ML20133G859

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Summary of 961105 Meeting W/Util in Rockville,Md to Discuss Environmental License Renewal Program.List of Attendees & Matls Distributed During Meeting Encl
ML20133G859
Person / Time
Site: Calvert Cliffs  Constellation icon.png
Issue date: 01/14/1997
From: Scott Flanders
NRC (Affiliation Not Assigned)
To:
NRC (Affiliation Not Assigned)
References
NUDOCS 9701160191
Download: ML20133G859 (37)
v • d • e


Text

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Sb 'Sn aA y* 4 UNITED STATES g j NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555 0001

% January 14, 1997 ORGANIZATION: Baltimore Gas and Electric

SUBJECT:

SUMMARY

OF MEETING WITH BALTIM0RE GAS AND ELECTRIC COMPANY (BGE) ON BGE LICENSE RENEWAL ACTIVITIES On November 5,1996, the Nuclear Regulatory Commission (NRC) staff met with representatives of BGE in Rockville, Maryland, to discuss BGE's environmental license renewal program. A list of meeting attendees is provided in Attachment 1. Attachment 2 is a copy of the materials distributed during the meeting.

During the meeting, BGE discussed the background and status of its license renewal environmental report program, presented it's understanding of the Part  !

51 rule, and requested the staff's review of a BGE developed environmental report template.

BGE stated that it developed the environmental report program plan between 1992-1994. The program identifies environment-related requirements for license renewal and develops a plan for meeting those requirements. Some of i the major inputs to the environmental report plan included 10 CFR Part 51, the Generic Environmental Impact Statement (GEIS), environmental report program plan, the original environmental report and supplements, and the Maryland Department of Natural Resources Power Plant Research Program data and reports.

BGE discussed it's understanding of the Part 51 rule. BGE stated that it had some uncertainty as to the staff's expectations for a few issues and would like to open some dialogue with the staff on these issues independent of whether the staff agreed to review the BGE environmental report template.

These issues included Severe Accident Mitigation Design Alternatives (SAMDAs),

transportation, and Environmental Justice. The staff agreed to discuss these issues with BGE.

During the meeting, BGE presented a copy of the environmental template. BGE 4 discussed the format of the template. BGE acknowledged that the template

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9701160191 970114 DR ADOCK0500g7

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j Baltimore Gas and Electric Company January 14, 1997 i

presented at the meeting was for discussion purposes only. The staff stated

it would consider BGE's request and give a final answer at the upcoming NRC/

1 BGE management meeting.

i cott C. Flanders, Project Manager i

License Renewal Project Directorate Division of-Reactor Program Management

( Office of Nuclear Reactor Regulation 4

- Docket Nos. 50-317, 50-318 Attachments: 1. Attendance List

2. Meeting Handouts cc w/ attachments: See next page l

l l

Calvert Cliffs Nuclear Power Plant Baltimore Gas & Electric Company Unit Nos. I and 2 1

, cc: )

3 President Mr. Joseph H. Walter, Chief Engineer Calvert County Board of Public Service Commission of Commissioners Maryland i 175 Main Street Engineering Division Prince Frederick, Md 20678 6 St. Paul Centre Baltimore, MD 21202-6806 D. A. Brune, Esquire .

General Counsel Kristen A. Burger, Esquire Baltimore Gas and Electric Company Maryland People's Counsel  ;

P.O. Box 1475 6 St. Paul Centre Baltimore, MD 21203 Suite 2101 Baltimore, MD 21202-1631 Jay E. Silberg, Esquire Shaw, Pittman, Potts and Trowbridge Patricia T. Birnie, Esquire i 2300 N Street, NW Co-Director Washington, DC 20037 Maryland Safe Energy Coalition  !

P.O. Box 33111 Mr. Terrence J. Camilleri, Director, Baltimore, MD 21218 NRM Calvert Cliffs Nuclear Power Plant Mr. Robert E. Denton 1650 Calvert Cliffs Parkway Vice President - Nuclear Energy l Lusby, MD 20657-4702 Baltimore Gas and Electric Company Calvert Cliffs Nuclear Power Plant Resident Inspector 1650 Calvert Cliffs Parkway c/o U.S. Nuclear Regulatory Lusby, MD 20657-4702 Commission P.O. Box 287 Mr. Larry Bell St. Leonard, MD 20685 NRC Technical Training Center 5700 Brainerd Road Mr. Richard I. McLean Chattanooga, TN 37411-4017 Administrator - Radioecology Department of Natural Resources 580 Taylor Avenue Tawes State Office Building '

B3 Annapolis, MD 21401 Regional Administrator, Region I U.S. Nuclear Regulatory Commission 475 Allendale Road King of Prussia, PA 19406

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v Distribution:  !

Hard Copy.._ '

Central file /Docketlile -

PUBLIC

  • PDLR R/F MCase, 0-11 H21

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E-MAIL FMiraglia/AThadani (A) (FJM/ACT)

RZimmerman (RPZ)

TMartin (TTM)

DMatthews (DBM)

SNewberry (SFN)

SFlanders (SCF)

EJordan (JKR)

DCleary (DPC)

JMoulton (JPMI)

SHoffman (STH)

FAkstulewicz (FMA)

RJohnson (RJOHN)

PTKuo (PTK)

BPalla (RLP3)

BZalcman (BXZ)

CCraig (MC1)

RArchitzel (REA)

LDoerflein (LTD)

JSStewart (JCSI)

WDean (EMD)

JMitchell (JAM)

RCorreria (RPS)

RWessman (RHW)

SStrosnider (JRS2)

SDroggitis (SCD)

SPeterson (SRP)

Glainas (GCL)

TSpeis (TPS)

JMoore/EHoler GMizuno (GSM)

BSheron (BWS)

GBagchi (GXBl) 160034 I .

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. .= .. - . - . . - - _ _ - . .

ATTENDANCE LIST NRC MEETING WITH BALTIMORE EAS AND ELECTRIC NOVEMBER 5. 1996 NAME ORGANIZATION

1. Scott Flanders NRR/DRPM/PDLR  !
2. David Matthews NRR/DRPM/PGEB
3. Barth Doroshuk BGE
4. Julea Bradley Halliburton NUS j
5. Jon Cudworth Halliburton NUS l
6. Robert Tucker BGE
7. James Bennett -

BGE

8. David Lewis Shaw Pittman
9. Sandra Collins ERM, Inc.
10. Tricia Heroux for EPRI
11. Alice Carson Bechtel Power
12. Don Cleary NRR/RES/DRA
13. Kathryn Sutton Winston & Strawn
14. Rich McLean Maryland, DNR
15. John Moulton NRR/DRPM/PDLR l
16. Steve Hoffman NRR/DRPM/PDLR I
17. Robert Hill Duke Power
18. Bob Borsum B&WOG
19. Francis Akstulewicz NRR/PGEB ,
20. Richard E. Johnson NRR/RES/EMMEB l
21. P. T. Kuo NRR/PDLR l
22. William Burton Versar, Inc.
23. Bob Palla NRR/DSSA/SCSB
24. Barry Zalcman NRR/DRPM/PGEB
25. Claudia Craig NRC/NRR/PGEB
26. Ralph Architzel NRC/NRR/PGEB l

Attachment 1 l

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BGE Environm:ntal Lic::nco R:nswsl Prcgram

[M ute cycie u.n.sement unit ]

BGE Environmental License Renewal Program - Status Report Robert L. Tucker November 5,1996 Slide 1 Life Cycle Management Unit Purpose Of Presentation Discuss the background and status of BGE's Environmental License Renewal Program

. Present BGE's understanding of the final Part 51 requirements

= initiate discussions on several open items Attachment 2 Page 1

BGE Envircnm:ntal Licenso R:n:wnl Prsgram

[M ur.cyci.uanas m.ntunit ]

BGE Environmental Approach to  !

License Renewal n mnmen al Environmental Ufe Cycle Environmental RW Program Management Report Plan F Plan l

Three Phased Process Slide 3

[g ur. cyci. uanagement unit ]

BGE License Renewal Environmental Strategy l

- Build upon our 30 year relationship with the f environment l

- Ensure the license renewal evaluations are fully integrated with corporate environmental mission and with local, state, and regional issues l

- Be involved in 10 CFR 51 rulemaking l Six$e 4 Page 2

BGE Environm:ntsi Licen o R n:wn! Program I.-

)

Life cycle Management Unit Environmental Report Program Plan i

Developed over 1992-1994 time frame

  • Identifies environment-related requirements for 4

license renewal and plan for meeting thdse requirements.

- Milestones and externalinfluences

- Detailed task descriptions

- Program schedule

- Resource requirements i

Slide 5

(' g ute cycie Manag.m.nt unit ]

Environmental Life Cycle Management Plan Describes day-to-day environmental protection activities and relationship to license renewal. Discusses:

- Mission, policy, goals, and objectives

- Responsibilities

- Environmental activities

- Schedule and controls

- License renewalissues Sinde 6 Page 3

SGE Envir@nmental License Renewal Program

[M uf. cyci. u.n. .m.nt unit ]

Maior inputs - BGE License Renewal Environmental Report

  • Environmental Report Program Plan
  • Environmental Life Cycle Management Plan
  • Original License Environmental Report and supplements
  • Final Environmental impact Statement (FES) and supp!ements
  • Environmentalissue Matrix .
  • Tasked with ensuring that Maryland meets its electricity demands at reasonable costs while protecting the state's valuable natural resources
  • Conduct a range of research and monitoring projects addressing power plants (including Calvert Cliffs) impacts on the environment Participated in 10 CFR 51 rulemaking process Shde8 Page 4

BGE Environmsntal Lic:nto Rsngw 1 Progrcm l-l i

[M ur.cyci.u.n.

.nt unit ]

BGE's Draft License Renewal i ER Approach
Assembled core team of in-house expertise l . Contracted outside expertise (vendor)
  • Scheduled 1-year preparation

! = Tiered to FES (noted changes; environmental i effects)

Cross-referenced GEIS issues
Completed in 1995 Shde 9

[M ut. cyci. u.n. .m.nt unit ]

i BGE's Draft License Renewal ER i i

a Contained environmental input for license renewal i application to NRC. Discussed:

- Calvert Cliffs Plant site and plant systems

- Environmental effects of operation

- Followed format of existing guidance, Regulatory Guide 4.2

. Shde 10 Page 5

BGE Environm:ntal Lic:n:3 R:nsw.il Prcgram

[M ut. cyci. u.n.

m.nt unit ]

10 CFR 51 Final Rule '-

1 I

Shoe 11 1

[g tir. cyci. u.n.a.m.nt unit ]

issue Categorv Definitions Category 1: License renewalissues which NRC has resolved on a generic basis for all nuclear power plants and which an environmental report for the operating license renewal stage need not address

[10 CFR 51.53(c)(3)(1)]

Category 2: License renewal issues which NRC has determined must be resolved on a plant-specific basis and which an environmental report for the operating license renewal stage must address (10 CFR 51.53(c)(3)(li)]

NA: Not applicable (no categorization)

Shoe 12 Page 6

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BGE Environm:ntal Lic:nco R:nswal Prsgrcm i

[M ut.cyci.u.naa.m.nt unit ]

Final Rule issue Categories

  • 68 Category 1
  • 22 Category 2

- 5 not applicable to Calvert Cliffs by definition (e.g.,

cooling towers and ponds, Ranney wells)

- 17 applicable to Calvert Cliffs
  • 2 "NA"

- Electromagnetic fields chronic effects

- Environmentaljustice i

Shde 13 1

4

[g ur.cyci u.n.s.m.ntunit ]

Rule - ER Matchup

  • Rule-ER Cross Reference Table
  • Template for format and content Shde 14 Page 7

i 1.- ,

i BGE Environm5ntal Lic::nno Rcn w:1 Progrcm

i.  ;

i i

),

j Life Cycle Management Unit

! License Renewal ER Outline i 4

Summary 1.0 Purpose of and need for action 2.0 Altematives including proposed action j 3.0 Affected environment 4.0 Environmental consequences and mitigating actions 5.0 Compliance status References

]

, Appendices i

} Note: To expedore hRC usage of the ER. uurime a basedon ARC formatforpresentanon of

matenals m an ennronmental empact statement (10 CFR $1. *0(b) auf 10 CFR fl Subparr A.

AppenJte A. Secuen llajj Sixie 15 i

i Life Cycle Management Unit Rule - ER Cross Reference Table No., Jo CFR 51.53 Reauirement Environmental Reoort Action

5. (b) Environmental considerations. 62.1 would describe the proposed The environmental recort shall contain accon.

a description of the proposed action, S. a swoment M h purposes, Chapter 1 wou6d identify the purpose.

7. a deteripuon of the environment Chapter 3 describe the effected environment.
8. and discuss the following considersuons: H.1 would discuss environmental imp from W proposed N (1) The impact of the proposed action p.1.1 would adopt by reference, as on the environment impacts shall be appropriate, gel 3 conclusions for discussed in proportion to their Category 1 lasues.

s6gnificance; Shde 16 Page 8

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.. 1 BGE Environm::ntal License Renewal Program l

l l

[M uf cyciemanagementunit Chapter 4 - Environmental Consequences and Mitigating Actions

= Incorporate by reference Category 1 GEIS issues

  • Provide plant specific analysis of applicable Category 2 GEIS lasues
  • Will not address EMF [10 CFR 51 Subpart A, Appendix B, Table B-1, footnote 5)

- Address environmental Justice as necessary pending further g. idance Sigle 17 i

l Life Cycie Management Unit Applicable Categorv 2 issues

  • Entrainment . Public services - education
  • impingement (refurbishment)
  • Heat shock
  • Offsite land use a Groundwater use (refurbishment)
  • Refurbishment impacts
  • Offsite land use (license (terrestrial resources) renewal term)
  • Threatened & endangered
  • Public services, species transportation
  • Air quality during
  • Historic and refurbishment archaeological resources
  • Electric shock
  • Severe accidents
  • Housing
  • Transportation Public services - utilities Shoe 18 Page 9

1 BGE Environmental License Renewal Program

[M ufo cyci. u.n.gement unit ]

Applicable Category 2 issues I lasue: Entrainment of fish and shellfish in ear 1y life stages [10 CFR 61.63(c)(3)(ll)(B) and 10 CFR 61 Subpart A, Appendix B, Table B-1, issue No. 26]

Approach: Provide copy of CWA 316(b) determination '

Conclusion:

ER Section 4.1.2 Provide excerpt from 1982 NPDES permit regarding CWA 316(b) determination Shde 19

[g Life eycie man.gement unit ]

Applicable Categorv 2 Issues (Cont'd)

Issue.'

Impingement of fish and shellfish [10 CFR 61.63(c)(3)(II)(B) and 10 CFR 61 Subpart A, Appendix B Table B 1, issue No. 26]

Approach: Provide copy of CWA 316(b) determination

Conclusion:

ER Section 4.1.2 Provide excerpt from 1982 NPDES permit regarding CWA 316(b) determination Slee 20 Page 10

4 BGE Environmental License Renewal Program .

- I a

[M uf.cycie u.n.

ment unit ]

1

, Anolicable Cateaorv. 2 issue (Cont'd) l lesue: Heat shock [10 CFR 61.63(c)(3)(II)(B) and 10 CFR 61 Subpart A.

Appendix B, Table B-1, issue No. 27]

Approach: CWA 316(a) approval not required because Calvert Cliffs meets thermallimits I

Conclusion:

ER Section 4.1.2 - Provide excerpt from 1982 NPDES permit I regarding conformance with thermal limits Shoe 21 Lit. Cycle M.nagement Unit Applicable Categorv 2 issues (Cont'd) issue: Groundwater use conflicts (potable and service water)[10 CFR 61.63(c)(3)(ll)(C) and 10 CFR 61 Subpart A, Appendix B, Table B-1. Issue No. 33]

Approach: Current (1994) site boundary impact modeled at less than 1 foot per year License renewal 201 ear cumulative site boundary impact modeled at 1.1 feet MPPRP annual report Aquia aquifer groundwater levels in Calvert Cliffs area most strongly influenced by area municipal and Naval Air Station withdrawals

Conclusion:

ER Section 4.1.3 Impact will be identified and mitigation alternatives will be evaluated Shoe 22 Page 11

BGE Envir nmental Lic:nto R:nsw 1 Progrcm l l

M ufe cycie u.n.sement unit ]

Applicable categorv 2 issues (cont'd)

Issue: Refurbishment impacts (terrestrial impacts) [10 CFR 51.53(c)(3)(ll)(E) and 10 CFR 51 Subpart A, Appendix B Table B 1, issue No.40]

Approach: Refurbishment impacts would take place inside the plant Activities would not affect effluents l

Conclusion:

ER Section 4.1.4 -Impacts not expected

$hde 23 Life Cycle Management Unit Applicable Categorv 2 Issues (Cont'd)

Issue: Threatened and endangered species [10 CFR 51.53(c)(3)(li)(E) and 10 CFR 51 Subpart A, Appendix B Table B 1, issue No.49]

One species, shortnose sturgeon, documented as inhabiting gpp Chesapeake Bay Calvert Cliffs impingement studies (1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> per day,6 days per week since start of operation) have never collected species Will consult with U.S. Fish and Wildlife Service, National Marine Fisheries Service, and Maryland Natural Heritage Program prior to license renewal

Conclusion:

ER Section 4.1.5 Impact will be defined and mitigation alternatives will be evaluated Note: Consuttation would also address terrestrial species Slede 24 Page 12

BGE Environm ntal Lic nso R:ntwil Prcgram M ute cycie management unit ]

1 j

Applicable Categorv 2 issues (Cont'd)

Air quality during refurbishment (nonattainment and issue:

maintenance areas)[10 CFR 51.53(c)(3)(ll)(F) and 10 CFR 61 Subpart A, Appendix B, Table B 1, Issue No. 60) l 1

Approach: Identify Calvert Cliffs plant and area attainment status l Refurbishment activities would take place inside the plant i Activities would not affect effluents l

Project worker vehicle air impacts l 1

Conclusion:

ER Section 4.1.6. Impacts will be identified and mitigation attematives will be evaluated Shde 25 l

Life Cycle Management Unit Applicable Categorv 2 Issues (Cont'd)

Issue: Electromagnetic fields, ecute effects (electric shock) [10 CFR 61.63(c)(3)(ll)(H) and 10 CFR 51 Subpart A, Appendix B, Table B 1, issue No. 59]

Approach: Transmission lines meet GEIS criteria (designed to National Electrical Safety Code)

No increased voltage nor change in right of-way land usage since construction

Conclusion:

ER Section 4.1.7 - Demonstrate conformance with NESC Side 26 Page 13

BGE Environmental License Renewal Program j

Life Cycle Management Unit Applicable Categorv 2 issues (Cont'd) 1 issue: Housing impacts [10 CFR 61.53(c)(3)(li)(1) and 10 CFR 61 Subpart A, Appendix B, Table B-1, issue No. 83]

Approach: Describe the Tri-County (Calvert, St. Mary'e', and I Charies) housing market Calvert Cliffs is not in a " low population area" The Calvert Cliffs area has sustained growth since construction There are no growth control measures in place that limit housing development Conservative assumption of 120 additional workers ER Section 4.1.8 -Impact will be identified and

Conclusion:

mitigation attematives will be evaluated Shoe 27 Life Cycle Management Unit Apolicable Categorv 2 lssues (Cont'd)

Issue: Public services: public utilities [10 CFR 61.53(c)(3)(il)(1) and 10 CFR 51 Suboart A, Appendix B. Table B 1, Issue No. 65]

Approach: Discuss local supply water system's ability to meet current demand Maximum change in employment and population (assumed increase of 120 employees) due to license renewal estimated to be less than 1 percent of the projected growth for area

Conclusion:

ER Section 4.1.9 -Impact will be identified and mitigation altomatives will be evaluated Shoe 28 Page 14

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

BGE Environm ntal Licann R:nsw 1 Pr:grcm

[M ufe eycie uenagen..nt unit Anolicable Cateaorv. 2 issues (Cont'd)

~ 1 Public services, education (refurbishment) [10 CFR 1

issue: 51.63(c)(3)(ll)(l) and 10 CFR 61 Subpart A, Appendix B, Table B 1, issue No. 66] l l

, Approach: Describe local school system and enrollment istatus l l

Estimate incigrating workers required to meet refurbishment demands Project resultant increase in school enrollment I

)

Conclusion:

ER Section 4.1.10. impact will be identified and mitigation alternatives will be evaluated Shde 29 l

l

[g ufe cycie uanagement unit ]

Applicable Categorv 2 issues (Cont'd)

Issue: Offsite land use (refurbishment)[10 CFR 61.53(c)(3)(ll)(1) and 10 CFR 61 Subpart A, Appendix B, Table B-1, Issue No. 68]

Approach: FES Section ll.C discussed Calvert Cliffs regional land use increasing trend in decreasing agricultural land Area undergoing continual land use changes due to population growth Small number of workers to meet refurbishment demand is incidental to county population growth

Conclusion:

ER Section 4.1.6. impact will be identified and mitigation alternatives will be evaluated Shde 30 l

Page 15

BGE Environmental License Renewal Program Life Cycle Management Unit Aoplicable Categorv 2 issues (Cont'd)

Issue: Offsite land use (license renewal term) [10 CFR 51.53(c)(3)(II)(1) and 10 CFR 51 Subpart A, Appendix B. Table B-1, issue No. 69)

Approach: FES Section li.C discussed Calvert Cliffs regionalland use increasing trend of decreasing agriculturalland Area undergoing continualland use changes due to l population growth '

Small number of additionallicense renewal term workers (assumed to be 120) is incidental to county population growth

Conclusion:

ER Section 4.1.12 -Impact will be identified and mitigation attematives will be evaluated S4de 31 Life Cycle Management Unit Applicable Categorv 2 issues (Cont'd)

Public services, transportation [10 CFR 51.53(c)(3)(il)(J)

Issue: and 10 CFR 51 Subpart A, Appendix B, Table B 1, Issue No. 70)

Approach: Describe locallevel of transportation services increase in staff due to refurbishment is expected to be a very small percentage of normal operations and refueling outage staff numbers ER Section 4.1.13 Impact will be identified and

Conclusion:

mitigation attematives will be evaluated Shde 32 Page 16

I i

BGE Environmental License Renewal Program l l

Life Cycle Management Unit Applicable Categorv 2 issues (Cont'd) issue: Historic and archaeological resources [10 CFR 51.53(c)(3)(ll)(K) and 10 CFR 51 Subpart A, Appendix B, Table B-1, issue No. 71]

Approach: FES Sections ll.D and Xil.E preservation commitment met Archeological surveys (Scuth Circult)

Additional survey work done for South Circuit. No resources encountered during construction Will consult with State Historic Preservation Office

Conclusion:

ER Section 4.1.14 Would explain why no adverse impact i expected Shde 33 Life Cycle Management Unit Applicable Category 2 issues (Cont'd) issue: Severe accidents [10 CFR 51.53(c)(3)(ii)(L) and 10 CFR 51 Subpart A Appendix B, Table B-1, issue 76)

Approach: Calvert Cliffs IPE for intemally Initiated events submitted to NRC; preparing an IPE for extemal events Calvert Cliffs IPE Identifies seven plant improvements made to address plant specific vulnerabilities Base mitigation alternatives for intemally initiated events on completed Calvert Cliffs IPE. Base mitigation attematives for externally initiated events on a comparison of Calvert Cliffs t '

other plants with completed IPEEEs and by using NRC analysis for 1.imerick, Comanche Peak, and Watts Bar

Conclusion:

ER Section 4.1.15 - Mitigation attematives will be evaluated side 34 Page 17

(

BGE Environm:ntSI Lic:n:o R nsw 1 Progrcm Life Cycle Management Unit Applicable Categorv 21ssues (Cont'd) lasue: Transportation (uranium fuel cycle and waste management)

[10 CFR 51.53(c)(3)(ll)(M) and 10 CFR 61 Subpart A, Appendix B, Table B-1, issue No. 85]

Approach: Approach being developed Further guidance from NRC staff needed

Conclusion:

ER Section 4.1.16 To be determined Shde 35 l

l

[g ufe cycie uanagement unit ]

Uncategorized "NA" Issues a EMF - Chronic effects

- No discussion to be included in ER

- Environmental Justice

- Applicant's requirements are unclear

- Further guidance from NRC staff needed Shoe 36 Page 18

i BGE Environmental License Renewal Program

[M ur. cyci. u.n. .m.nt unit ]

Rule - ER Template Format follows outline presented earlier

  • Content for each section defined I
  • Regulatory requirement for each section cited i Shoe 37 1

Life Cycle M.n.gement Unit Rule - ER Template Example (Refer to Slide 16)

. Chapter 1

. Chapter 2, Section 2.1

. Chapter 3

. Chapter 4, Section 4.1 Shoe 38 Page 19

' 'J. BGE Environmtntal Lic:nza Ransw 1 Progrcm

[M ut. cycie maneo.m.nt unit ]

Need Will the BGE implementation of the 10 CFR Part 51 requirements meet NRC expectations for a license renewal ER?

- Further guidance on certain Category 3 issues (SAMDAs, Transportation)

- Expectations on "NA" issues (EMF, EnvironmentalJustice)

- Support of BGE format / content guidelines (Template, Cross Reference Table)

Slide 3's Page 20

RULE - ER CROSS REFERENCE TABLE Attachment L No. 10 CFR 51.53 Requirement Ensiro imental Report Action

1. (c) Operatmg hcense renewal stage. (1) Each apphcant for renewal of a license to operate a nuclear power plant il6E would submit 4I copies of the under part 54 of this chapter shall submit with its application the number of copies specified in { 51.55 of a separate " Applicant's Environmental Report-Operating document entitled " Applicant's Environmental Report-Operating License Renewal Stage." License Renewal Stage" to the Director of the

[$ 51.55 included below for case of reference] OfEce of Nuclear Reactor Regulation and g 51.55 Environmental report - number of copies; distribution would retain 109 copies pending written (a) Each applicant for a license to construct and operate a production or utilization facility covered by distribution instructions from the Director.

paragraphs (b)(1),(b)(2),(b)(3), or (b)(4) of f SI 20, cach aonlicant for renewal of an operatinc license for a nuclear oower olant_ each applicant for a license amendment authorizing the decommissioning of a production or utilization facility covered by Q 51.20, and each applicant for a license or license amendment to store spent fuel at a nuclear power plant after expiration of the operat ng license for the nuclear power plant shall submit to the Director of the OfEce of Nuclear Reactor Reculation or the Director of the OfEce of Nuclear Material Safety and Safeguards, as appropriate, 4 Lsepictsf aa.cns ironmental recort or supplement to an ens ironmental report. The applicant shall retain an additional 109 copies of the environmental rspon or any supplement to the environmental report for distnbution to parties and Boards in the NRC orgsgsdines: FederaLStaigad.Jegal ofEcialt and any afTected Indian tribes in aGEDrdance with written instructions issued by the Director of the OfEce of Nuclear Reactor Reculation or the Director of the OfEcc of Nuclear Material Safety and Safeguards, as appropriate. [ underlined highlights added for emphasis]

2. (2)lhe report must contam a descnption of the proposed action, mcludmg the apphcant's plans to modify the { 2.1 would desenbe the proposed action.

facihty or its administrative contml procedures as described in accordance with 5 54.21 of this chapter. This report { 2.1.6 would describe modifications.

must describe in detail the modifications directly affecting the environment or affecting plant emuents that afTect the environment.

3. In addition, the applicant shall discuss m this report the environmental impacts of alternatives j 2.2 would identify the No-Action Alternative, and { 4.2 would analyze the environmental impacts associated with feasible methods to meet the No-Action Alternative power demands.
4. and any other matters descnbed in Q 51.45. BGE would submit signed ongmal and copies

[f 51.45 included below for case of reference] as described above in item No.1.

9 51.45 Environmentai report.

(a) General. As reouired by (( 51.50,51.53,51.54 51.60,5161. 5162 or $168, as appropriate,_ cash apphcant or petitioner for a rulemaking shall submit with its anolication or petition for rulemaking one signed oricinal of a separate document entitled "Anohcant's" or " Petitioner's Environmental Reoort." as appropnate and the number of copies soecified in f f 51.55,5166, or 9 5169. An applicant or petitioner for rulemaking may submit a supplement to an environmental report at any time. [ underlined highlights added for emphasis]

5. (b) Enwronmentaleonsiderations. The environmental report shall contain a desenption of the proposed {2.1 would desenbe the proposed action.

action,

6. a statement ofits purposes. Chapter I would identify the purpose.
7. a descnption of the environment alTected. Chapter 3 desenbe the afTected environment.

1-1 1I/4/96

RULE - ER CROSS REFERENCE TABLE . continued.

N o. 10 CFR 51.53 Requirement Environmental Report Action

8. and discuss the following considerations: {4.1 would discuss environmental impacts from (I) The impact of the proposed action on the environment. Impacts shall be discussed in proportion to the propcsed action. {4.1.1 would adopt by their significance; reference, as appropriate, GEIS conclusions for Category I issues.
9. (2) Any adverse environmental effects which cannot be avoided should the proposal be implemented. {4.1 would discuss adverse effects. {4.3.1 would summarize unavoidable adverse impacts.
10. (3) Alternatives to the proposed action. The discussion ot' alternatives shall be sutliciently complete to {2.2 would discuss the No-Action Alternathe.

aid the Commission in developing and exploring, pursuant to section 102(2)(E) of NEPA, appropriate { 2.3 would present impacts from the proposed attematives to recommended courses of action in any proposal which invokes unresolved conflicts conceming action and the No-Action Altemative in attemative uses of available resources? To the extent practicable, the en ironmental impacts of the proposal comparative fashion and the alternatives should be presented in comparative form;

11. (4) The relationship between local short-term uses of man's environment and the maintenance and {4.4 would address short-term versus long-term enhancement of long-term productivity; and issues.
12. (5) Any arreversible and irretrievable commitments of resources uhich would be mvohed m the proposed {4.3.2 would address resource commitments.

action should it be implemented.

13. (c) Analysas. The environmental report shall include an analysis that considers and balances the Chapter 4 would be an analysis ofimpacts, environmental effects of the proposed action, the environmental impacts of alternatives to the proposed action, including mitigative alternatives. The chapter and attematives available for reducing or avoiding adverse environmental efTects. Except for environmental would not address economic, technical, and reports prepared at the license renewal stage pursuant to 51.53(c), the analysis in the environmental report other benefits and costs not related to the should also include consideration of the economic, technical, and other benefits and costs of the proposed environment except for mitigation. { 2.2 would action and of alternatives. Environmental reports prepared at the license renewal stage pursuant to { 51.53(c) use economic and technical factors in rejecting,  ;

need not discuss the economic or technical benefits and costs of either the proposed action or alternatives as unfeasible, attemathes from further analysis.

except insofar as such benefits and costs are either essential for a determination regarding the inclusion of an attemative in the range of alternatives considered or relevant to mitigation. In addition, environmental reports prepared pursuant to { 51.53(c) need not discuss other issues not related to the environmental effects of the proposed action and attematives. The analyses for environmental reports shall, to the fullest extent practicable, quantify the various factors considered. To the extent that there are important quahtative considerations or factors that cannot be quantified, those considerations or factors shall be discussed in qualitatis e terms. The environmental report should contain sufficient data to aid the Commission in its development of an independent analysis. .

I4. (d) Status ofcomphance. The environmental report shall list all Federal permits, licenses, approvals and other { 5.1 would include list of Federal and other entitlements which mus* be obtained in connection with the proposed action and shall describe the status of permits, etc , for the proposed action, and compliance with these requirements. Appendix 1 would provide agency approvals.

15. T he environmental report shall also mclude a discussion of the status of compliance with applicable { 5.1 would discuss comphance status of environmental quality standards and requirements including, but not limited to, applicable zoning and land-use proposed action, and Appendix II would regulations, and thermal and other water pollution limitations or requirements which have been imposed by provide the Maryland Water Quality Federal, State, regional, and local agencies having responsibility for environmental protection. Certification.

16 lhe discussion of alternatives in the report shall mclude a discussion of whether the alternatives will comply { 5.2 would discuss compliance of the no-action with such applicable environmental quality standards and requirements. alternative.

1-2 11/4/96

RULE - ER CROSS REFERENCE TABLE . continued.

No. 10 CFR 51.53 Requirement Environmental Report Action

17. (c) Adverse information The information submitted pursuant to paragraphs (b) through (d) of this section BGE would include adverse information, as should not be confined to information supporting the proposed action but should also include adverse applicable.

information.

18. 1he report is not required to include discussion of need for power or the economic costs and economic benefits of the lh ER would not discuss need for power.

proposed action or of alternatises to the proposed action except insofar as such costs and benefits are either essential Chapter 4 would discuss economic costs and for a determination regarding the inclusion of an alternative in the range of alternatives considered or relevant to economic benefits only in relation to mitigation.

mitigation. The environmental report need not discuss other issues not related to the environmental effects of the proposed action and the alternatives.

19. In addition, the environmental report need not discuss any aspect of the storage of spent fuel for the facil ty withm the The ER would not discuss spent fuel storage in scope of the generic determination in f S t.23(a) and in accordance with 6 51.23(b). the spent fuel pool or Independent Spent Fuel Storage Installation after the license renewal term.
20. (3) For those applicants seeking an imtial renewal license ano holding either an operatmg license or construction The ER would not contain analyses of Category permit as of June 30,1995, the environmental report shall include the information required in paragraph (c)(2) of this I issues unless, pursuant to 51.53(c)(3)(iv), new section subject to the following conditions and considerations: and significant information made an NRC GEIS (i) The environmental report for the operating license renewal stage is not required to contain analyses of the analysis inapplicable to CCNPP. Consistent environmental impacts of the license renewal issues identified as Category I issues in appendix B to subpart A of this with the regulatory preamble (61 FR 109, part. 6/5/96, pp 28467-28496, at p 28483), j 4.1.1 would adopt by reference NRC GEIS analyses (absent new and significant information).
21. (ii) The ensironmental report must contain analyses of the environmental impacts of the proposed action, Ihe ER would not include this analysis because including the impacts of refurbishment activities, if any, associated with license renewal and the impacts of operation CCNPP does not have cooling towers or during the renewal term, for those issues identified as Category 2 issues in appendix L1 to subpart A of this part. The cooling ponds. Appendix A would state this for required analyses are as follows: the underlying issues (13 and 34).

(A) If the applicant's plant utilizes coolingtowers or cocting ponds and withdraws make-up water from a river w hose annual flow rate is less than 3.15 x 10 ft'/ year (9 x 10' m'/ year), an assessment of the impact of the proposed action on the flow of the river and related impacts on instream and riparian ecological communities must be prosided.

The applicant shall also provide an assessment of the impacts of the withdrawal of water from the river on alluvial aquifers during low flow.

22. (B) If the applicant's plant utilizes once-through cooling or cooling pond heat dissipation systems, the applicant g 2.1.3 would descnbe the CCNPP heat shall provide a copy of current Clean Water Act 316(b) determinations and, if necessary, a 316(a) variance in dissipation system and Q 3.1 would describe accordance with 40 CFR part 125, or equivalent State permits and supporting documentation. If the applicant can not aquatic ecology; { 4.1.2 would provide CCNPP provide these documents, it shall assess the impact of the proposed action on fish and shellfish resources resulting 316(b) documentation and would document that from heat shock and impingement and entrainment. a 316(a) variance was not necessary for CCNPP. Appendix B and C would provide portions of the CCNPP 1982 discharge permit relative to 316(b) and 316(a), respectively.

1-3 1I/4/96

RULE - ER CROSS REFERENCE TABLE Attachment 1. continued.

No. 10 CFR 51.53 Requirement Environmental Report Action

23. (C)If the apphcant's plant uses Ranney wells or pumps more than 100 gallons of ground water per mmute, an Appendix A would state that, because CCNPP assessment of the impact of the proposed action on ground-water use must be provided does not use Ranney wells, the underlying issue (35)is not apphcable to CCNPP. 6 2.1.4 would demonstrate that CCNPP pumps more than 100 gallons of groundwater per minute, ) 3.2 would describe the pertinent geology and hydrogeology, and i 41.3 would assess impacts. Appendis D would proside well impact calculations _
24. (D)If the apphcant's plant is located at an miand site and utihics coolmg ponds, an assessment of the impact of the Appendix A would state that, because CCNPP proposed action on groundwater quahty must be provided does not utilize coohng ponds, the underlying issuc 09)is not appbcabic to CCNPP.
25. (E) All hcense renewal apphcants shall assess the impact of refurbishment and other hcense-renewal-related 9 4.1.4 would assess refurbishment impacts to construction activities on important plant and animal habitats. Additionally, the aoplicant shall assess the impact of terrestnal resources. { 3.3 would identify the proposed action on threatened or endangered species in accordance with the Endangered Species Act. special status species, f 4.1.5 would address impacts to special status species. and Appendix E would provide special status species consultations.
26. (F) If the apphcant's plant is located m or near a nonattamment or mamtenance area, an assessment of vehicle f 3.4 would desenbe air quahty of CCNPP area, exhaust emissions anticipated at the time of peak refurbishment workforce must be prosided in accordance with the and { 4.1.6 would address schicle exhaust Clean Air Act as amended. emissions.
27. (G) If the applicant's plant uses a cochng pond, take, or canal or discharges into a nver havmg an annual average Appendix A would state that, because CCNPP flow rate ofless than 3.15 x 10" ff/ year (9 x 10" m'/ year), an assessment of the impact of the proposed action on does not use a cooling pond, lake, or canal and public health from thermophilic organisms in the affected water must be provided. does not discharge into a river, the underlying issue (57) is not applicable to CCNPP.
28. (11)If the apphcant's transmission imes that were constructed for the specific purpose ct i.onnectmg the plant to { 2.1.5 would descnbe the CCNPP transmission the transmission system do not meet the recommendations of the National Electric Safety Code for presenting electric lines and conformance with the NESC, and i shock from induced currents, an assessment of the impact of the proposed action on the potential shock hazard from 4.1.7 would state that, due to NESC the transmission lines must be provided. conformance, the underlying issue (59) is not applicable to CCNPP.
29. (I) An assessment of the impact of the proposed action on housing avadabihty, land-use, and pubhc schools ( 3.5 would desenbe pubhc services. Q{ 41.8 (impacts from refurbishment activities only) within the vicinity of the plant must be provided. Additionally, the 4.1.10, and 4.1.9 would assess housing, schools, applicant shall provide an assessment of the impact of population increases attnbutable to the proposed project on the and water supply impacts, respectively. { 3.6 public water supply. would describe offsite land use and { $ 4.1.1I and 4.1.12 would assess refurbishment and i renewal-term impacts. respectively.
30. (J) All applicants shall assess the impact of the proposed project on local transportation durmg penods of hcense i 3.5 would descnbe local transportation, and t '

renewal refurbishment activities. 4.1.13 would assess impacts.

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RULE - ER CROSS REFERENCE TABLE . continued.

No. 10 CI'R 51.53 Requirement Environmental Report Action

31. (K) All apphcants shall assess whether any histonc or archaeological properties will be af fected by the proposed { 3.7 would desenbe CCNPP cultural resources, project. $ 4.1.14 would describe impacts, and Appendix F would provide cultural resources consultations.
32. (L)If the stafT has not previously considered severe accedent mitigation alternatnes for the apphcant's plant m an { 3 8 would provide demographic mformation, environmental impact statement or related supplement or in an ens ironmental assessment, a consideration of f 4.1.15 would discuss severe accident alternatives to mitigate severe accidents must be provided. mitigation alternatives, and Appendix G would provide detailed severe accident discussion.
33. (M) ~1he environmental effects of transportation of fuel and waste shall be reviewed m accordance with 9 51.52. Because CCNPP fuel ennchment is 5*. and l{ 51.52 included below for case of referencel aserage level ofirradiation for irradiated fuel g 51.52 Environmental effects of transportation of fuel and waste - Table S-4 can be up to 60,000 megawart-days per metne Every environmental report prepared for the construction permit stage of a hght-water-cooled nuclear ton. f 2.1.2 would desenbe CCNPP fuel power reactor, and submitted after February 4,1975, shall contain a statement concerning transportation of fuel enrichment and average level ofirradiation, and and radioactive wastes to and from the reactor. That statement shall indicate that the reactor and this i 4.1.16 would consider transportation impacts.

transportation either meet all of the conditions in paragraph (a) of this section or all of the conditions in paragraph (b) of this section.

(a)(I) The reactor has a core thermal power level not exceeding 3,800 megawatts, (2) The reactor fuel is in the form of sintered uranium dioxide pellets having a uranium-235 ennchment not exceeding 4% by weight, and the pellets are encapsulated in nrcaloy rods, (3) The average level ofirradiation of the irradiated fuel from the reactor does not esceed 33.000 megawatt-days per metric ton, and no irradiated fuel assembly is shipped until at least 90 days afler it is discharged from the reactor; (4) With the exception ofirradiated fuci, all radioactive waste shipped from the reactor is packaged and in a solid form; (5) unirradiated fuel is shipped to the reactor by truck; irradiated fuel is shipped from the reactor by truck, rail, or barge; and radioactive waste other than irradiated fuel is shipped from the reactor by truck or rail, and (6) The environmental impacts of transportation of fuel and waste to and from the reactor, w ith respect to normal conditions of transport and possible accidents in transport, are as set forth in Summary table S J in paragraph (c) of this section; and the values in the table represent the contribution of the transportation to the environmental costs of licensing the reactor.

(b) For reactors not meeting the conditions of paragraph (a) of this section, the statement shall contain a full description and detailed analyds of the ensironmental efTects of transportation of fuel and wastes to and from the reactor, including values for the environmental impact under normal conditions of transpert and for the ,

environmental risk from accidents in transport. The statement shall indicate that the values determined by the analysis represent the contribution of such effects to the environmental costs oflicensing the reactor.

1-5 1I/4/96

RULE- ER CROSS REFERENCETABLE Attachment 1. continued No, 10 CFR 51.53 Requirement Envicommental Report Action (c)

Summary Table S Environmental Impact of Transportation of Fuel and Waste to and from One Light-Water-Cooled Nuclear Power Reactor' Normal Conditions of Transport Environmental impact Heat (per irradiated fuel cask m transit) 250,000 litu/hr.

Weight (govemed by Federal or State restrictions). 73,000 lbs. per truck; 100 tons per cask per rail car Traffic density:

Truck Less than I per day Rail 12ss than 3 per month Exposed population Estimated number Range of doses to etposed Cumulauve does to etposed of persons etposed individuals'(per reactor population (per reactor year)'

year)

Transportatenworkers . 200 0 of to 300 millirem . 4 man-rem General public Onlookers 1,100 0.003 to 13 milliterc. _ 3 man-rem Along route 600.000 0 0001 to 0 06 millirem..

Accidents in Transport Environmental nsk Radelogical effects Small' Common (nonradiological) causes I fatal injury in 100 reactor years; I nonfatal injury in 10 reactor years: $475 property damage per reactor year

' Data supportmg this table are given in the Commisson's " Environmental Survey of Transponauon of Radioactsve Mawrials to and from Nuclear Power Plants " WASII-1238, December 1972, and Supp. I NUREG-75/038 April 1975.

Bath documents are availabic for inspection and copying at the Commission's Public Docurnent Room. 2120 L Street NW., Washington, DC and may be obtained from National Technical Information Service, Springfield, VA 22161.

WAsil-1238 is available from NTIS at a cost of15 45 (microfiche, $2.25) and NUREG-75/038 is available at a cost of

$3.25 (microfiche, $2.25).

'The Federal Radiation Council has recommended that the radiation doses from all sources of radiation other than natural background and medical exposures should be limited to 5,000 millirem per year for individuals as a result of occupational exposure and should be limited to 500 millirem per year for individuals in the general population. The dose to individuals due to average natural radiation is about 130 millirem per year.

' Man-rem is an expression for the summation of whole body doses to individuals in a group. Thus, if each member cf a population group of 1,000 people were to receive a dese of 0.001 rem (I millirem), or if 2 people were to receive a does of 0.5 rem (500 millirem), the total man-rem in each case would be I man-rem.

'Although the environmental risk of radiological effects stemming from transportation accidents is currently incapable of being numerically quantified, the risk remains small regardless of whether it is being applied to a single reactor or a multi-reactor site.

34. (iii) The report must contain a consideration of alternatives for reducing adverse impacts, as required by Chapter 4 would include consideration of f S t.45(c), for all Category 2 license renewalissues in Appendix B to Subpart A of this part. No such consideration is mitigation alternatives, required for Category I issues in Appendix B to Subpart A of this part.

[for text of 6 51.45(c), see item No.13, above]

35. (iv)'Ihe environmental report must contain any new and sigmficant information regarding the environmental Any new and significant information would be impacts oflicense renewal of which the applicant is aware. provided throughout the document as necessary.

1-6 1I/4/96

4 Template for the Calvert Cliffs Nuclear Power Plant License Renewal Environmental Report Introduction This template provides an outline of the Baltimore Gas and Electric Company (BGE) environmental report (ER) for ,

Calvert Cliffs Nuclear Power Plant (CCNPP) license renewal. The outline is annotated to describe the contents of l each section and to identify the regulatory requirement being addressed.

BGE has based the contents of the outline on U.S. Nuclear Regulatory Commission (NRC) regulatory requirements l found at Title 10, Code of Federal Regulations, Part 51, Section 53, Paragraph (c) Operating license renewal stage

[10 CFR S t.53(c)].' Attachment I provides cross-references from regulatory requirements to ER sections that the outline identifies.

Regulation 10 CFR 51.53 does not specify a format for an ER. Ilowever, NRC would use the ER as input when l preparing a CCNPP license renewal environmental impact statement in accordance with National Environmental Policy Act requirements. To expedite NRC usage of the ER, BGE has formatted it to follow NRC format for presentation of materials in an environmental impact statement.'

Environmental Report Annotated Outline Summary (format from 10 CFR 51.70(b) and 10 CFR 51 Subpart A, Appendix A, Section 3]

Summarize ER, stressing major issues; identify any unresolved issues; and present major conclusions and recommendations.

1. Purpose of and need for action [ required by 10 CFR 51.45(b) as incorporated by 10 CFR 51.53(c)(2)]

Describe the pumose of the proposed action as that of providing an option that allows for power generation capability beyond the tenn of the plant's current operating license to meet future system generating needs, as such needs may be determined by state, company, and federal decision makers (input from 61 FR 109, 6/5/96, p 28471.

2. Alternatives including the proposed action 2.1 Proposed action [ required by 10 CFR 51.53(c)(2) and 10 CFR 51.45(b) as referenced in 10 CFR 51.53(c)(2)]

{ 2.1 would provide enough information about CCNPP for reader to understand applicability of Q 4.1 issues and mitigation alternatives 2.1.1 General plant information 2.1.2 Nuclear fuel (input to ER $ 4.1.16) 2.1.3 Ileat dissipation system (input to ER (( 4.1.2) 2 Federal Register, Vol. 61, No.109, June 5,1996, pp 28467-28496; and Fedcral Register, Vol. 61, No.147, July 30,1996, pp 39555-39556.

' 10 CFR 51.70(b) and 10 CFR 51 Subpart A, Appendix A, Section 1(a),

templat1. doc 1 1I/4/96

\.

2.1.4 Groundwater use (input to ER i 4.1.3) 2.1.5 Transmission facilities (input to ER Q 4.1.7) 2.1.6 Modifications (required by 10 CFR 51.53(c)(2)](input to ER {Q 4.1.4,4.1.6,4.1.8,4.1.9,4.1.10, 4.1.11, and 4.1.13)

2.2 No-Action Alternative [ required by 10 CFR 51.53(c)(2)]

Under the No-Action Alternative, CCNPP would be decommissioned and an alternative power supply would be used to meet the demand for power. This section will present various power supply alternatives to meet the demand assonated with the No-Action Alternative. Feasible alternative will be determined, and the basis for concluding unreasonable will be provided. For each feasible. alternative, a general description would be provided with manpower estimates, emission discussion, description of cooling water system, delivery systems, and technology altematives within the alternatives.

1

?

2.3 Summary comparison Discuss differences in environmental impacts from proposed action and alternatives. Provide tabular comparison between proposed action and alternatives for each Category 2 issue applicable to CCNPP and any other Category 2 or I issue applicable to an alternative (s) for which impact is moderate or large.

3. Affected envimnment Provide enough information to support { 4.1 analyses of Category 2 issues and any new and significant information,if any.

3.1 Aquatic ecology (input to ER Q 4.1;2) 3.2 Geology and groundwater hydrology (input to ER @ 4.1.3) 3.3 Biological resources (input to ER (( 4.1.4 and 4.1.5) 3.4 Air quality (input to ER { 4.1.6) 3.5 Public sen ices (input to ER {[ 4.1.8,4.1.9,4.1.10, and 4.1.13) 3.6 Offsite land use (input to ER (( 4.1.11 and 4.1.12) 3.7 Cultural resources (input to ER l 4.1.14) 3.8 Demography (input to ER QQ 4.1.15 )

4. Environmental consequences and mitigating actions 4.1 Proposed action For each issue discussed in Q{ 4.1.2 through 4.1.16, start discussion with statement ofissue; identify and discuss alternative mitigation measures; and identify whether impact, after intended mitigation, is small, moderate, or large, as defined below (10 CFR 51 Subpart A, Appendix B, Table B-1, footnote 3):

Small- for the issue, environmental effects are not detectable or are so minor that they will neither destabilize nor noticeably alter any important attribute of the resource templat1. doc 2 11/4/96

l l

/

l Moderate- for the issue, environmental effects are sufficient to alter noticeably, but not to l destabilize, important attributes of the resource 1

Large- for the issue, environmental effects are clearly noticeable and are sufficient to destabilire important attributes of the resource 4.1.1 Introduction  !

l I

Adopt by reference NRC GEIS conclusions for Category 1 issues. Indicate the Category 2 issues that are not applicable to CCNPP and provide basis for conclusion. Reference Appendix A for identification of ER sections that address specific Category 2 issues.

4.1.2 Aquatic ecology [ required by 10 CFR 51.53(c)(3XiiXB); Table B-1 issue Numbers 25,26, and 27]

Describe 316 (b) requirement and the history of CCNPP compliance (reference documentation in ,

Appendix B). Describe 316 (a) requirement and inapplicability to CCNPP because thermal variance )

is not needed. In Appendix C, provide pages from the 1982 CCNPP discharge permit to document l comphance. l l

1 l

4.1.3 Groundwater use [ required by 10 CFR 51.53(cX3XiiXC); Table B-1 Issue Number 33] '

4.1.4 Refurbishment impacts (to terrestrial resources) [ required by 10 CFR 51.53(cX3)(iiXE); Table B-1 1ssue 40]

4.1.5 Threatened and endangered species (required by 10 CFR 51.53(c)(3)(ii)(E); Table B-1 issue 49]

4.1.6 Air quality during refurbishment (nonattainment and maintenance areas) [ required by 10 CFR 51.53(c)(3)(ii)(F); Table B-1 issue 50]

4.1.7 Electric shock [ required by 10 CFR 51.53(cX3)(iiXH); Table B-11ssue 59]

4.1.8 Housing impacts [ required by 10 CFR S t.53(c)(3Xii)(1); Table B-1 Issue 63]

4.1.9 Public services: public utilities [ required by 10 CFR 51.53(c)(3Xii)(I); Table B-11ssue 65]

4.1.10 Public services, education (refurbishment) [ required by 10 CFR 51.53(c)(3)(ii)(1); Table B-1 Issue 66]

4.1.11 Offsite land use (refurbishment) [ required by 10 CFR 51.53(c)(3)(iiXI); Table B-1 Issue 68]

4.1.12 Offsite land use (license renewal term) [ required by 10 CFR 51.53(c)(3 Xii)(1); Table B-1 1ssue 69]

j 4.1.13 Public services, transportation [ required by 10 CFR 51.53(c)(3XiiXJ); Table B-1 issue 70]

i 4.1.14 Historic and archaeological resources [ required by 10 CFR 51.53(c)(3)(ii)(K); Table B-11ssue 71]

l l

4.1.15 Severe accident mitigation alternatives [ required by 10 CFR 51.53(c)(3Xii)(L); Table B-1 issue

, 76]

l l templat t. doc 3 11/4/96

1 I. ,

i 1

4.1.16 Transportation [ uranium fuel cycle and waste management] [ required by 10 CFR 51.53(cX3Xii)(M); Table B-1 Issue 85] ,

I i

4.2 No-Action Altemative [ required by 10 CFR 51.53(c)(2) and 51.53(cX3Xiii)]

l For each of the feasible ways to meet the power demands of the No-Action Altemative (ER 6 2.2), discuss significant issues addressed in 6 4.1 plus any other applicable Category 2 or 1 issue for which impact would l be moderate or large and address mitigative attematives. Provide enough detail that NRC can determine whether or not environmental impacts oflicense renewal are so great, compared to the No-Action Alternatives, that preserving the option oflicense renewal for future decision makers would be unreasonable 1

- I

[10 CFR S t.95(cX4)].

. l 4.3 Committed resources 4.3.1 Unavoidable adverse impacts [ required by 10 CFR Sl.45(b)(2) as referenced in 10 CFR 51.53(c)(2)]

Summarize adverse impacts that j 4.1 identifies for the proposed action (i.e., license renewal) as unavoidable after minimization by mitigative measures (e.g., impingement mortalities). l 1

4.3.2 Irreversible or irretrievable resource commitments [ required by 10 CFR 51.45 (bX5) as referenced in 10 CFR SI.53(c)(2)]

Identify subset of f 4.3.1 impacts that are permanent or of such long-term impact as to be considered relatively permanent. Identify assumption that long-term is longer than license renewal period.

4.4 Short-term use versus long-term productivity [ required by 10 CFR 51.45 (b)(4) as referenced in 10 CFR 51.53(c)(2)]

Describe GEIS Category 1 impacts and Section 4.2 Category 2 impacts, as applied to renewing the CCNPP license, local short-term uses of man's environment (or identify any that are not short-term). Identify any ways that these short term uses affect the maintenance and enhancement oflong-term productivity of man's environment.

5. Compliance status [ required by 10 CFR 51.45(d) as referer.ced in 10 CFR S t.53(c)(2)]

5.1 Proposed action List approvals Federally required for license renewal and identify compliance status. Discuss status of compliance with Federal, State, and local environmental protection requirements. Identify any unresolved enforcement actions.

5.2 No-Action Alternative identify whether the no-action alternative would comply with Federal, State, and local enviromnental protection requirements.

6. References templat1. doc 4 11/4/96

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Appendix A Category 2 Issues Appendix B 316(b) documentation I

Appendix C 316(a) documentation Appendix D Offsite wellimpact calculation 1

Appendix E Special status species consultation i Appendix F Cultural resources consultation Appendix G Severe accidents Appendix 11 Water quality certification Appendix 1 Other approvals l

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templatl. doc 5 11/4/96

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t Baltimore Gas and Electric Company January 14, 1997 presented at the meeting was for discussion purposes only. The staff stated it would consider BGE's request and give a final answer at the upcoming NRC/

BGE management meeting.

Original signed by:

, ' Scott C. Flanders, Project Manager License Renewal Project Directorate Division of Reactor Program Management Office of Nuclear Reactor Regulation Docket Nos. 50-317, 50-318 Attachments: 1. Attendance List- .

2. Meeting Handouts cc w/ attachments: Distribution (see next page)

See next page .

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