impact of the 32 individual nuclear power plant license renewal on 33 groundwater quality must be provided."

34 35 This Category 2 issue is discussed in section 4.4.3 of the 36 GEIS.

37 38 The purpose of this section is to provide guidance to the 39 applicant for identification and assessment of tho impacts of 40 groundwater degradation resulting from seepage of cooling pond 41 water.

If the applicant cannot demonstrate that the plant is 42 not located at an inland site or does not use cooling ponds, 43 an assessment should be provided.

44 45 INFORMATION AND ANALYSIS CONTENT 46 47 The following types of information and analyses should 48 generally be provided to assess the potential for groundwater 49 quality degradation resulting from seepage of cooling pond 50 water during operation for sites with cooling ponds.

In 51 performing assessments, significant consideration should be 52 given to actual experience of the plant over the past 20 or LL more years of operation.

Data based on operational experience l

54 is considered more reliable than data based on predictions.

55 16 l

l l-

1 A.

The use of closed-cycle cooling ponds.

If such a pond is a

not osed, the information called for in items B through J 3

can be omitted.

4 5

B.

The location of the plant.

If the plant site is not 6

located inland, the information called for in items c 7

through J can be omitted.

B 9

C.

Cooling pond characteristics (e.g., use of liners, une of 10 impermeable materials, impermeable natural soils) that 11 would prevent infiltration into local aquifers.

la 13 D.

Types and concentrations of impurities in the cooling 14 pond water, and chemistry of soils along pathways to 15 local aquifers.

16 17 E.

Characteristics including quality of trater of local 18 aquifers that could be affected by infiltration of 19 cooling pond water.

20 21 F.

Federal, State and local groundwater quality 32 requirements, with emphasis on any changes to these 23 requirements that have occurred during the plant's 34 operational period.

35 26 G.

Identification and characterization of all off-site 27 groundwater users who could be impacted by degradation of 38 aquifers.

39 30 H.

Mitigation measures proposed by the applicant to avoid or 31 minimize any groundwater degradation impacts.

32 33 I.

If an assessment is required, a determination of whether 34 contamination of groundwater from the cooling pond (s) is 35 possible.

This determination should be based primarily 36 on the concentration of contaminants in-the cooling pond 37 water and characteristics of intervening soils and rock.

38

- If contamination of groundwater is determined to be 39 highly unlikely, the analysis may be considered complete 40 and the following steps may be omitted.

41 43 J.

Assessment of the types and magnituden of contamination 43 introduced into the aquifer.

Estimated contamination 44 levels should be compared with Federal and State 45 groundwater quality standards and with water quality 46-requirements of other potentially affected groundwater 47 users.

If Federal and State standards are met, and ether-i 48 groundwater users are not impacted, the analysis should l

49 be considered complete.

-C0 51 17

+-w.,wair--y-

-y v,'

y wpy,--r-p-y y

7.mm,,-,

yy

-w-f6

---,-,,..-m.

,,,.,-.m,,.y.m.,.,

-.-,-w,.

. -. --m-.

m

1 2.3 GROUNDWATER USE CONTLICTS 2

3 10 CFR 51.53 (c) (3) (ii) (c) requires that the supplemental 4

environmental report demonstrate that:

5 6

"The nuclear power plant does not usa Ranney wells and 7

either does not pump 100 or more gallons per minute of 8

groundwater or does not have private wells located within 9

the cones of depression of the nuclear power plant wells.

10 If no such demonstration can be made, an assessment of 11 the impact of the individual nuclear power plant license la renewal on groundwater use conflicts must be provided."

13 14 This Category 2 issue is a combination cl three related issues 15 discussed in sections 4.2.2.1.1, 4.2.2.1.2, end 4.2.2.1.4 of 16 the GEIS.

17 18 This section provides guidance to the applicant for 19 identification and assessment of the environmental impacts of 30 groundwater Withdrawal and use during the license renewal al period.

If the applicant cannot demonstrate that the plant 33 does not use Ranney wells and either does not pump 100 or more 23 gallons por minute of groundwater or does not have private 34 wells located within the cones of depression of the plant 25 wells, the supplemental environmental report should provide an 26 assessment of the impact of groundwater use conflicts.

27 38 INFORMATION AND ANALYSIS CONTENT 39 30 The following types of information and analyses should 31 generally be provided to assess the presence and magnitude of 33 groundwater use conflicts during operation.

33 34 A.

Identification of any operational groundwater uses or 35 operational dewatering activities. If none, the 36 information called.for in items B through G can be 37 omitted.

38 39 B.

Locations of on-site wells, depths of wells, and 40 operational pumping capacities and durations.

If pumping 41 rates are less than 100 gpm and Ranney wells are not 42 used, the information called for in items C through G can 43 be omitted.

44 45 C.

Descriptions of groundwater aquifers under the site, 46 including characteristics needed to determine the size of 47 cones of depression associated with on-site wells.

48 49 0.

Determination of sizes of cones of depression of on-site 50 wells.

51 18

1 E.

Locations of any off-site wells (existing and known 2

future) within the cones of depression of on-site wells, 3

and the depths, pumping capacities, and water needs for 4

the wells.

If no such off-site wells are identified, 5

items F through G may be omitted.

6 7

F.

Any mitigation measures proposed to avoid or minimize 8

groundwater use conflicts.

9 10 G.

A determination of the extent to which operational 11 groundwater use or dewatering activities will impact off-12 site groundwater users (current and known future users).

13 This determination should be based on the amount of water 14 withdrawn on site, the recharge capabilities of the 15 aquifer, locations and elevations of off-site wells, and 16 water needs of other water users.

17 18 19 2.4 EFFECTS OF REFURBISHMEffT Oli IMpORTAliT PLAliT AllD AllIMAL 20 HABITATS 21 22 10 CPR 51.53 (c) (3) (ii) (D) requires that the supplemental 23 environmental report demonstrate that:

24 25

" License renewal-related construction activities that are 26 to be undertaken involving additional on-site land use 27 will not affect important plant and animal habitats.

If 28 no such demonstration can be made, an assessment of the 29 impact of the individual plant license renewal on 30 important plant and animal habitats must be provided."

31 32 This Category 2 issue is discussed in section 3.6 of the GEIS.

33 34 An applicant whose plans for license renewal involve 35 construction of new structures or involve laydown areas on 36 previously undisturbed land should briefly describe the 37 activities involved, the areas to be disturbed, and whether 38 important plant and animal habitats will be affected.

39 Particularly important resources include wetlands, habitats 40 used by threatened or endangered species, staging or resting 41 areas for large numbers of waterfowl, rookeries, restricted 42 wintering areas for wildlife, communal roost sites, strutting 43 or breeding grounds of gallinaceous birds, and rare plant 44 community types.

The applicant should identify-alternative 45 courses of action available to avoid or reduce possible 46 impacts, evaluate the icvel of impacts, and justify the 47 proposed course of action.

48 i

49 If important plant and animal habitats occur on a plant site 50 but it is shown they would be avoided during the course of 51 refurbishment activities, the impacts are considered 52 insignificant, and no further evaluation is necessary.

If l

53 this demonstration cannot be made, the supplemental l

54 environmental report should provide an assessment of the i

55 impact of on-site land use on important plant and animal l

19 1

1 habitate.

Assessments should be conducted in sufficient 2

detail to project both the potential impacts and provide 3

mitigative measures to control the level of impact.

4 5

IliFORMATIoli AllD AllALYSIS CollTEliT 6

7 The kinds of information and analyses that should be provided 8

will be affected by site-and plant-specific factors, and the 9

degree of detail should be modified according to the 10 anticipated magnitude of the potential impacts.

The following 11 information and analyses should usually be provided:

12 13 A.

Identification of important plant and animal habitats on-14 site or in the vicinity.

If none, items B and C do not i

15 apply.

16 17 B.

Identification of any construction activities that will 18 involve additional on-site land use that may affect 19 important plant and animal habitats.

If none, item C 20 does not apply.

21 22 C.

For the plant site and vicinity:

23 24 1.

a map of the site and vicinity showing the area and 25 boundaries of major wetland communities, special 26 habitats (e.g., spring seeps, bogs, sink holes, 27 rare or unique habitats), and any habitats used by 28 "important" species; 29 30 2.

a list of "important" terrestrial wetlands 31 vertebrate species known to occur, and lists of 32 invertebrate wetland species of local importance or 33 concern as disease vectors or pests; 34 35 3.

estimates of the relative abundance of both 36 commercially and recreationally important wetland 37 game and nongame vertebrates; 38 39 4.

any proposed refurbishment activities expected to l

40 impact wetland communities that have been defined 41 as rare or unique or that support threatened or 42 endangered species; 1

43 l

44 5.

estimates of the impact magnitude on these 45 important species having commercial or recreational 4

46 value.

The estimates may be expressed in terms of 47 dollars, lost opportunity for recreational i

48 pursuits, percent reduction in harvest, percent l

49 loss of habitat, or other appropriate quantifiers; 50 51 6.

a description of proposed mitigation reasures to 52 minimize the impacts described above; and 53 20

1 7.

a list of threatened or endangered wetland species 2

that are known to occur, their site-specific 3

habitat, and estimates of their population.

4 5

Reference may be made, in the assessment of this issue, to 6

information provided in sections 2.1 and 2.7 of the 7

supplemental environmental report.

Mitigation is discussed in 8

section 3.6 of the GEIS.

9 10 2.5 ErPECTS OF REPURBISHMENT ON_SURPACE WATER OUALITY

-11 12-10 CTR 51.53 (c) (3) (ii) (E) requires that the supplemental 13 environmental report demonstrate that 14 i

15 "No major construction activities associated with the 16 individural nuclear power plant license renewal will occur 17 at the rite.

If no such demonstration can be made, a 10 construction impact control program that will mitigate 19 potential impacts on the aquatic environment from soil 20 erosion or spills must be implemented; and a description 21 of such program must be provided."22-23_

This-Category 2 issue is discussed in section 3.4.1 of the 24 GEIS.

25 26 Thoso applicants:whose plans for license renewal and plant 27 life extension involve construction of new-structures or 28 involve lay down. areas on previously undisturbed land should 29 briefly describe the activities involved, the areas to be

=30 disturbed, and commitments to minimize potential impacts from 31 soil erosion or spills.

Impacts that might otherwise be 32 considered moderate or large may be rated as small by the 33 staff if applicants demonstrate that approved."best management 34-practice"-will be employed to control soil-erosion and spills.

35 If this demonstration cannot be made, the supplemental-36 environmental-report should provide an assessment of soil 37 erosion impacts and spill impacts.

38 39 This assessment should evaluate the impacts of refurbishment 40 construction activities.

These impacts should include 41

-building or expanding on-site storage capability for spent 42

_ fuel.

TheLimpact evaluation should be limited to the 43 construction activities themselves and the time period during 44 which the construction is accomplished.

45 46 INFORMATION AND ANALYSIS CONTENT 47 48_

The following information and analyses should usually be 14 9 provided:

-50 51 A.

A discussion of what, if any, major construction 52-activities (e.g., the construction of on-site spent fuel 53 storage facilities) will be needed as part of license 54 renewal.

If none, the following items may be omitted.

55 21 a - -... - - -. -. -

- _ _ _ _ _ - =

1 B.

A description of the facilities to be provided or 2

expanded and the associated construction activities.

3 4

c.

A description of the magnitude of potential impacts 5

associated with the proposed construction activities and 6

how those impacts will be mitigated, including a 7

description of the construction impact control program 8

and the programs implementation.

9 10 D.

A description of the best management practicos to be used 11 to control soil erosion and spills, consistent with 12 Section 319 of the clean Water Act.

13 14 Mitigation measures to help protect surface water quality from 15 refurbishment impacts are discussed in section 3.4.1 of the 16 GEIS.

37 18 2.6 EFFECTS OF LICENSE RENEWAL ON HOUSING 19 30 10 CFR 51. 53 (c) (3) (ii) (F) requires that the supplemental al environmental report demonstrate that:

33 23 "The nuclear power plant is in a medium or high 3

24 population area and not in an area where growth control 25 measures that limit housing development are in effect.

36 If no such demonstration can be made, an assessment of 37 the impact of the individual nuclear power plant license 38 renewal on housing availability must be provided."

29 30 This Category 2 issue is a combination of two related issues 31 discussed in sections 3.7.2 and 4.7.2 of the GEIS.

33 33 If the required demonstration cannot be made, an assessment of 34 how housing availability would be affected by any increased 35 on-site labor force associated with license renewal should be 36 made.

37 38 The applicant should provide demographic data based on the 39 current decade census and, where available, more recent census 40 data.

3 41 An area is considered to have a medium or high 42 population if any one of the following conditions is 43 satisfied:

44 45 (a) the plant is.within 20 miles of a city of 25,000; 46 (b) the plant is within 50 miles of a city of 100,000; 47 (c) the population of the area within 20 miles of the 48 plant is 75,000 or more; 49 (d) the population of the area within 50 miles of the 50 plant is 1,500,000 or more; or 51 (c) the population of the area within 20 miles of the La plant is 50,000 or more and within 50 miles of the 53 plant the population is 400,000 or more.

22 l

1 This assessment should consider incremental on-site labor, 2

peak number of workers and duration of the peak, the number of 3

workers expected to commute daily, the number of workers 4

expected to require temporary and permanent housing, and tho 5

inventory of rental and of permanent housing within 50 miles 6

of the site.

The incremental demands for housing should be 7

compared to the total inventory of housing and a level of 8

impact assessment (small, moderate or largo) should be made.

9 10 11 A similar analysis should be performed to assess the level of 12 impact on housing availability from the incremontal labor 13 force during refueling and maintenance outages.

14 15 INFORMATION AND ANALYSIS CONTENT 16 17 The particu'.ar kinds of information and analyses that should 18 be provided will be affected by site-and plant-specific 19 factors, and the degree of detail will be modified according 20 to the anticipated magnitude of the potential impacts.

The 21 following housing-related information, which may be obtained 22 from the environmental report, and supplemented as necessary 23 from appropriate Federal, State, and local agencies, and 24 housing-related business entities, should be provided:

25 26 A.

population density and city size data (current decade 27 census or more recent data where available) to 28 demonstrate whether the plant is situated in a medium or 29 high population area.

Information required is population 30 within 20 miles of the plant, population within 50 miles 31 of the plant, and a map showing any cities of 25,000 or 32 more within 20 miles of the plant and any cities of 33 100,000 or more within 50 miles of the plant.

34 35 B.

Existence of growth controls which limit housing 36 development.

If information provided in A and B indicate 37 that the nuclear power plant is in a medium or high 38 population area and not in an area where growth control l

39 measures that limit housing development are in effect, 40 then C may be omitted.

41 42 C.

Number, types, and locations of housing units, including i

43 year-round, seasonal homes, mobile homes, hotel / motels 44 and public housing units, and housing characteristics 45 such as the vacancy rates for such units, monthly median 46 gross rentals and costs, site of units, quality, etc.

i 47 48 D.

population change / economic development that could impact 49 on vacancy rates,-rental prices and potential for 50 inflation.

l 51

(

52 E.

Location of existing and projected housing and trailer 1

53 parks; current temporary worker housing patternst l

54 location, type, and value of current housing units; and i

55 forecasted location preferences of new personnel.

i 23 l

~

m

1 F.-

potential for conversion of housing units.

2 3

G.

The number of workers and duration of assignment for tbe 4

refurbishment period and for periodic refueling and 5

maintenance outages.

6 7

H.

Estimates of peak transient population within 10 miles of 8

the plant, and identification on a map of any major 9

facilities accounting for transient population.

10 la I.

A screening of housing characteristics in the 'tegion of la the site to determine potentially affected subregions and 13 communities.

At least the following factors should be 14 considered:

15 forecasted location preferences of new personnel 16 forecasted number of personnel and duration of 17 18 assignment during plant refurbishment and refueling 19 maintenance outages location of existing and projected housing rental 30 al markets in region transportation accessibility 23 number and types of housing units 33 locally enacted measures that limit housing 34 35 development 36 37 J.

An assessment of impacted areas of the region, if any, 28 and the associated communities and forecasts of the 39 extent and magnitude of impacts in terms of housing 30 availability, inflation, changes in housing stock, 31 accessibility to resident population, levels of impact 33 during the refurbishment and refueling / maintenance 33 outages.

34 35 K.

A description of any proposed mitigation measures to 36 minimize the potential impacts described above.

37 38 2.7 ELECTRIC SHOCK FROM TRANSMISSION LINE INDUCED CURRENTS 39 40 10 CFR 51.53 (c) (3) (ii) (G) requires that the supplemental 41 environmental report demonstrate that:

43 43 "The design of the transmission lines of the nuclear 44 power plant meets the National Electric Safety Code 45 recommendations regarding tne prevention of electric 46 shock from induced currents.

If no such demonstration 47 can be made, an assessment of the impact of the 48 individual nuclear power plant license renewal on the l

49 potential electric shock hazard from the transmission 50 linet of the plant must be provided."

51 l -

52 This Category 2 issue is discussed in Section 4.5.4.1 of the 53 GEIS.

54 l

24

l 1

The potential for electric shock from induced current should-l 2

be reviewed with respect to the National Electric Safety Code 3

(NESC) recommendation if (1) no NESC review was performed in 4-the NEPA review for the initial operating license; (2) a 5

change in voltage has been made since the initial operating 6-license and no NESC review was performed; or (3) land use 7

features have changed since the original operating license 8

resulting in possible hazardous conditions.

Wherever the 9

potential for severe shock exists the applicant should take 10 action to reduce the potential. The results of any analyses 11 and subsequent actions should be reported in the supplemental 12 environmental report.

13 i

14 This issue concerns those portions of the operating high 15

_ voltage transmission lines (HVTLs) that connect the plant with 16 the regional electric transmission grid.

The scope also 17 includes only acute shock effects.

Other HVTL issues, l

18 including the issue of chronic health-effects from HVTL 19 electric and magnetic fields, have been identified as Category 20 1 issues.

Mitigation for this issue is mentioned in section 21 4.5.4.1.1 of the GEIS.

22 23 INFORMATION AND-ANALYSIS CONTENT 24 25 Data and information that should be provided for evaluating 26

_the existence of, or potential for, electric shock from HVTLs 27 should-include ti.e following:

28 29 A.

A demonstration that the HVTLs meet the National Electric 30 Safety Code.

If this demonstration can be.made, the 31 impact of this' issue is bounded by Appendix B of 10 CFR 32 51 and the following information can be omitted.

33 34 B.

National Electric-Safety Code (current edition) 35 recommendations requirements and applicable state 36 standards.

37

. 38 C.

HVTL electrical design and operating parameters including 39 operating voltage, operating current, line capacity, 40 conductor type,. conductor configuration and spacing, 41 conductor clearances,= and electric and magnetic fields at 42 the center and-edge of the right-of-way.

43 44 D.

Description of_ complaints received-by the applicant or by 45 the relevant regulatory authority concerning electric 46 shock from objects near HVTLs.

47 48 E.

Descriptions, including photos and maps, of large or

. 49 linear metal objects near HVTLS, including buildings,

' 50 fences,-railroad tracks, and irrigation pipes.

51 52 F.

Grounding procedures for stationary objects along the 53 rights-of-way.

54 25 4

---nn

..,-,-..n.--

-.,..._.,_..,-__.-.._._,-,._-_,n,-,,-.__

n.,-,,,,--n,_,,,,,,,,--,e

-m,

i 1

G.

Changes made since initial licensing including operating 2

voltage changes and nearby land-use changes.

3 4

H.

potential for electric shock from large vehicles stopped 5

under the I;VTL.

6 7

1.

The magnitude of potential impacts on health from the 8

above described shock hazard during the license renewal 9

term.

10 11 J.

A description of proposed mitigation measures to minimize 12 the potential impact described above.

13 14 2.8 HEALTH EFFECTS OF THERMOPHILIC ORGANISMS 15 16 10 CFR 51.53 (c) (3) (ii) (H) requires that the supplemental 17 environmental report demonstrate that:

18 19 "The nuclear power plant does not use a cooling pond, 20 lake, or canal and does not discharge water to a small 21 river.

If no such demonstration can be made, an 22 assessment of the impact of thermophilic organisms on the 23 health of recreational users of affected water must be 24 provided."

25 26 This Category 2 issue is discussed in section 4.3.6 of the 27 GEIS.

28 29 Plants using cooling ponds, lakes, or canals and those 30 discharging to small rivers (average flow less than 2830 nd/s) 31 have the potential to influence thermophilic microorganisms 32 (e.g., Salmonella sp., Shigella sp., pseudomonas aeruginosa, 33 Legionella sp., Naegleria, Acanthamoeba and thermophilic 34 fungi).

Health questions related to public use of affected 35 waters should be addressed by the applicant in the form of 36 consultation wit'a the state health department prior to 37 application for license renewal.

If the applicant cannot 38 demonstrate that the plant does not use cooling ponds, lakes, 39 or canals and does not discharge into a small river, the 40 supplemental environmental report should provide an assessment 41 of the potential for health effects and the results of the 42 consultation with the state health department.

43 44 INFORMATION AND ANALYSIS CONTENT 45 46 Information and analyses that should be provided for the 47 evaluation of the existence, and potential for deleterious 48 impacts, of thermophilic microorganisms include the following:

49 50 A.

Whether the plant uses a cooling pond, lake, or canal, or 51 once-through cooling systems with discharge to a small 52 river (flow rate less that 2830 ud/s).

If not, this 53 issue is bounded by Appendix B, 10 CFR 51 and the 54 information called for in items B through I can be 55 omitted.

26 n

)

1 B.

Knowledge of the tests for the occurrence of the cited 2

pathogens, and factors germane to their presence in 3

aquatic environs.

4 5

C.

Temperature increases of aquatic environs subject to 6

thermal discharges.

7 0

D.

Information on the levels of concentration of these 9

organisms which are considered as hazardous to public 10 henith.

Note:

OSHA or other legal standards for 11 exposure to microorganisms do not exist at present.

12 13 E.

Information on potential control measures.

14 13 T.

Results of analysis made for the presence of deleterious 16 thermophilic microorganisms.

These include the enteric 17 pathogens Salmonella sp. and Shigella sp. as well as 18 pseudomonas aeruginosa and thermophilic fungi.

In 19 addition, analyses for the presence of unusually high 20 concentrations of the normally present Legionella sp.

21 (Legionnaires' disease bacteria) and the free-living 22 amoebae of the genera Naegleria and Acanthamoeba should 23 be cited.

24 25 G.

An evaluation of the data concerning the occurrence and 26 concentrations of any of the listed deleterious 27 thermophilic microorganisms and whether or not any of 28 them are present under conditions that might be harmful 29 to members of the public coming in contact with them.

30 Consultation with state health departments should be 31 utilized for this evaluation.

32 33 H.

A determination of the magnitude of potential impacts of 34 thermophilic organisms on public health during the 35 license renewal term.

36 37 I.

A description of proposed mitigation measures to minimine 38 the potential impacts described above.

39 40 2.9 LOW-LEVEL RADIOACTIVE WASTE STORAGE AND DISPOSAL 41 42 10 CFR 51. 53 (c) (3) (ii) (I) requires that the suppismentsl 43 environmental report demonstrate that 44 45 "The nuclear power plant will have access to a low-level 46 radioactive waste disposal facility through a low-level 47 waste compact or an unaffiliated state.

If no such 48 demonstration can be made, a presentation of capability 49 and plans for interim vaste storage must be provided with 50 an assessment of potential ecological habitat destruction 51 due to construction activities."

52 53 27

1 I

1

-This is a Category 2 issue that covers two-issues under " Solid

-2 Wacte Management" in Table A-1.

These issues are " low-level 3

radioactive waste storage" and " low-level radioactive waste

-4) disposal." :They are addressed in sections 6.3.2 and 6.3.3 of 1F the GEIS.

6 7-The applicant should demonstrate access to off-site disposal 18?

-facilities for--low-level radioactive vaste-through a low-level 9

wast 0 compact or an unaffiliated State during the full t3rm of 10=

the renewed operating license.

If this demonstration is made, 11 no further information is required.

If this demonstration is L12 not made, applicants must demonstrate that they-have examined 13 their capabilities and plans for ctraite storage, storage by

14 off-site contractor, and special waste reduction contingencies 15 or other vaste management methods.--On-site storage of low-16 level waste for up to_3 years is considered normal and does

'17 not require further-analysis.

If prolonged on-sjte storage s 18-1aw-level waste is required, the potential for plant and-19 animal habitat disturbance should be evaluated.

30

.al-INFORMATION A'ND ANALYSIS CONTENT 23

'33 The kinds of,information and analyses that should be provided

24 will be affected by site-and plant-specific factors, and the 35-degree of detail should be modified according to tha l36 anticipated magnitudu of the potential impacts.

The following 127-

-information should1usually be provided:

?9 A.

A demonstration that the applicant will have access to a t

low-level radioactive weste disposal facility through a low-level waste compact or an unaffiliated State.

If 6

73-such a d7monstration is provided, the following items may 33-be omitted.

134 35-

-B.

A description of the plans for both temporary.and 36; permanent storage-including a description of the interim 37 wast # storage systems to-be generated during the renewal 38-

-term..

39-40 C.-

The anticipated quantity and characteristics of the

43 -

wastes.

42 14 3 ?

.D.-

'An assessment of the nagnitude of-potential plant and 44-animal habitat disruption resulting from the construction 45 of-interim waste-storage systems.

46:

47 E.

A description of propored tions to mitigate any

'48 moderate-to large impacts.

-49 28 b

___=______- ____-___ _ _

1 3.10 DEMONSTRATION OF COST ADVANTAGE OF LICENSE RENEWAL 2

-3 10 CFR Sl.53 (c) (3) (ii) (J) requires a demonstration that:

4 5.

" Replacement of equivalent generating capacity by a coal-6 fired plant has no demonstrated cost advantage' over the 7

individual nuclear power plant license renewal. If no 8

such demonstration can be made, a justification for 9

choosing the license renewal alternative must be 10 provided.- For nuclear power plants located in 11 California, Oregon, Washington, or Arizona, applicants 11 for license renewal must provide an assessment of 13 geothermal generating capacity as an alternative to 14-license renewal in addition to the cost demonstration 15 results."

16 17 This Category 2 issue is a combination of four related issues 18 discussed in sections 7.3.6 and 9.4.5 of the GEIS.

19 20 Under a wide set of circumstances nuclear power plant 21-refurbishment and operation during a license renewal period is 22 expected to be economical. However, plants with a history of 23 significantly lower than average capacity factors or higher 24 than average operating and maintenance costs may not be 25 economic to relicense.

License renewal of plants with high 26 refurbishment costs may be less economical than building new 27 generating plants.

In the States of California, Oregon, 28 Washington, and Arizona geothermal energy may be a source of 29 baseload power with economic and environmental advantages over 30 renewing the license of a nuclear power plant.

For nuclear 31 power plants located in these states,--applicants must provide 32 an assessment of the cost and environmental impacts of 33 geothermal relative to license renewal.

34 35 Appendix H to NUREG-1437 providas an acceptable simplified 36 screening tort for separating those cases for which a formal 37 economic ana:

.is is necessary from those for which it is not.

J8 Combinations of break-even capital-costs and future operating a

costs for license renewal are developed.

Refurbishment costs 40 are equivalent to capital costs for this methodology; and-41 future fuel, operation and maintenance (O&M), and interim 42 capital costs comprise the future operating costs.

No credit 43 is.taken in the threshold analysis for the delay of 44 decommissioning.

45 46 INFORMATION AND ANALYSIS CONTENT L

47 48 Table 2.10-1 shows threshold criteria developed by the staff l

49-for capital and operational costs of license renewal.

These l

50 criteria have been developed hased on combinations of capital l

I S1 In performing the cost demonstration, costs of l

52 refurbis:hment, constructica, fuel, and operation and l

53 maintenance must be considered.

29

9 8

L 1

and operational costs for which license renewal would have a a

margin of economic advantage over the costs of a new 3

conventional coal plant.

The margin of advantage for license 4

renewal was built into the critoria by performing a break-oven 5

economic analysis between nuclear refurbishnent and 6

conventional coal while making assumptions economically 7

advantageous to coal (relative to the reference case cost 8

comparison).

First, this analysis is based on cost 9

relationships between NUPLEX and new coal plants beginning in 10 2000 instead of 2020.

Because of the cost escalation 11 assumption for coal fuel costs, this change means the 12 threshold values are more advantageous to the new coal 13 alternative than would be the case if they had been identified 14 using the reference case assumptions.

Second, in developing 15 the threshold criteria, a new coal plant is assumed to have a 16 70% capacity factor instead of a 60% capacity factor.

Third, 17 no credit for the delay of decommissioning is included for 18 nuclear plants, Changing the fuel cost assumptions, assuming 19 70% capacite factor for coal plants (instead of 60% in the 20 margin for uncertainty in the analysis.

21 22 Uncertainties include possible underestimates of refurbishment 23 capital costs, the possibility of higher than historical 24 operating costs during the decommissioning.

If its projected 25 capital and operational costs can break even under these 26 assumptions, license renewal is deemed to have met the 27 threshold test.

Further, by employing cost relationships as 28 of the year 2000, the threshold analysis is most relevant to 29 the initial license renewal applications.

30 31 Given the modified assumptions, the staff found the 32 relationship that defines the combinations of operational and 3:

capital costs that support the economics of license renewal 34 for a twenty-year period.

Some of these combinations are 33 presented in Table 2.10-1 for plants that operated at capacity 36 factors of 50%, 60%, or 70%.

In other words, if an applicant 37 is able to demonstrate that the plant would meet any of the 38 combinations of operational and capital threshold values 39 presented in Table 2.10-1 for the capacity factor at or above 40 which the' plant cperates, the plant passes the threshold 41 criteris m.d the applicant may avoid further economic 42 justification.

Alternatively, it passes the threshold 43 criteria if it can demonstrate that it meets any combination 44 of break-even operational and capital threshold values implied 45 by the formula in Table 2.10-1.

This formula can be used with 46 any combination of capacity factor and estimated capital costs 47 to find the operational cost threshold value.

48 49 30 l

- - - - -A

-l " Table 2.10-1 Threshold operational cost criteria for capital ~ cost

-2 categories at 50%, 60%, and 70% capacity factors' 3

operational cost maximum 4

For capital cost (1989$/kW)

(1989$/kW),

for-capacity factor of:

5 Greater than -Less than or equal to 50%

60%

70%

6 0

100 188 227 267 7

100 200 180 219 255 8

200-400 164 203 243 9

400 600 148 187 226 10 600 800 132 171 210 11 800 1,000 115 155 194 12 13

  • The operational cost' criteria represent the maximum that the historical 14 operational costs for the correnponding capaelty f actor and capital refurbishment 15 costs.

Instead of using this table, a licensee may use the general formula for 16 calculating an operational cost maximum using a particular capacity factor and 17 capital refurbishment costa 18 19 operational cost maximum = -1.61 + (394.60 x cF/100) - (0.0802 x CC),

20 21 where CT = the capacity factor, expressed as a percentage, and cc = the estimated 22 refurbishment. capital costs. Refurbishment capital costs must include overnight 23: construction costs, ATUDC, and the preser t values of energy replacement and 24 increased regulatory costs.

25 26-27 28 If an applicant cannot provide this demonstration using the 29 simplified analysis methodology of Appendix H to NUREG-1437, a

30. detailed cost analysis should be provided showing that plant license 31 renewal is the most cost effective option compared to the most 32 reasonable _ alternative source of baseload electricity generation, 33 which may be fired by coal, oil, gas, or may be new nuclear.

34, Sections 9.3.8 through 9.3.10 of the GEIS discusses the alternatives.

35 36 If ar. assessment is required, the applicant should determine the most 37 reasonabic alternative source of baseload electricity generation, and 38 should compare its cost effectiveness with the license-renewal 39 -alternative. - Estimates of the cost associated with the most 40 reasonabic alternative source of generation should be provided.

41 Detailed breakdowns should be provided for cost components such as

-42. overnight investment, allowance for fundo used during construction, 43 interim investment, operation and maintenance, and fuel.

44 45-2.11 THREATENED OR ENDANGERED SPECIES 46-47-10 - CFR 51. 53 (c) (3) (iii) ( A) requires tiat the supplemental ER contain 48 an assessment regarding:

s 49 50-

"The impact of the individual nuclear power plant license 51 renewal on threatened or endangered species."

31

=

1 This Category 3 issue is addressed in Sections 3.5, 3.6, and 4.2.1.1 2

of the GEIS.

3 4

Applicants should review the current Federal Recister and State 5

listings of threatened or endangered species and consult with the 6

appropriate regional office of the U.S. Fish and Wildlifa "'-vice and 7

the National Marir.e Fisheries Service, and the appropria ate 8

agencies, to identify those threatened or endangered sper.,

that 9

have been observed in the site area.

Applicants should also identify 10 those threatened or endangered species that could be expected within 11 the site area based on area range classification, ever. though 12 sightings have not been documented.

13 14 If threatened or endangered species are identified as occurring or 15 expected to occur in the site area, applicants should assess the 16 mitigative actions to be taken in license renewal with regard to 17 plant modifications, refurbishment, and renewed operation to 18 determine the potential for direct impact on the identified species 19 or their habitat.

20 21 INFORMATION AND ANALYSIS CONTENT 22 23 Each supp2emental environmental report submitted as part of an 24 application for license renewal should include an environmental 25 assessment of threatened or endangered species.

This assessment 26 should include the following information and analyses:

27 28 A.

Lists of endangered, threatened, and candidate species that have 29 been identified for the area of the plant and the area 30 immediately surrounding the plant, based on consultation with 31 the U.S.

Fish and Wildlife Service, tha National Marine 32 Fisheries Service, and appropriate State agencies.

33 34 B.

Documentation of any consultations during the operating lifetime 35 of the plant between the plant personnel and the appropriate 36 Federal and State agencies to identify any new endangered, 37 threatened, or candidate species; 38 39 C.

Copies of biological assessments prepared to meet the 40 requirements of the Endangered Species Act; 41 42 D.

Records of additional actions taken by the applicant to meet the 43 requirements of the Endangered Species Act; 44 45 E.

Description of impacts on endangered, threatened, and candidate 46 species; the magnitude of such impacts; and proposed mitigative 47 measures, if any, to minimize the potential for impact on any of 48 these species or their habitat.

49 50 2.12 *PMSPORTATION IMPACTS OF REFURBISHMENT 51 52 10 CFR 51. 53 (c) (3) (iii) (B) requires that the supplemental 53 environmental report contain an assessment regarding:

54 32 I

J

-l "The impact of-the individual nuclear power plant license a

renewal on local transportation during periods of license-3-

renewal-related refurbishment activities."-

4 5

This Category 3 issue is discussed in Section 3.7.4.2 of the GEIS.

6 In assessing the transportation impacts of refurbishment activities, 7

applicants should consider the increase in traffic associated with 8

9 additional workers and local road and traffic control conditions.

10 11 Applicants should determine the extent to which the service levels on 12 roads within 20 miles of the site will be degraded by increased 13 traffic during periods of refurbishment.

Close attention should be given to-identifying and assessing potential congestion points, such 14-as intersections,. narrow bridges, and segments of roads with low 15 16 speed limits or numerous traffic signals, or under construction.

17 Whenever the service level vill be degraded to below category B for 18 one or more locations for more than 1 month, the applicant should 19 consult with the appropriate highway-authorities to determine whether alternatives are available and warranted to reduce traffic impacts.

20 21 Category B is a level:of service, as defined by the Transportation 22 Board, indicating that existing roadways can accommodate traffic 23 without substantial delays even if no improvements are made.

24 Alternatives may include staggered work shifts, shift hours that do not-coincide with normal heavy traffic hours, carpool incentives, 25 and additional police or traffic control personnel.

26

'27 28 INFORMATION AND ANALYSIS CONTENT 29 30 Applicants should provide the following information and analyses on 31 transportation in the region around the site.

This information may 32 be obtained from the environmental report and supplemented as

-33 necessary from appropriate Federal, State, and local agencies.

34 35 A.

A description of the magnitude, origins, and routes of workers during the proposed plant refurbirhment outage and the duration 36 27 of the outage.

38 l

39 B.

-Significant changes that have occurred (and are projected to 40 occur prior to refurbishment) to regional and local highway-41 systems since the operating license was issued.

This includes 42 changes in flow-and constraint, commuting patterns, and l

43-conditions of roads and highways.

L 44 45 C.

Residential and nonresidential development which has occurred L

46

-(and is projected to occur prior to refurbishment) since the.

47-operating license was issued.

48 49 D.

Type, availability, and usage of public transportation.

50 51 E.

Refurbishment modifications that might affect traffic flow to 52-and from the plant site.

53 l

54 T.-

Characterization oi nistorical and current transportation 55 conditions in tne site region to establish the baseline 33 1

=-

1 conditions.

Use all transportation attributes :eflected by the 3

information on site region and actions that may be impacted by 3

refurbishment activities.

Provide appropriate frequency 4

distributions, cross-tabulations and graphic representations of 5-the-data as appropriate.

6 7

G.

Projection of baseline conditions without refurbishment using 8

historic and projected trends, coupled with factors other than 9

refurbishment that may affect transportation.

10 11 H.

Comparison of demand factors with " supply" factors, such as the 12 availability and condition of transportation infrastructure,

-13 roadways, and transportation system management experience, 14 personnel, and equipment.

Also determination of transportation 15 impacts by examining, for e.xample, traffic congestion, community 16 satisfaction or frustracion with community transportation 17 systems, and financial and non-financial pressures on local and 18 state jurisdictions to mitigate impacts.

Transportation impact 19 will be influenced by such " demand" factors as the number of 20 commuting workers, number of workers per vehicle, availability 21 and use of public transportation or contractor-provided van 22 pooling, and use of transportation systems by secondary workers 23 and dependents.

24 25 I.

Focus on potential highway impacts, but recognize that impacts 26 can occur with air, river, and rail systems as well, and that 27 transportation may involve the movement of goods as well as 28 people.

Relevant public concerns for transportation-related 29 issues, such as traffic noise and pollution should also be 30 considered.

31 32 J.

Assume, for a best estimate, that the in-migrants will settle in

'3?

the same communities and proportions as current site workers 34 with similar characteristics, taking into account also their 35 expressed location preferences.

Assume, for the uaximum impact 36 estimate, that all in-migrants will choose housing in one of the 37 realler communitiet, thereby concentrating the transportation 38 impacts.

39 40 K.

Report anticipated transportation impacts in such terms as 41 anticipated traffic congestion by location, declines in levels 42 of service, required infrastructure improvements, increased 43 potential for accidents, accelerated.dcterioration of roadway 44 beds and surfaces, system costs, and public concerns.

45 46 L.

For transportation impacts that have been identified, describe 47-impacted areas, duration of impacts, and impacted communities of 48 the region.

Describe minor transportation impacts in

[

49 qualitative terms.

For adverse impacts (i.e.,

impacts that 50 should be mitigated or avoided) that can be predicted, the 51 applicant should conduct a more detailed analysis which will, 52 where practical, make quantitative estimates of the magnitude of 53 the impects and plans for their_ mitigation.

54 55 34

1 CHAPTER 3.

ASSESSMENT OF OVERALL BENEFIT COST DETERMINATION 2

3 10 CFR 51.53 (c) (4) states:

4 5

"The supplemental report must contain an analysis of whether the 6

assessment required by paragraph 51.53 (c) (3) (ii)-(iii) of this 7

section changes the findings documented in Table B-1 that the 8

renewal of any operating license for up to 20 years will have 9

accrued benefits that outweigh the economic, environmental and 10 social costs of license renewal."

11 12 The applicant's evaluation should determine whether the new 13' infcrmation presented in the supplemental environmental report 14 changes the Commission's conditional generic determination on the 15 cost-benefit balance as stated in Appendix B of 10 CFR 51.

The conditional determination is that the renewal of an operating license 16 17 for up to 20 years will have accrued benefits that outweigh the 18 economic, environmental, and social cost of license renewal.

The 13 applicant should consider the overall magnitude of impacts for the 20 set of environmental issues described in Chapter 2 that are 21 applicable to the plant after applying all proposed mitigative 23 measures. HIf the applicant concludes either (1) that all issues identified in Chapter 2 are irrelevant to its plant or (2) that any 23 environmental impacts are so small that further consideration of 24 25 mitigative measures is not warranted, then no further analysis is 26 required.

However, if adverse impacts that are moderate or large are 27 identified, then the applicant must determine the collective effect 28 of the impacts on the conditional Commission finding on the cost-29 benefit balance.

The applicant should also consider the magnitude of 30 any unavoidable impacts, the required commitment of resources, and 3a the relationship between short-term use and long-term productivity.

33 In making this overall evaluation of costs and benefits, applicants 33 34 may consider those areas in which the impacts of the individual plant license renewal are clearly less or the benefits clearly greater than 35 36 -those found generically in the GEIS.

A detailed description of any 37 such counterbalancing factors, the weighting of these factors, and 38 the basis for using plant-specific data in the overall evaluation 39-process should be provided.

40 41 42 35

This page has been left blank intentionally, 36 1

REFERENCES 1)

NUREG-0099, Regulatory Guide 4.2, Revision 2,

" Preparation of Environmental Reports for Nuclear Power Stations," U.S. Nuclear Regulatory Commission, July 1976 2)

NUREG-1429, " Environmental Standard Review Plan for the Review of License Renewal Applications for Nuclear Power Plants," U.S.

Nuclear Regulatory Commission 3)

NUREG-1437, Draft 4, " Generic Environmental Impact Statement.

for License Renewal," U.S. Nuclear Regulatory Commission, May 14, 1991 4)

NUREG-0555, " Environmental Standard Review Plans for the Environmental Review of Construction Permit Applications for Nuclear PoWor Plants, " U.S. Nuclear Regulatory Commission, May 1979 9

37

This page has-been left blank intentionally i..

33

.,, -~.

~.....

a.

~ APPENDIX A 1 Summary hf Findings on NEPA issues for License Renewal of Nuclear Power Plants l

2-Issue -

Category Findings

. c

- PART 1. NEED FOR GENERATING CAPACITY Need for generating 1

1ARGE BENEFIT. License renewal of an individual nuclear power

~

espacity via license renewal plant will be needed to meet generating capacity requirements in the

~

service area and to avoid constructing and operating new generating facilities which would otherwise be necessary to replace the retired nuclear plant.

PART II. IMPACTS OF ALTERNATIVES Advantages of alternatives.

1 NO ADVANTAGE. License senewal of an individual nuclear power to license renewal plant is found to be preferable to replacement of the generating capacity with a new facility to the year 2020. License renewal is 3

found to be preferable, both emironmentally and economically to

- eithen new fossil fueled or new nuclear capacity. Wind, solar photovoltaic cells, solar thermal power, hydropower,'and biomass are found to be not preferable to license renewal because of echnological limitations, availability, and economics Geothermat could be competitive in areas where geothermal resources are readily available. These areas are in the states of California,-

Oregon, Washington, and Arizona.

PART III. BENEFITS / COST ASSESSMENT BENEFITS

' Direct Economic Generating apacity-1 1ARGE BENEFIT. Will provide from 72 x 10 to 1270 x 10 ' net 3

3 kW(e) reflecting the smallest to the largest plant.

1 Ele tric energy 1

1ARGE BENEFTT Will provide from 391 x 10 to 6898 x 10 6

6 kWh/yr reflecting the smallest to the largest plant.

3 Avoided costs

-2 SMALL TO 1ARGE BENEFIT. Compared to replacement of electric generating capacity with a new coal. fired plant, license renewal offers savings under a diverse set of conditions.

1 July 3,1991 A1 m

r.w--

e no m

-r s

-s e-

=

e=

--n

~m+

w s mr

._~

Indirect Local taxes 1

SMALL BENEFIT. Tax revenues will increase due to capital Refurbishment improvements.

Local taxes 1

SMALL BEN.. IT. The impact of tax revenues may vary frorn Renewal term small to large depending on the total tax base of the taxing jurisdictions.

Employment 1

SMALL BENEFIT. Impacts on regional employment will be small Refurbishment to moderate depending on the total employment base of the region, and will be short lived.

Employment 1

SMALL BENEFTI'. Impacts on regional employment will be small -

Renewal term to large depending on the total employment base of the region.

COSTS 3

Direct Economic Refurbishment 2

MODERATE COST. Refurbishment costs will vary widely depending on specific plant requirements. In general, costs will be significantly lower relative to the capital cost of new coal-fired plants.

Fuel 2

SMALL COST. Fuel costs will be much lower than for a new coal-fired plant.

Operation and 2

1ARGE COST. O & M costs will vary widely depending on specific maintenance plant performance but on the average they will be significantly more that for a new coal fired plant.

July 3,1991 A2

i Environmental and Socioeconomic Surface Water Quality, Hydrology, and Use (for all plants)

Effects of refurbishment on 2

SMALL COST. Impacts are expected to be minor and insignificant surface water quality during refurbishment if there are no major construction activities associated with the indisidual plant license renewal or if Dest Mtnagement Practices (BMPs) are ernployed to control soil crosion and spills; applicant must provide evidence of approved BMPs in license renewal application.

Effects of refurbishment on 1

SMALL COST. Water use during refurbishment will not change or surface water use will be reduced during reactor outage.

Altered current patterns'ut 1

SMALL COST.- Has not been found to be a problem at operating intake and discharge nuclear power plants and a not expected to be a problem during the structures -

license renewal term.

Altered salinity gradients 1

SMALL COST. Has not been found to be a problem at operating nuclear power plants and is not expected to be a problem during the license renewal term.

Altered thermal 1

SMALL COST. Has not been found to be a p'roblem at operating stratification of lakes nuclear power plants and is not expected to be a problem during the license renewal term.

Temperature effects on 1

SMALL COST Has oct been found to be a problem at operating sediment transport capacity nuclear power plants and is not, expected to be a problem during the license renewal term.

Scouring due to discharged.

1 SMALL COST. Has not been found to be a problem at operating cooling water nuclear power plants and is not expected to be a problem during the license renewal term.

Eutrophication 1

SMALL COST. Has not been found to be a problera at operating nuc! car power plants and is not expected to be a problem during the bcense renewal term.

July 3,1991 A3

Discharge of chlorine or 1

SMALL COST. Effects are readily controlled through National other blocides Pollutant Discharge Elimination System (NPDES) permit and periodic modifications, if needed, and is not expected to be a problem during the license renewal term.

Discharge of senitary 1

SMALL COST, Effects are readily controlled through NPDES wastes permit and periodic modifications, if needed, and is not expected to be a problem during the license renewal term.

Discharge of other 1

SMALL COST. Has not been found to be a problem at operating chemical contaminants nuc1 car power plants with cooling tower-based heat dissipation (e.g., metals) systems. Has been satisfactorily mitigated at other plants. It is not expected to be a problem during the license renewal term.

Water use conflicts 1

SMALL COST. Has not been found to be a problem at operating nuclear power plants with once-through heat dissipation systems.

The issue has been a concern at two nuclear power plants with cooling ponds and at two plants with cooling towers, but it will be resolved with appropriate state or regional regulatory agencies outside of NRC license renewal actions. It is not expected to be a problem during the license senewal term.

Aquatle Ecology (for all plants)

' Refurbishment 1

SMALL COST, During plant shutdown and refurbishment there will be negligible effects on aquatic biota due to a reduction of entrainment and impingement of organisms or reduced release of chemicals.

Accumulation of 1

SMALL COST. Has been a concern at a single nuclear power plant contaminants ir sediments with a cooling pond, but has been satisfactorily mitigated. Has not or biota been found to be a problem at operating nuclear power plants with cooling towers or once.through cooling system:., or a cooling pond, except for one plant. It was successfully mitigated at that plant. It is not expected to be a problem during the license renewal term.

July 3,1991 A-4

Entrainment of 1

ShtALL COST. lias not been found to be a problem at operating phytoplankton and nuclear power plants and is not expected to be a problem during the zooplankten license renewal terr.4.

Cold shock 1

ShiALL COST. lias been satisfactorily mitigated at operating nuclear plants with once-through cooling systems and has not endangered fish populations. Has not been found to be a problem at operating nuclear power plants with cooling towers or cooling ponds. It is not expected to be a problem during the license renewal term.

Thermal plume barrier 1

ShiALL COST. Has not been found to be a problem at operating to migrrting fish nuclear power plants and is not expected to be a problem during the license renewal term.

Premature ernergence of 1

ShtALL COST. lias not been found to be a problem at operating aquatic insects nuclear power plants and is not expected to be a problem during the license renewal term.

Gas supenaturation 1

ShtALL COST. Presiously a concern at a small number of (gas bubble disease) operating nudear power plants with once-through cooling systems, but has been satisfactorily mitigated. Has not been found to be a problem at operating nuclear power plants with cooling towers or cooling pnnds. It is not expected to be a picbkm durirq; the license renewal term.

Low dissolved oxygen in i

ShiALL COST. Has been a coccin done txdear power plant the discharge with a once through cooling sgtero W issue v91 be toonitored in the NPDES permit renewal process. Has cot been found to be a problem at operating cadear power plants with cooling towers or cooling ponds, it is not expected to be a prob!ete during the license renewal term, Losses from predation, 1

ShtALL COST. Has not been found to be a prob!cm at operating parasitism, and disease nuclear power plants and is not expected to be a problem during the among organisms license renewal ten i.

exposed to sublethal stresses July 3,1991 A-5

Stimulation of nuisance 1

SMAll COST, lias been satisfactorily mitigated at the single organkms (e.g.,

nuclea* power plant with a once through cooling system where it was shipworms) a problem. Has not been found to be a problem t.t operating nuclear power plants with cooling towers or cooling ponds. It is not expected to be a problem during the license renewal term.

Aquatle Ecology (for plant with once through heat dissipallon systems)

Entrainment of fish and 2

ShiALL COST, Has not been found to be a problem at most shellfish early life stages operating plants and is not expected to be a problem during the license renewal term. Licensees of plants that do not have an approved Clean Water Act 316(b) determination or equivalent state permit at the time of license renewal application must evaluate the entrainment issue in the license renewal application.

Impingement of fish and 2

ShiAll COST Has not been found to be a problem at most shellfish operating plants and is not expected to be a probletu during the license renewal term. Licensees, of plants that do not have an approved Clean Water Act 316(b) determination or equivalent state permit if required at the time of license renewal application must evaluate the impingement issue in the license renewal application.

Heat shock 2

ShiALL COST Has not been found to be a problem at most operating plants and is not expected the problem during license renewal term. Licensees of plants that do not have an approved Clean Water Act 316(a) determination or equivalent state permit, if required, at the time of license renewal application must evaluate the heat shock issue in the license rentwal application.

Aquatic Ecology (for plants with cooling tower based beat dissipation systenas)

Entrainment of fish and 1

ShiALL COST Has not been found to be a problem at operating shellfish early life stages nuclear power plants with this type of cooling system and is not expected to be a problem during the license renewal term.

July 3,1991 A6

i l

1 l

Impingement of fish and 1

SMALL COST Has not been found to be a problem at operating shellfish nuclear power plants with this type of cooling system and is not expected to be a probiem during the license renewal term.

Ileatshock 1

SMALL COST. lias not been found to be a problem at operating nuclear power plants with this t3pe of cooling system and is not expected to be a problem during the license renewal term.

Aquatic Ecology (for plants with cooling posd heat dissipation systems)

Impingement of fish 2

SMALL COST Has not been found to be a problem at most operating plants and is not expected to be a problem duriag the license renewal term. Licensees of plants that do not have an approved Clean Water Act 316(b) determination or equivalent state permit at the time of license renewal application must evaluate the impingement issue in the license renewal application.

Entrainment of fish early 2

SMALL COST Has not been found to be a problem at most life stages operating plants and is not expected to be a problem during the license renewal term. Licensees of placts that do not have an approved Clean Water Act 316(b) determination or equivalent state permit at the time of Ucense renewal application must evaluate the entrainment issue in the license renewal application.

Heat shock 2

SMALL COST. Has not been found to be a problem at most operating plants and is not expected to be a problem during the license renewal term. Licensees of plants that do not have an approved Clean Water Act 116(a) determination or equivalent state permit,if required at the time of license renewal application must evaluate the heat shock issue in the license renewal application.

July 3,1991 A7

Groundwater Use and Quality, impacts of Refurbishment Groundwater use and 1

ShtALL COST. Extensive dewatering during the original quality construction on some sites will not be repeated during refurbishment on any sites. Any plants wastes produced during refurbishment will be handled in the same manner as in current operating practices and is not expected to be a problem during the license renewal term.

Groundnter Use and Quality, impacts of OperatJon Groundwater use conflicts

?

ShfALL COST. Has not been found to be a problem at most (potable and service water) operating plants and is not expected to be a problem during the license renewal term. Plants pumping 100 or more gpm ud basing private wells located within cones of depression of reactor wells are required to assess for use conflict during the license renewal term.

Groundwater use conflicts 2

ShiALL COST. Has not been found to be a problem at most (water pumped for operating plants and is not expected to be a problem during the dewatering) license renewal term. Plants pumping 100 or more gpmm.d having private wells located within cones of depression of plant wells are required to assess for use conflict during the license renewal term.

Groundwater use conflicts 1

ShiALL COST. Water use conflicts are small and will be reso:ved (Surface water u.nd as as necessary through surface water regulatory mechanism outside of make up water-potentially NRC license renewal process and h not expected to be a problem affecting aquifer recharge) for any plant during the license renewal term.

Groundwater use conflicts 2

ShiALL COST Ranney wells can result in potential groundwater e: mney wells) depression beyond site boundary. Impacts of large groundwater withdrawal for cooling tower makeup at nuclear power plants using Ranney wells must be evaluated at the time of application for license renewal.

Groundwater quality 1

ShtALL COST. Groundwater quality at river sites may be depaded degradation (Ranney wells) by induced infiltration of poor quality river water into an aquifer that supplies large quantities of reactor cooling water. However, the lower quality infiltrating water would not preclude the current uses of groundwater and is not expected to be a problem during the license renewal term.

' July 3,1991 A8 l

.- - - - _ ~. _ -.

Groundwater quality 1

SMALL COST. Nuclear power plants do not contribute sign.Deantly depadation (saltwater to raltwater intrusion.

intrusion)

Groundwater quality 2

SMALL COST. Sites with close& cycle cooling ponds may depade depadation (coo!ir.g pcundwater quality. This is not an issue for those plants located in ponds) salt marshes. However, for those plants located inland, the quality of the poundwater in the vicinity of the ponds must be shown to be adequate to allow continuation of current uses.

Terrestrial Resources Refurbishment impacts 2

SMALL COST. Insignincant impact if no loss of important plant and animal habitat occurs if important plant and animal habitats are affected the potential impact will be assessed at the time of license renewal, Cooling tower impacts on 1

SMALL COST. Salt drift, icing, fogging. or increased humidity crops associated with cooling tower operation have not been found to be a problem at operating nuclear power plants and is not expected to be a problem during the license renewal term, Cooling tower impacts on 1

SMALL COST. Salt drift, iciug, fogging, or increased humidity native plants associated with cooling tower operation have not been found to be a problem at operating nuclear power plants and is not crpected to be a problem during the license renewal term.

Bird collisions wis cooling 1

SMALL COST. Has not been found to be a prob'em at operating towers nuclear power plants and is not expected to be a problem during the license renewal term.

4 July 3,1991 A9

-. - =.

l Cooling pond impacts on 1

ShiAll, COST. No signincant damage to vegetation has been tenestrial resources observed as a result of foggtng, icing, or increased relative humidity at nuclear reactor cooling ponds. The low levels of water contaminants in cooling ponds are not a threat to wildlife using the ponds, No signincant impact is expected at any nuclear power plant during the license renewal term.

Power line right of way 1

ShiALL COST. Periodic vegetation control causes cyclic changes in management (cutting and the density of wildlife populations dependent on the right of way, but herbicide application) long-term densities appear relatively stable. Numerous studies show neither significant positive nor negative effects of power line rights-of way on wildlife, hs signincant impact is expected at any nuclear power plant during the license renewal term.

Bird collisions with power 1

SNiALL COST. Has not been found to be a problem at operating lines nuclear power plants and is not expected to be a problem during the license renewal term.

Impacts of electromagnetic 1

ShtALL COST, No significant impacts of electromagnetic Celds on fields on flora and fauna terrestrial flora and fauna have been identified and is not expected (plants, agricultural crops, to be a problem during the license renewal term.

honeybees, wildlife, livestock)

Floodplains and wetland on 1

ShiALL COST. Periodic vegetation control is necessary in forested power line right of way wetlands underneath power lines and can be achieved with minkaal da nage to the wetlani On rare occasions when heavy equipment may rr.ed to enter a wetland to repair a power line, impacts can be minimized through the use of standard practices. No significant impact is expected at any nuclear power plant during th-license renewal term.

Threataned or E sdangered Species (for all plants)

July 3,1991 A.10

Threatened or endangered 3

Generally, reactor refurbishment and continued operation is not species expected to adversely affect threatened or endangered species.

However, consultation with appropriate agencies must occur to determine if, in fact, threatened or endangered species are present and if they will be adversely affected.

Air Quality Air Quality 1

SMALL COST. Air quality impacts from reactor refurbishment associ u.6 with license renewal are expected to be small.

Land Use On site land use 1

SMALL COST, Projected on-site land use changes sequired during refurbishment and the renewal period would be a small fraction of any nuclear power plant site.

Iluman IIcalth, impacts of Refurbishment Radiation exposures to the 1

SMALL COST. During refurbishment, the gaseous effluents would public result to doses well below the natural background dose. Applicable l

regulatory dose limits to the public are not expected to be exceeded.

Occupational radiation 1

SMALL COST. Avt.. age occupational doses from refurbishment are exposures expected to be within the range of annual average doses experienced for pressurized-water reactors and boiling water reactors. Upper.

l l

limit cancer and genetic risks from radiation exposure from the incremental doses from refurbishment are expected to be leas than 1% of the natural cancer and genetic risks.

Iluman Health, impacts of Operation During License Renewal Microbiological organisms 1

SMALL COST. Occupational health questions are expected to be (occupational health) resolved using industiial bygiene principles to minimize worker exposures.

L l

July 3,1991 A.11

f Microbiological organisms 2

SMALL COST Has not been found to be a problem at most

.(public health) operating plants and is not expected to be a problem during the license renewal term. At the time of license renewal of plants taing cooling ponds, lakes, or canals and plants discharging to small rivers applicants will assess the impact of thermophilie organisms on the health of recreational users of affected water.

Noise 1

SMALL COST. Has notbeen found to be a problem at operating plants and is not expected to be a problem at any reactor during the license renewal term.

Electromagnetic fields, 2

SMALL COST. Has not been found to be problem at most acute effects (electric operating plants and is not expected to be a problem during the shock)

License renewal term. If it cannot be found at the tbc of license renewal that the transmissian lines of the plant meets the National Electric Safety Code recommendations regarding the prevention of shock from induced currents then an assessment of the potential electric shock hazard from the transmission lines of the plant must be provided.

Electromagnetic fields, 1

SMALL COST. Biological and physical studies of 60-Hz chronic effects electromagnetic tields have not found consistent evidence linking harmful effects with field exposures.

- Ra&Aa ernosures to 1

SMALL COST. Present radiation doses to the public are very small public with respect to natural background radiation; and doses from refurbishment are expected to be similar in magnitudes.

Occupational r adiation 1

SMALL COST. Projected maximum occupational doses during the exposures license renewal term are within the range of doses experienced and are considerably below the 5 rem expo:ure limit.

July 3,1991 A-12 i

Socioeconomics Housing impacts of 2

ShiALL COST. Not expected to be a problem at any plant located refurbishment in a medium or high population area and not in an area where growth control menures that limit housing development are in effect. Housing impacts of the workforce associated with refurbishment will be assessed at the time oflicense renewal for plants located in sparsely populated areas or in aren with growth contro! measures that limit housing development.

Housing impacts of license 2

ShiALL COST. Not expected to be a prtiblem at any plant located renewal term in a medium or high population area and not in an area where growth control measures that limit housing development are in effect. Housing impacts of the workforce associated with refueling / maintenance outages will be assessed at the time of license renewal for plants located in sparsely populated areas or in areas with growth control measura that limit housing development.

Public senice impacts of 1

ShiALL COST. Refurbishment induced population growth will be refurbishment small and will not strain local infrastructure at any plant.

Transportation impacts of 3

Impacts are generally expected to be small, however, they must be refurbishment assessed for each plant to consider the increase in traflic associated with the additional workers and the local road and traffic control conditions.

Public senice (including 1

ShiALL COST. No significant impacts are expected during the transportation) impacts license renewal term.

during license renewal term Offsite land use impacts of ShiALL COST. Impacts will not be significant at any plant because refurbishment plant. induced population growth will have little effect on land use patterns.

Offsite land use impacts of 1

ShiALL COST. Changes in land use would be associated with I

license renewal term population and tax revenue changes resulting from license renewal of a plant. These changes are expected to be small for all plants.

July 3.1991 A 13 l

l l

I l

Historic resources irnpacts 1

ShtALL COST. No significant impacts are expected during of refurbishment refurbishment.

Historic resources impacts 1

ShiALL COST. No significant impacts are expected during the of license renewal term license renewal term.

(transmission lines)

Historic resources impacts 1

SMALL COST. No significant impacts are expected during the of license renewal term license renewal term.

(normal operations)

Aesthetic impacts of 1

ShiALL COST. No significant impacts are expected during refurbishment refurbishment.

Aesthetic impacts of 1

SAtALL COST. Impacts will be small to moderate depending on license renewal term the visualintrusiveness of the plant on historic and aesthet'c resources in the area.

Aesthetic impacts of 1

ShtALL COST. No significant impacts are expected during the license renewal term license renewal term.

(transmission lines)

Uranium Fuel Cycle Radiological and 1

ShiALL COST. Impacts on the U.S. population from radioactive nonradiological Impacts gaseous and liquid releases including radon ?22 and technetium-99 is small compared with the impacts of natural background radiation.

Nonradiological impacts on the environment are small.

Environmental Impr. cts of Postulated Accidents Design basis accidents 1

ShiALL COST. Regulations require that consequences from design basis events remain acceptable for every plant.

Severe Accidents 1

ShiALL COST. Risk from atmospheric releases is small.

(Atmospheric releases)

Severc Accidents 1

SMALL COST. Risks from both the drinking water pathway and (Fallout onto open bodies the aquatic food pathway are small and interdiction can further of water) reduce both sufficiently for all plants.

July 3,1991 A 14

t

.y gb h*

s, a

g' IMAGE EVAL.UATION A

/

\\

<d' TEST TARGET (MT-3) f _a. %.

r R,/I}'N 4,

ff 49 do 4>

y I.0 P

m im.m

,s l,l w:

L4 1.25 1.4 j!i6 g==

4 150mm 4

6" t

p e?

n,?

//g'b

~

O ge-V

,p

hA

-__.-4

-4.ma

- - - - ' - - ~ " - - ~ - ' - - - - - - " - - ~

1 3

y _ ;k 3e

^'

~'

i ?^

qf+.

//

9//,/

IMAGE EVALUATION O

't--fi

. g/"

TEST TARGET (MT-3)

/%

g////

t

(

~

gY/> gy,Y ki@3 g[,

l.O jIj l,l i--

p,ts Lm I.25 1.4 II i.6 w

- 150mm 4

g.,

/ Ierf

/ 4*g n

, y

,3,,/

+

n h

=;c w

&(i,3

=

e[ :1, O

ig IMAGE EVALUATION

/

\\//g/

^W TEST TARGET (MT-3) k/

'~

^

$f.4pf

'gg V+

g' I 1.0

-m m

22

=_

.' M 2.0 l,l ha LM i1.25

! l.4 I!!! i.6 l

l ee+: ki!

4 150mm 4

6" r

Ja y%

4 % /j4,%

9 e

gjpp,

,/4p'\\

ej e

by/,,,

+;y

  • r Severe Accidents 1

ShM11 COST. Interdiction and the low probability of base mat (Releases from penetration yield a low risk to the public for all plants, groundwater)

Severe Accidents 1

SMAll COST. Predicted costs due to postulated accidents range (Economic consequences) from $2000/ reactor year to $374,000/ reactor year.

Severe Accident Mitigation 1

SMALL COST. Low risk to the emironment from severe accidents.

Design Alternatives Solid Waste Management Nonradiological waste 1

SMAll COST, No changes to generating systems are anticipated for license renewal Existing regulations will casure proper handling and disposal at all plants.

Iow level radioettive waste 2

SMA11 COST. Impacts will be small for plants basieg access to storage offsite disposal space. For those plants denied the use of off site disposal space due to delayed compact plans, the potential for ecological habitat disturbance due to construction of on site storage facilities must be evaluated.

Low level radioactive waste 2

SMAll COST. Off site disposal facilities are planning to handle disposal refurbishment and normal operations waste streams for an additional 20 years. If implementation of plans is delayed, plants in affected cornpact regions or unaffdiated states must plan for extcoded interim storage for an indefinite period of time and evaluate the impacts of such storage.

Mixed waste 1

SMALL COST. License renewal will not increase the small, l-continuing risk to human health and the environment posed by I

mixed waste at all plants.

Spent fuel 1

SMAll COST. A 50% greater volume of spent fuel from an l

additional 20 yeacs of operation can be safely accommodated on-site with small environmental effects through dry or pool storage at all plants if a permanent repository or monitored retrievable storage facility is not available.

July 3,1901 A.15

~_

I Transportation 1

ShiALL COST, Rail and truck transport corridors can safely accommodate increased shipments of radioactive wastes associated l

with license renewal. Shipments would result in impacts within the scope of the Table S.4 rule and therefore would result in acceptable impact.

Decommissioning Radiation doses 1

ShiALL COST. Doses to the public are small regardless of which decommissioning method is used. Occupational doses would increase no more than 1 man rem due to buildup of long lived radionuclides during the license renewal term.

Waste management 1

ShiALL COST. Decommissioning at the end of a 20 year license renewal period would generate no more solid wastes than at the end of the current license term. No increase in the quant ties of Class C i

or greater than Class C wastes would be expected.

Air quality 1

ShiALL COST. Air quality impacts of decommissioning are expected to be negligible whether at the end of the current operating term or at the end of the license renewal term.

Water quality 1

ShiALL COST. The potential for significant water quality impacts from erosion or spills is no greater if decommissioning occurs after a 20 year license renewal period or after the original 40-year operadon period, and sneasures are readily available to avoid such impacts.

SMALL COST. Decommissioning after either the initial operating Ecological resources 1

period or after a 20 year license renewal period is not expected to have any direct ecological impacts.

Socioeconomic impacts 1

ShiALL COST. Decommissioning would have some short term socioeconomic impacts. The impacts would not be incrcased by delaying decommissioning until the end of a 20 year relicense period, but they might be decreased by population and economic growth.

I The numencal entnes in tha column are based on the folkmng category definesions July 3,1991 A 16

~

- Category 1:

A genene conclusion on the impact has been reached for all afleded nuclear poetr plants-

- Category 2.

A genene conclasson on the impact has been reached for effe41cd nuclear poetr plants that fall *1 thin defined bounds.

- Category 3 A genene concluson on the impact ns not vtached for any affected nuclear power plants.

2 The ftediep in this column apply to Category 1 issues and Catrgory 2 usves %en plants fall within the bounds of the genene analyus. For Part I of this tabi, the entry in ths column indicates the level of need For Pan 11 of this table, the t

entry la tha column indicates the relatm advantages of alternatus to beense renemit For Pan !!! of this tabk, the entnes in this column an benehts or ccsts, as indicated t y the folloming headinp-JM8dlimpacts art so minor that they mirrant neither detailed inwatigation or conuderapon of mitigitm actions uten such impacts are negatm.

MODFRAE impacu are hitely to be cleariy evident and usually mirrsnt considerauon of mitigation alternatma m' hen such impaeu are negaim.

lABOE impacu invotve either a severt penalty or a major benefit and matigation alternalma are almiys considered een such impacu are negsim.

The unctrumry associated with the economic crut of hanse nnemil leads to the requirement that a demonstrauon mill be made by an apphcant for heense renemil that then ss no cost advantage of replaecment of eqvmient generitmg capanry by a near coal fired postr plant If no such demonstration can be made, a jusu6 cation for chan6:ng the beense nnemil alternatm must be prended in the apphcation. The justificahon millinclude an asacasment of the etat of hetrue rtnetil rtlatm to reasonable alternatm replactment generating capactry. Cosu considered must include rtfurbishment and j

construction. fuct and oprauon and maintenance.

t l

l l

l July 3,1991 A 17