ML20137E350

Summary of 970307 Meeting W/Bge in Rockville MD to Provide Comments on License Renewal Er Template Proposed by Util. List of Meeting Participants Encl

ML20137E350
Person / Time
Site:	Calvert Cliffs
Issue date:	03/24/1997
From:	Craig C NRC (Affiliation Not Assigned)
To:	Matthews D NRC (Affiliation Not Assigned)
References
NUDOCS 9703270162
Download: ML20137E350 (15)

Text

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k p- UNITED STATES j

g NUCLEAR REGULATORY COMMISSION t WASHINGTON, D.C. 20086-4001 J

• • • • • [ March 24, 1997:  ;

i MEMORANDUM TO: David B. Matthews, Chief 1 Generic Issues and Environmental t Projects-Branch .

Division of Reactor Program Management .5 Office of Nuclear Reactor Regulation )

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FROM:. Claudia M. Craig, Senior' Project Manager Generic Issues and Environmental d G. .Mi j Projects Branch 1 Division of Reactor Program Management

Office of Nuclear Reactor Regulation ~ l

SUMMARY

OF MEETING WITH BALTIMORE GAS & ELECTRIC (BGE) TO

DISCUSS LICENSE RENEWAL ENVIRONMENTAL REPORT (ER) TEMPLATE i l PROCESS j l

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The subject meeting was held at the Nuclear Regulatory Commission (NRC)

! offices.in Rockville, Maryland on March 7,1997, between representatives of ,

BGE and the NRC staff. The purpose of the meeting was to provide BGE with NRC  !

l staff comments on the license renewal ER template proposed by BGE. ,

{ Attachment 1 is a list of meeting participants.

. BGE proposed the ER template process in order to develop a format and content

guide for the ER to be submitted in support of a license renewal application.

i Existing NRC guidance is currently being updated to reflect the revised

. 10 CFR Part 51, which includes the environmental requirements of a license renewal application. BGE anticipates completing their ER prior.to final j guidance being issued by the Commissiun, thus, the effort on the template to i determine an acceptable format and content. It is the staff and BGE's-i objective that the completed environmental report template outline a format  ;

and content such that if an ER 'is submitted which follows the template and contains sufficient information, it is likely the report would be accepted for review, s

The staff provided BGE with their preliminary comments on the template based j i on knowledge at this time. See Attachment 2. Da each of the staff comments, -

l the comment was discussed such that BGE understood the staff's issue. BGE  ;

i will review the NRC comments and provide a revised template and/or written i responses to the comments at the next meeting. Several issues were discussed which need further clarification either from BGE or the staff. These include:

whether formal .NRC legal review of the template will occur before completion of the project, whether mitigation measures need to be evaluated if a i Category 2 issue has been determined to have insignificant impacts, whether q7 9703270162 970324 PDR ADOCK 05000317 ME CBHM.sO P PDR i

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D. Matthews March 24, 1997

there is an inconsistency between the GEIS and the rule regarding evaluation 1

- of the impacts of transportation both during the refurbishment term and the license renewal term, how the GEIS will be referenced by BGE, and how new and i significant information will be identified.

j The staff also provided preliminary comments on the four specific issues BGE '

! requested additional information on. These include electric shock, severe-accident mitigation design alternatives (SAMDAs), environmental justice (EJ),

and the impacts associated with transportation in the vicinity of a high-level waste repository site. BGE will review the staff comments and then propose a course of action. A separate meeting may be scheduled in the near future to i

discuss the technical details of SAMDAs. Other issues discussed include: how l to submit the information for EJ, the scope of issues-that need to be addressed in EJ, and whether alternatives and alternate generating facilities need to be examined under EJ. Further discussion on the transportation issue i was deferred at this time until the staff has more information and guidance, q

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The schedule for the regulatory guide and environmental standard review plan was' discussed as well as the possibility of submitting the application and l supporting information in electronic form. The staff committed to get back to BGE regarding the selection of examples. Examples will be reviewed to ensure an appropriate level of detail is included in the ER and will not be reviewed for technical merit.- The agreed upon schedule remains valid with the next

! interaction occurring in early April 1997, when BGE will provide an updated template, responses to NRC comments, and detailed examples. The representatives agreed to set a date for the senior management meeting to i discuss-the template effort at higher levels of management.

Docket Nos. 50-317, 50-318 Attachments: As stated

.cc w/atts: See next page l

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BGE / NRC MEETING -

) ENVIRONMENTAL REPORT TEMPLATE PROCESS MARCH 7, 1997 i

MEETING PARTICIPANTS t

88ME ORGANIZATION

! Claudia Craig NRC/NRR/PGEB Ralph Architzel NRC/NRR/PGEB

Jon Cudworth Halliburton NUS ,

Robert Tucker BGE i

David Lewis Shaw Pittman i

! J.V. Ramsdell PNNL

. Tricia Heroux for EPRI Bob Borsum for Duke Power j Scott Flanders NRC/NRR/PDLR l Barry Zaleman NRC/NRR/PGEB Jim Wilson NRC/NRR/PGEB Barth W. Doroshuk BGE i

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ATTACHMENT 1

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. GENERAL. COMMENTS / QUESTIONS ON TEMPLATE

• Preliminary comments - reaction to template based on current knowledge and possible staff positions

• Section 2.1.1, second bullet "Use table to list post-FES NEPA documentation" - does this mean post-NEPA legislation / rules that have been passed or documentation specific to CCNPP with regard to post-NEPA requirements?

• Section 2.2 - Alternatives Scope of alternatives review is in Chapter 8 of GEIS and 61 FR 28483 and should include: 1) environmental impacts of termination of operation and decommissioning CCNPP, 2) construction of feasible alternative generating capacity to replace CCNPP, 3) power imports, 4) additional energy conservation measures in the service area (demand-side management and conservation), 5) mix of the above alternatives.

BGE should consider State planning documents, how BGE will fit into the future energy picture in Maryland, and any interactions with the State as a starting point for the list of alternatives.

• Section 2.3 What is the purpose of putting the summary comparison of environmental impacts here rather than under 4.2 where the impacts are identified and evaluated?

• Sections 3'and 4 - Does BGE plan to include in the ER the type of information similar to that in RG 4.2 for the details of Sections 3 and 47 (the words " describe" lack level of detail)

• Section 3.1 Does BGE plan to only describe environment if affected by proposed action or describe it and then say it is not affected?

• Section 4.1 Need to address environmental impacts from the proposed action - then look at alternatives and at the impact after mitigation - (Issue, identify impact, discuss alternative mitigation measures, identify after mitigation what impact is)

• Section 4.1.1 How does BGE plan to adopt by reference NRC GEIS conclusion for Category 1 issues? How does BGE ensure GEIS applies to CCNPP?

Affirmation statement? Any systematic effort to become aware of any new and significant information should be explained briefly in the ER, but the analyses need not be included. New information is any factor resulting in an environmental impact which either was not considered in the GEIS or the magnitude exceeds that described in the GEIS.

Significant information must be shown to change the findings for a Category 1 issue to cause a substantial environmer9' impact that is not identified in the GEIS.

ATTACHMENT 2

The'ER should present a sufficiently broad picture of refurbishment and operating activities / changes to allow the NRC reviewers (and the public) to make the judgement that it is unlikely that there is new and significant information not reported in the ER that may bring any Category 1 GEIS finding into question.

• Section 4.1.7, Threatened and Endangered Species Need to look at both refurbishment period and continued operation - both Category 2 (see Table B-1 and see pages 3-48, 3-51 and 4-122 of GEIS)

Does BGE have an environmental protection plan? What is the status, any need to update?

• Section 4.1.15 Only addresses public services, transportation during refurbishment term

- what about impacts of operation during renewal term? See pg 4-106 of GEIS.

• Section 4.2 Explain what is meant by " reference applicable discussion" (first bullet) and " provide sufficient detail" (third bullet). Again, starting point should be State studies and interaction

• Appendix A, second bullet - for each issue, identify where in the ER the issue is discussed - are there plans to address each issue in the ER or only the Category 2s?

How are past commitments in the environmental arena addressed (will anything in license renewal cause the commitment to change)?

From Table B does BGE need to address:

Water use conflicts?

Ground water degradation - cooling ponds?

Microbiological organisms i

SPECIFIC BGE ISSUES

• ELECTRIC SH0CK ILI:

Two options: 1) proposed action of license renewal has no impact on the potential shock hazard, line will remain energized regardless of license renewal - no demonstration of NESC compliance is needed, 2) include NESC compliance.

Reouirements:

10 CFR 51.53(c)(3)(ii): I "The environmental report must contain analyses of the environmental impacts of the proposed action, including the impacts of refurbishment activities, if any, associated with license renewal and the impacts of operation during the renewal term, for those issues identified as i Category 2 issues in Appendix B to subpart A of this part. The required '

analyses are as follows:

10 CFR 51.53(c)(3)(ii)(H):

"If the applicant's transmission lines that were constructed for the specific purpose of connecting the plant to the transmission system do l not meet the recommendations of the National Electric Safety Code for l

preventing electric shock from induced currents, an assessment of the I impact of the proposed action on the potential shock hazard from the  ;

transmission lines must be provided."

Table B-1: i

" Electrical shock resulting from direct access to energized conductors l or from induced charges in metallic structure have not been found to be l a problem at most operating plants and generally are not expected to be a problem during the license renewal term. However, site-specific review is required to determine the significance of the electric shock potential at the site."

GEIS:

Three points: 1) i' a of electrical shock not addressed during original licensing, 2] operating licenses issued with a stated transmission line v at age that may have been upgraded over time, l possibly without an R , sis, 3) possible land use changes.

Electrical shock issue is of small significance for plants operated in adherence with National Electric Safety Code (NESC).

Without review of each plant to determine conformance with NESC, impossible to determine potential impact of sign;ficance of electric shock.

NRC Comment:

BGE is expected to comply with 10 CFR 51.53(c)(3)(ii)(H) and perform an assessment of the impact on the proposed action on the potential shock hazard if their lines do not meet the NESC.

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i One possible approach may be:

1) confirm that transmission line was designed and routed using NESC standards in existence at time of construction, 2) identify and assess the significance of any differences between old standards-and those in existence now, 3) if there are any significant differences, identify location of any human activity within or at the border of the right of ,

way that may be subject.to shock hazard, 4) if locations are identified, '

assess what mitigative actions are warranted.

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SEVERE ACCIDENT MITIGATION DESIGN ALTERNATIVES ILQE:

Three options: 1) follow approach used for Limerick, 2) follow Limerick approach except do not evaluate externally initiated events qualitatively, 3) perform a bounding analysis that demonstrates CCNPP falls within Limerick and Comanche Peak analyses.

Reauirements:

10 CFR 51.53(c)(3)(ii)(L):

"If the staff has not previously considered severe accident mitigation alternatives for the applicant's plant in an environmental impact statement or relatod supplement or in an environmental as'sessment, a consideration of alternatives to mitigate severe accidents must be provided."

Table B-1:

"The probability weighted consequences of atmospheric releases, fallout onto open bodies of water, releases to graund water, and societal and economic impacts from sever? accidents at e small for all plants.

However, alternatives to mitigate severo accidents must be considered for all plants that have not co'esidered such alternatives."

GEIS:

Site-specific consiferation of alternatives to mitigate severe accidents shall be performed 'or license renewal unless it has already been included in an EIS or EA.

NRC Comment:

BGE needs to perform a site-specific analysis.

1 Explain what BGE means by " qualitatively treat externally-initiated events".

When does BGE expect to complete IPEEE7 Will this be before an LR l application is submitted?

i Is the Calvert Cliffs IPE a Level 37 If not, will need to extend the l analysis to include an assessment of source terms and consequences (see the approach taken for Watts Bar) l l

SAMDA analysis should: 1) determine risk estimates, 2) describe process ;

for identifying potential design improvements, 3) determine the cost -

impacts of potential design improvements, 4) perform a cost-benefit comparison Staff needs to understand the process used to derive the list of potential improvements.

Review Watts Bar SAMDA analysis - that is the most recent and reflects current staff thinking.

BGE can look at SAMDAs for other plants aftar to compare with CCNPP I list.  !

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The $2000/ person-rem value should be used as a screening tool rather than an absolute go/no-go. An engineering assessment should be performed for any SAMDA that results in a $/ person-rem value within a factor of 5-10 of this.

Note that the $2000 per averted person-rem is for human health effects only - need to account for other costs including adverse impact on both off-site property and on-site property.

Following completion of IPEEE, the follow-on assessment of external events should not only strive to identify additional SAMDAs oriented towards preventing / mitigating core damage from external events. Rather once the IPEEE is completed, the value-impact for all SAMDAs (including those originally identified for internal events, as well as those oriented to external events) should be reassessed considering the combined risk reduction from both internal and external events. (Those SAMDAs which provide risk reduction may come closer to being cost beneficial when the full risk reduction- from both internal and external events - is weighed against the costs).

See " Regulatory Analysis Technical Evaluation Handbook", January 1997.

SAMDA analysis should follow the analysis used in NUREG

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• ' TRANSPORTATION E1:

Compare environmental effects to Table S-4 Defer generic and cumulative transportation impacts until DOE issues its EIS for HLW repository.

Reauirements:

10 CFR 51.53(C)(3)(ii)(M):

"The environmental effects of transportation of fuel and waste shall be reviewed in accordance with 10 CFR 51.52. The-review of impacts shall' also discuss the generic and cumulative impacts. associated with j transportation operation in the vicinity of a high-level waste 1 repository site. The candidate site at Yucca Mountain should be used i for the purpose of impact analysis as long as that site is under j consideration for licensing." 1 Table B-1:

" Table S-4 of this Part contains an assessment of impact parameters to be used in evaluating transportation effects in each case."

10 CFR 51.52:

Every ER shall contain a statement concerning transportation of fuel and waste to and from the reactor. The statement shall indicate whether the reactor and transportation meets all the conditions of paragraph (a) or all the conditions in paragraph (b).

(a) core thermal power level not exceeding 3,800 megawatts, uranium-235 enrichment does not exceed 4% by weight and pellets encapsulated in zircaloy, level of irradiation does not exceed 33,000 megawatt-days per metric ton and irradiated fuel is shipped at least 90 days after it is discharged, all radioactive waste shipped is packaged and in solid form, unirradiated fuel is shipped by truck, irradiated fuel shipped by truck, rail or barge, radioactive waste shipped by truck or rail, environmental impacts of transportation are set forth in Table S-4.

(b) For reactors that don't meet (a) the. ER shall contain a full description and detailed analysis of environmental effects of the transportation of fuel and wastes.

EA and Finding of No Significant Impact for. Extended Burnup Fuel: I Staff concluded that the environmental impacts in Table S-3 and' S-4 for l' a burnup level of 33 Gwd/MtU are conservative and bound the corresponding impacts for burnup level up to a maximum rod average burnup level of 60 Gwd/MtU and uranium-235 enrichments up to 5 percent by weight.  !

EA for BGE'for proposed amendment to increase maximum U-235 enrichment I to 5% by weight-and batch average discharge burnup limit of 60,000 i MWD /MT.

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GEIS:

i The radiological and nonradiological environmental impacts from the i transportation of fuel and waste attributable to license renewal . a

power reactor have been reviewed. However, because a detailed analysis of the environmental impacts of transportation to the proposed repository at Yucca Mountain is not yet available, transportation of fuel and waste is Category 2.

NRC Comment:

4 At.this time, defer this issue.

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ENVIRONMENTAL JUSTICE j BEE- .

I Need identification of input reeded.  !

Reauirements:

Table B-1 "The need for and the content of an analysis of environmental justice  !

will be addressed in plant-specific reviews." l Footnote: EJ was not addressed in the GEIS because guidance was not av&ilable. This issue will be addressed in individual license renewal reviads.

NRC Comment:

Follow NRR staff interim guidance contained in OL 906. ,

l Include 3 steps: i

1) from census data, identify low income and minority populations,

2) identify those issues that may have significant environmental impacts on the population of interest, 3) determine which issues will have moderate or large impacts and assess what mitigation alternatives are available.

Provide description of systematic process used to consider potential significance of full range of environmental issues.

Applicant should work with local officials and communities if they  !

identify low income or minority populations. .

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D. Matthews -2_ March 24, 1997 there is an inconsistency between the GEIS and the rule regarding evaluation i of the impacts of transportation both during the refurbishment term and the l license ' renewal- term, how the GEIS will be referenced by BGE, and how new and 2

significant information will be identified.

j The staff also provided preliminary comments on the four specific issues BGE l

requested additional information on. These include electric shock, severe 1 accident mitigation design alternatives (SAMDAs), environmental justice (EJ),

i and-the impacts associated with transportation in the vicinity of a high-level  ;

waste repository site. BGE will review the staff comments and then propose a  !

j course of action. A separate meeting may be scheduled in the near future to  ;

discuss the technical details of SAMDAs. Other issues discussed include: how 4

-to submit the information for EJ, the scope of issues that need to be j i addressed in EJ, and whether alternatives and alternate generating facilities 1 need to be examined under EJ. Further discussion on the transportation issue l

was deferred at this time untti the staff has more information and guidance. ~

I The schedule for the regulatory guide and environmental standard review plan  !

was discussed as well as the possibility of, submitting the application and i supporting information.in electronic form. The staff committed to get back to l BGE regarding the~ selection of examples. Examples will be reviewed to ensure  !

an appropriate level of detail is included in the ER and will not be reviewed i

for technical merit. The agreed upon schedule remains valid with the next interaction occurring in early April 1997, when BGE will provide an updated

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template, responses to NRC comments, and detailed examples. The representatives agreed to set a date for the senior management meeting to l discuss the template effort at higher levels of management.

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! Docket Nos. 50-317, 50-318 Attachments: As stated l

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NAME CCraigiW" RArchitzel' DMat,tMedt DATE 3/M /97 3/F/97 3/7/97

! 0FFICIAL RECORD COPY l

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President Mr. Joseph H. Walter, Chief Engineer Calvert County Board of Public Service Commission of Commissioners Maryland 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 2102 Baltimore, MD 21202-1631 Jay E. Silberg, Esquire .

Shaw, Pittman, Potts, and Trowbridge Patricia T. Birnie, Esquire 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. Larry Bell 1650 Calvert Cliffs Parkway NRC Technical Training Center Lusby, MD 20657-47027 5700 Brainerd Road Chattanooga, TN 37411-4017 Resident Inspector U.S. Nuclear Regulatory Mr. Barth Doroshuk i Commission Calvert Cliffs Nuclear Power Plant '

P.O. Box 287 1650 Calvert Cliffs Parkway St. Leonard, MD 20685 Lusby, MD 20657-47027 '

Mr. Richard I. McLean Mr. Robert Tucker '

Administrator - Radioecology Calvert Cliffs Nuclear Power Plant Department of Natural Resources 1650 Calvert Cliffs Parkway 580 Taylor Avenue Lusby, MD 20657-47027 Tawes State Office Building, 83 Annapolis, MD 21401 Mr. Doug Walters Nuclear Energy Institute i Regional Administrator, Region I 1776 I Street, NW ,

U.S. Nuclear Regulatory Commission Suite 400 '

475 Allendale Road Washington, DC 20006-3708 l King of Prussia, PA 19406 l

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DISTRIBUUQN:w/ attachments: Mtg. Summary w/BGE Dated March 24, 1997 Central File '

i PUBLIC PGEB R/F ,

RArchitzel l CCraig EHoller E-Mail SCollins/FMiraglia RZimmerman AThadani TMartin SNewberry ,

SFlanders I DMatthews l BZalcman  !

LChandler, OGC  !

JMoore, OGC ,

DCleary, RES i JWilson SBajwa i ADromerick l DScaletti

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