ML20138K915

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Summary of 970205 Meeting W/Bge in Rockville,Md Re License Renewal Er Template Process Proposed by Bge.List of Meeting Participants Encl
ML20138K915
Person / Time
Site: Calvert Cliffs  Constellation icon.png
Issue date: 02/13/1997
From: Craig C
NRC (Affiliation Not Assigned)
To: Matthews D
NRC (Affiliation Not Assigned)
References
NUDOCS 9702190217
Download: ML20138K915 (42)
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Text

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g j NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. *- maai

\.m./ February 13, 1997 l

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MEMORANDUM T0: David B. Matthews, Chief L

Generic Issues and Environmental )

! Projects Branch I Division of Reactor Program Management j Office'of Nuclear Reactor Regulatic: i FROM: Claudia M. Craig, Senior Project Manager

. Generic Issues and Environmental g( 0-4 Projects Branch Division of Reactor Program Management (  !

Office of Nuclear Reactor. Regulation

SUBJECT:

SUPB4ARY OF MEETING WITH BALTIM0RE GAS & ELECTRIC (BGE) TO  ;

DI$ CUSS LICENSE RENEWAL ENVIRONMENTAL REPORT (ER). TEMPLATE  ;

PROCESS i'

The subject meeting was held at the' Nuclear Regulatory Commission (NRC) offices in Rockville, Maryland on' February 5,1997, between representatives of BGE and the NRC staff. The purpose of the meeting was to discuss the license  :

renewal ER template process proposed by BGE. Attachment 1 is a: list of meeting participants, Attachment 2 is a copy of both the BGE and'NRC non-j l

proprietary presentation material, j 1

BGE proposed the ER template process in order to develop a format and content i guide for the ER to be submitted in support of a license renewal application. . j Existing NRC guidance is currently being updated to reflect the revised'10 CFR '

Part 51. The revised rule includes the environmental requirements of a

' license renewal application. BGE anticipates' completing their ER prior to final guidance being issued by the Commission, thus, the effort on the template to determine an acceptable format 'and content. It is the staff and BGE's objectiv0 that the completed environmental template outline a format and content such that if the ER follows the template, sufficient information will be contained in the report to accept the report for review.

BGE provided a status of the BGE Calvert Cliffs ER. It is BGE's intention that an.ER be completed by May 1997. The template process would occur in parallel with the completion of the ER. BGE also provided a status of NEI activities with regard to development of industry standards for the ER portion of a license renewal application. There is an attempt to take the BGE template and "genericize" it for industry use (include issues for both PWRs and BWRs etc.).

BGE could not speak to what NEI will-do, but it appears that NEI may opt to comment on the draft NRC regulatory guide (RG) using the " generic" template j versus developing separate industry standards or guidance. BGE stated that NEI would contact NRC separately to discuss their activities.

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The NRC staff provided comments on the assumptions it used to develop a draft i schedule for review of the template and the status of development of the RG l

< and the environmental standard review plan (ESRP). The staff agreed with the 1 BGE objective that the final template would outline an acceptable format and '

content for an ER that would be acceptable to begin a review. The staff I
stated its ' preference to select examples that will be more detailed than just  ;

! format and content after the' initial round of comments on the template. The  ;

staff believes that the template should be essentially set before the examples j!

i are selected and that the examples should provide a wide range of ease and

difficulty to provide insights for future license renewal application reviews.  ;
The staff also noted that the RG and ESRP work is the top priority and the t
template work is seen as a. benefit, as long as consistency between all the I

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i efforts is maintained.  !

BGE then. discussed each section of the template (the template is included in  !

Attachment 2 to this summary). Attachment 1 to the template is a cross  ;

i reference which provides the 10 CFR 51 requirement and the ER section and BGE action. The template was developed in the format of an NRC environmental i j

, impact statement and BGE stated that it did not use the guidance in RG 4.2, -

1 "Freparation of Environmental Reports for Nuclear Power Stations" to develop- )

L 'the template. BGE provided their proposed schedule while NRC proposed their i

! schedule. Discussion ensued about how to combine dates and milestones. The  !

[ agreed upon draft schedule is as follows: l 1 .

2/5/97 - receive first draft of template '

{l wk of 3/10/97 - NRC to provide comments on template, BGE and NRC to decide on

, examples, and discuss issues concerning severe accident mitigation i alternatives!(SAMA) and transportation wk of 4/1/97l- BGE;to provide revised template and draft examples i wk of 5/6/97 - NRC to provide comments on revised template.and draft examples I wk of 5/20/97 - BGE-to incorporate comments on template / examples and NRC/BGE senior management < meeting to discuss progress / issues on template process x

, y, It.,was discussed th'at the draft schedule outlined above is optimistic. The tentative! dates'are based on the premise that the template is close to what would be acceptable af.d extensive revisions will not be needed such that the

-template is in(relatively. good shape after the first round of comments.

. Discussions were held that the other guidance work, the ESRP and RG, have firm

commitment dates'to the Commission ~andathat the template work is still

, voluntary on the part of BGE and the NRC.

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BGErand the; staff also ' discussed scheduling specific meetings to discuss four distinct issues where BGE would like the NRC to provide additional guidance as to what the format and content should be for SAMA, transportation, env'ironmental justice, and ele'ctric shock. It was tentatively decided that the first two issues would be addressed in the 3/10/97 time frame and the

-latter two would be, addressed.at some later point.

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D. Matthews 3 February 13, 1997 BGE also provided the staff with some issues that may be used as examples.

These include: ground water, socioeconomic, electric shock, transportation (specifically Table S-4), and alternatives. BliE and the staff agreed to discuss the selection of examples after the staff has had a chance to review the draft template.

Docket Nos. 50-317, 318 Attachments: As stated cc w/atts: See next page 3

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d D. Matthews 3 Gebruary 13,1997 BGE also provided the staff with some issues that may be used as examples.

These include: ground water, socioeconomic, electric shock, transportation (specifically Table S-4), and alternatives. - BGE and the staff agreed to discuss the selection of examples after the staff has had a chance to review the draft template.

Attachments: As stated cc w/atts: See next page DISTRIBUTION:w/ attachments:

.; Central File

  • PUBLIC PGEB R/F RArchitzel CCraig l E-Mail FMiraglia/AThadani RZimmerman BSheron i

TMartin SNewberry SFlanders BZaleman LChandler, 0GC GHoller/JMoore, 0GC DCleary, RES JWilson ADromerick-DOCUMENT NAME: 2_5_97. MIN j

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D. Matthews 4 cc:

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 j Baltimore, MD 21202-1631 l

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

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ENVIRONMENTAL REPORT TEMPLATE PROCESS t

-.,- FEBRUARY 5, 1997 i <  ; 3 .

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, . MEETING PARTICIPANTS V

H8ME ORGANIZATION Claudia Craig NRC/NRR/PGEB Ralph Architzel NRC/NRR/PGEB Jim Wilson. .

NRC/NRR/PGEB Barry Zalcman NRC/NRR/PGEB  :

Scott F1anders NRC/NRR/PDLR ,

4 Don Cleary NRC/RES/DRA

Tricia Heroux for EPRI David Lewis Shaw Pittman Julea Bradley Halliburton NUS/BGE l Robert Tucker BGE Barth Doroshuk BGE Dave Matthews NRC/NRR/PGEB

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ATTACHMENT 1

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I Life Cycle Management Unit i

License Renewal Discussions 10CFR Part 51 .l February 5,1997 4

Barth W. Doroshuk .

Principal Engineer' Slide 1 LCM-97-004 ATTACHMENT 2

.i Life Cycle Management Unit Objectives of Discussions Provide NRC with status of BGE ER activities t

- Provide NRC with BGE objectives of this effort  ;

- Present 2/5/97 version of ER template

- Provide overview of template contents

- Discuss / agree to schedule reviews / discussions

- Establish need to discuss particular sections of l Pad 51 ,

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Slide 2 LCM-97-004 ,

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r Life Cycle Management Unit Status of BGE Environmental Report

- Draft Environmental Report prepared to 2/5/97 template requirements due 2/14/97 l-

- Will not include SAMA, EJ or Yucca Mountain generic and  :

cumulative effects analyses  ;

- BGE " Core Team" review complete by end of  ;

February 1

- Need to begin SAMA, EJ and transportation analysis soon j

- ER to be completed, including site reviews, by May 1997 Slide 3 f LCM-97-004 l t

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Life Cycle Management Unit BGE ObjecJves of Environmental Template Effort

- Achieve agreement between NRC and BGE.on format and content of an ER so that, should BGE submit LRA, NRC would find ER Section sufficient to begin review.

BGE recognizes NRC is developing regulatory guide and standard review plan.

BGE is a participating member of the NEl t

Working Group for license renewal and both the Part 54 and Part 51 task forces., .

t Slide 4 i LCM-97-004

Life Cycle Management Unit Template Overview Template provides comprehensive linkages from  :

10CFR Part 51 requirements to Environmental Report.

Template provides both descriptive elements i and requirements for the format and content of an Environmental Report.

Template will provide a basis, if implemented properly, for BGE to meet NRC expectations such that formal reviews can begin. -

i Slide 5 LCM-97-004

M Life Cycle Management Unit Template Overview Sections Introduction Section 1 -

Purpose and Need for Action Section 2 -

Alternatives including Proposed Action Section 3 -

Affected Environment Section 4 -

Environmental Consequences and Mitigating Actions Section 5 -

Compliance Status Section 6 References ,

Appendices -

Currently A through H Slide 6 LCM-97-004

Life Cycle Management Unit Proposed Template Schedule j Activity Date

- BGE submits initial draft of template for NRC review and comment . .. ................... .......... . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2/5/9 7

- NRC provides concurrence and/or comments to BGE..... . ......... 2/19/97

- BGE and NRC agree on four ER topics for exercise....... .... ......... 2/19/97

- BGE submits template portions of selected topics for NRC review and revised tempiate. ... . ... ...................... ... ............ 3/5/97

- NRC provides BGE comments on exercises ...... .. ... . .... ............ 3/26/97 BGE reviews NRC comments and submits response / corrected exercises..... . . .. .. . ... ... . ..... ... .. .. . ..... .... . 4/16/97

- BGE and NRC meet to close out any remaining items and prepare for Senior Management Meeting ...,....... .. ... ........... .. 5/14/97

- Senior Management Meeting ........ .. . ... . .. .................... ..... .. ... .... 5/21/97 Slide 7 LCM.97-004

f Life Cycle Management Unit 10CFR Part 51 Issue Specific Exchannes BGE requests clarification on four specific issues required to be evaluated by 10CFR51:

- Severe Accident Mitigation Alternatives ,

- Environmental Justice

- Transportation

- Electric Shock BGE has provided NRC with four papers containing

" current thinking" and "needs" regarding clarification i .

BGE proposes to conduct several focus meetings '

regarding these issues Slide 8 LCM-97-004

Life Cycle Management Unit 10CFR issue Specific Exchannes

- Initial Severe Accident Mitigation i Alte rn atives Exch a nge............ ......................... ...................... 2/19/97 Initial Transportation Exchange..................................... 2/19/97

- Initial Environmental Justice Exchange............... 3/5/97

- Initial Electric Shock Exchange.. ... . ... . ......... .. ....... 3/5/97 i

I Slide 9 LCM-97-004

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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 Template is annotated to describe the contents of 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 found at Title 10, Code of Federal Regulations, Part $1, Section 53, Paragraph (c) Operating license renewalstage

[10 CFR 51.53(c)].' Attachment 1 provides cross-references from regulatory requirements to ER sections that this '

Template identifies.

Regulation 10 CFR 51.53 does not specify a format for an ER. However, NRC would use the ER :'s input when  !

preparing a CCNPP license renewal environmental impact statement in accordance with National # avironmental l Policy Act requirements. To expedite NRC usage of the ER, BGE has formatted it to follow NRC format for l presentation of materials in an environmental impact statement.'

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Environmental Report Template l

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 i recommendations.

1. Purpose of and need for action [ required by 10 CFR S t.45(b) as incorporated by 10 CFR St.53(c)(2)] I Describe the purpose of the proposed action as that of providing an option that allows for power generation capability beyond the term of the plant's current operating license to meet future system generating needs (input from 61 FR 109,6/5/96, p 28472)
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)]

e 6 2.1 would provide sufficient information about CCNPP to facilitate an understanding'of the applicable Q 4.1 issues and mitigation attematives e To facilitate NRC review, references to background information provided in previous CCNPP documents (e.g., Final Environmental Statement) would be provided 2.1.1 General plant information i e

e Describe CCNPP location, site, plant. Use figures to illustrate )

identify FES. Use table to list post-FES National Environmental Policy Act documentation 1

' Federal Register, Vol. 61, No. 244, December 18,1996, pages 66537-66554; Federal Register, Vol. 61, No.109, June 5,1996, pp. 28467 28496; and Federal 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).

1 2/5/97

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I 2.1.2 Nuclear fuel and radioactive waste (input to ER i 4.1.18)

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  • Describe unirradiated fuel shipments to CCNPP l

. Describe fuel form and enrichment e Describe reactor core thermal power level e Describe irradiated fuel burnup rate, handling

. Describe irradiated fuel and other radioactive solid waste shipments from CCNPP 2.1.3 IIcat dissipation system (input to ER f $ 4.1.2,4.1.3, and 4.1.4)

  • Describe CCNPP cooling system (e.g., once-through heat dissipation system) 2.1.4 Groundwater use (input to ER { 4.1.5)
  • Describe CCNPP wells. Use table to summarize characteristics (e.g., depth, aquifer, capacity) and figure to illustrate locations relative to site boundary
  • Identify historical pumping rates (show greater than 100 gallons per minute). Use table to summarize data. Discuss any trend and use figure to illustrate

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2.1.5 Transmission facilities (input to ER Q 4.1.9)

. Describe CCNPP transmission facilities and changes since originallicensing. Use figure to illustrate locations e Describe change in use of the lines since original licensing 2.1.6 Modifications [ required by 10 CFR S t.53(c)(2)] (input ta ER (( 2.1.7,4.1.6,4.1.7, and 4.1.16)

  • Summarize CCNPP physical modifications as result of integrated plant assessment (IPA) i e Summarize changes to (or addition of) administrative control procedures from IPA 2.1.7 Employment (input to ER Q 4.1.8,4.1.10,4.1.11,4.1.12,4.1.13,4.1.14,4.1.15) e Describe number of CCNPP workers during routine operations and during refueling outages and the portion estimated living in Calvert County
  • Predict total refurbishment manpower requirements i
  • Describe any projected increase in stafling nnmber during license renewal term e

Explain differences in CCNPP employment projections versus GEIS estimates ..

2.2 Alternatives [ required by 10 CFR 51.53(c)(2)]

If the CCNPP licenses were not renewed, the plant would be decommissioned and an alternative power supply would be considered to meet the demand for power. This section will present various power supply alternatives to meet the demand. Feasible alternatives considered will be presented. For each feasible attemative, a general description would be provided with manpower estimates, emission discussion, description of cooling water system, delivery systems, and technology alternatives within the alternatives.

Impacts will be summarized in Q 2.3.

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2.2.1 Feasible Alternatives 2.2.1.1 Example - Coal-fired plant construction at Calvert Cliffs site

  • Provide general description of plant, including acreage and manpower needed
  • Describe construction, manpower l
  • Describe coal delivery system (barge dock, coal pile), maintenance dredging
  • Describe cooling water system including potential use existing system.

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  • Describe air emissions
  • Describe ash handling 2.2.2 Other Alternatives i

e Briefly discuss non-feasible alternatives

  • For each alternative, provide basis for concluding non-feasible 2.3 Proposed action / Alternatives summary comparison
  • Discuss differences in environmental impacts from proposed action (ER 0 4.1) and attematives (ER Q 4.2) 1
  • Provide tabular comparison between proposed action and alternatives for each Category 2 issue applicable to CCNPP and any other Category 2 or 1 issue applicable to an alternative (s) for which l impact is moderate or large l l
3. Affected environment 1

Provide sufficient information to support each of the below { 4.1 analyses of Category 2 issues and any new l and significant information, if any.

3.1 Biological resources 3.1.1 Aquatic ecology (input to ER { 4.1.2,4.1.3, and 4.1.4)

  • Describe CCNPP aquatic ecology
  • Describe CCNPP terrestrial ecology (if affected by refurbishment activities) 3.1.3 Special Status Species (input to ER $ 4.1.7)
  • Describe CCNPP special status (threatened ad endangered) aquatic species
  • Describe CCNPP special status (threatened and endangered) terrestrial species 3.2 Geology and groundwater hydrology (input to ER { 4.1.5)
  • Describe CCNPP and area geology as it applies ta groundwater aquifers affected by CCNPP. Use a figure to graphically illustrate the geology
  • Describe CCNPP and area groundwater hydrology. Use a table to summarize information about aquifers and a figure to illustrate potentiometric surface trending
  • Identify offsite wells and groundwater usage. Use a table to summarize data and a figure to illustrate location of nearest well finished in the aquifer that CCNPP uses 3 2/5/97

3.3 Air quality (input to ER { 4.1.8) e Describe National Ambient Air Quality Standards (NAAQS) status of CCNPP area e Identify closest nonattainment and mairenance area for vehicle emissions 3.4 llousing(input to ER g 4.1.10)

  • Describe historical growth rate and the percent attributable to the CCNPP work force e Describe current CCNPP-area housing availability (permanent and temporary) 3.5 Public services (input to ER (( 4.1.11,4.1.12, and 4.1.15)
  • Identify CCNPP-area public water supply systems (input to ER { 4.1.1l) e Describe any systems having problems meeting base or peak demand

. For any system having supply problems, estimate percent of demand attributable to CCNPP staff and indirect multiplier e Describe the adequacy of the County's educational system (input to ER $ 4.1.12)

  • Describe adequacy oflocallevel of services for transportation (input to ER f 4.1.15). _

3.6 Offsite land use (input to ER 66 4.1.13 and 4.1.14) e Describe trends in land use e Describe land use with regard to residential and commercial development in Calver. County e Use figures to illustrate location and general features 3.7 CulNral resources (input to ER 9 4.1.16)

For plant site and transmission line right-of-way: i e Describe past cultural resource investigations i j

e Describe prehistoric and historic resources e Describe current cultural resource protection activities l 3.8 Demography (input to ER (( 4.1.10,4.1.11,4.1.12,4.1.13,4.1.14,4.1.15, and 4.1.17 )

l e Describe population size and distribution around CCNPP i e Use figure to identify sectors and tables to summarize data

4. Environmental consequences and mitigating actions 4.1 Proposed action For each issue in il 4.1.2 through 4.1.18 (except as specifically noted), discuss the bulleted items below plus the issue specific information listed within each section.
  • State the issue e identify GEIS reason for tot making Category I and discuss how reason applies in case of CCNPP e Identify and discuss alternative mitigation measures [ required by 10 CFR 51.53(c)(3)(iii)]

e 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 i

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l Moderate- for the issue, environmental effects are sufficient to alter noticeably, but not to destabilize, important attributes of the resource Large- for the issue, environmental effects are clearly noticeable and are sufficient to destabilize l important attributes of the resource l 4.1.1 Introduction

  • 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 Entrainment [ required by 10 CFR S t.53(cX3XiiXB); Tape B-1 Issue Number 25]

In addition to the general information called for above in f 4.1 include the following:

  • Reference ER Q 2.1.3 for description of the heat dissipation system e Reference ER 6 3.1.1 to support discussion of mitigation alternatives
  • Describe 316(b) requireme : and history of CCNPP compliance e Use Appendix B to providc i >py of pages from CCNPP 1982 discharge permit that references 316(b) study 4.1.3 Irnpingement [ required by 10 CFR 51.53(cX3Xii)(B); Table B-1 Issue Number 26]

In addition to the general information called for above in { 4.1 include the following:

  • Reference ER { 2.1.3 for description of the heat dissipation system a Reference ER 6 4.1.2 for discussion of CCNPP 316(b) study

. Reference ER { 3.1.1 to support discussion of mitigation alternatives 4.1.4 lleat shock [ required by 10 CFR S t.53(c)(3)(ii)(B); Table B-1 Issue Number 27]

In addition to the general information called for above in 6 4.1 include the following:

  • Describe 316(a) requirement and applicability to CCNPP e Use Appendix B to provide copy of pages from CCNPP 1982 discharge permit that document compliance 4.1.5 Groundwater use [ required by 10 CFR 51.53(cK3)(ii)(C): Table B-1 Issue Number 33]

In addition to the general infonnation called for above in 6 4.1 include the following:

  • Reference ER g 3.2 discussion of geology and groundwater hydrology
  • Calculate current drawdown at CCNPP site boundary attributable to CCNPP withdrawal e Project drawdown attributable to withdrawal during license renewal period. Include calculations as Appendix C e Provide basis for conclusions regarding impacts to a hypothetical site boundary well 4.1.6 Refurbishment impacts (to terrestrial resources) [ required by 10 CFR 51.53(c)(3Xii)(E); Table B-1 issue 40]

In addition to the general infonnation called for above in Q 4.1 include the following:

  • Reference ER f 3.1.2 discussion of terrestrial ecology and { 2.1.6 for discussion of refurbishment scope
  • Describe effect of refurbishment activities on plant operations and the outside environment or effluents 5 2/5/97

4.1.7 Threatened and endangered species [ required by 10 CFR S t.53(cX3)(ii)(E); Table B-1 Issue 49]

In addition to the general information called for above in i 4.1 include the following:

  • Reference ER j 3.1.3 discussion of special status species and ER { 2.1.6 for discussion of plant modifications e Describe effect of refurbishment activities on important plant and animal habiws
  • Describe effect of plant modifications on threatened and endangered species e Describe status of consultation with Maryland 11eritage Program, U.S. Fish and Wildlife Service, and National Marine Fisheries Service. Include as Appendix D copies 6f DGE request for consultation and agencies' responses 4.1.8 Air quality during refurbishment (nonattainment and maintenance areas) [ required by 10 CFR S t.53(c)(3)(iiXF); Table B-1 1ssue 50]

In addition to the general information called for above in Q 4.1 include the following:

e Reference ER 0 3.3 discussion of air quality and ER { 2.1.7 for refurbishment work force e Provide basis for calculation ofincreased staff vehicles' emissions 4.1.9 Elect >ic shock (required by 10 CFR Sl.53(c)(3)(ii)(li); Table B-1 Issue 59] _

e Present issue statement and categorization as described above in { 4.1 (exclude discussion of mitigation alternatives and impact extent)

  • Reference ER 6 2.1.5 discussion of transmission lines e Explain inapplicability of this issue to the proposed action due to changes in transmission line use since original licensing 4.1.10 llousing impacts [ required by 10 CFR 51.53(c)(3)(ii)(I); Table B-1 Issue 63]

in addition to the general information called for above in { 4.1 include the following:

  • Reference ER 0 3.4 discussion of housing, ER 6 3.8 discussion of demography, and ER Q 2.1.7 discussion of refurbishment and license renewal term work force j e Compare increase in staff to normal operations and refueling outage staff numbers j e Project impacts to housing from increased number of staff during refurbishment and license i renewal term 4.1.11 Public services: public utilities [ required by 10 CFR 51.53(c)(3)(ii)(I); Table B-1 issue 65]

In addition to the general information called for above in Q 4.1 include the following:

  • Reference ER f 3.5 discussion of public services, ER { 3.8 discussion of demography, and ER

{ 2.1.7 discussion of refurbishment and license renewal term work force

  • Compare increases in staff to normal operations and refueling outage staff numbers e Project impacts to public water supply from increased number of staff during refurbishment and license renewal term 4.1.12 Public services, education (refurbishment) [ required by 10 CFR 51.53(c)(3)(ii)(1); Table B-1 issue 66]

In addition to the general information called for above in f 4.1 include the following:

e Reference ER 6 3.5 discussion of public services, ER Q 3.8 discussion of demography, and ER

{ 2.1.7 discussion of refurbishment work force e Compare increase in staff number from refurbishment to normal operations and refueling outage staff numbers e Project impacts to education system from increased number of staff during refurbishment 6 2/5/97

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l 4.1.13 Offsite land use (refurbishment) [ required by 10 CFR SI.53(cX3XiiXI); Table B-1 Issue 68]

I In addition to the general information called for above in 6 4.1 include the following:  !

  • Reference ER { 3.6 discussion of ofTsite land use, ER 6 3.8 discussion of demography, and ER

$ 2.1.7 discussion of refurbishment work force 1

e Compare increase in staff number from refurbishment to normal operations and refueling outage staff numbers

  • Project impacts to offsite land use from increased number of stafTduring refurbishment 4.1.14 Offsite land use (license renewal term) [ required by 10 CFR S t.53(cX3XiiXI); Table B-1 Issue 69]

In addition to the general information called for above in f 4.1 include the following:

  • Reference ER Q 3.6 discussion of offsite land use, ER { 3.8 discussion of demography, and ER l 2.1.7 discussion oflicense renewal term work force e Compare increase in staff number during license renewal term to normal operations staff numbers e Project impacts to offsite land use from increased number of staff during license renewal term

~

4.1.15 Public services, transportation (required by 10 CFR 51.53(cX3)(iiXJ); Table B-1 Issue 70]

In addition to the general information called for above in 6 4.1 include the following:

e Reference ER 9 3.5 discussion of offsite land use, ER { 3.8 discussion of demography, and ER l 2.1.7 discussion of refurbishment work force e Compare increase in staff number during refurbishment to normal operations and refueling outage staff numbers e Project impacts to transportation from increased number of staff during refurbishment 4.1.16 Historic and archaeological resources [ required by 10 CFR S t.53(c)(3)(iiXK); Table B-11ssue 71]

In addition to the general information called for above in { 4.1 include the following:

  • Reference ER { 3.7 discussion of cultural resources and ER i 2.1.6 discussion of refurbishment scope e Describe refurbishment and license renewal term impact to cultural resources l

. Describe status of consultation with Maryland Historic Trust (State Historic Preservation Officer). Include as Appendix E copies of BGE request for consultation and agency response i

4.1.17 Severe accident mitigation alternatives [ required by 10 CFR 51.53(cX3)(ii)(L); Table B-1 I

Issue 76]

e Approach TBD 4.1.18 Transportation [ uranium fuel cycle and waste management] [ required by 10 CFR 51.53(c)(3)(iiXM); Table B-1 issue 85]

In addition to the general information called for above in Q 4.1 include the following:

  • Reference ER $ 2.1.2 for discussion of CCNPP fuel enrichment and burnup
  • Discuss how CCNPP fuel characteristics differ from Table S-4 criteria e Describe NRC generic and CCNPP-specific analyses for higher enrichment and burnup rates j e Provide bounding analysis of Table S-4 generic impacts and NRC sensitivity analysis in the GEIS e include rederal Register notices of NRC transportation assessments in Appendix G e Approach to cumulative and synergistic impacts at Yucca Mountain [TBD]

7 2/5/97

_. ._ _ _ . . . -. _ - . _ _ - - _ _ . _ _ _ _ _ _ . _ _ _ _ > __ _ _ _ _ _ m . .. ._ __

1 l

i 1 i i

i 4.1.19 New and significant information [ required by 10 CFR 51.53(cX3Xiv)]

i If new and significant information exists, the following would be presented. j

.

  • Describe any CCNPP-specific information that would make a GEIS analysis or conclusion '

) for a Category 1 issue not applicable for CCNPP (none known now) 4.2 Alternatives [ required by 10 CFR 51.53(c)(2)]

For each of the feasible Alternatives to meet the power demands (ER i 2.2), discuss the following:

l e Reference applicable discussion of Alternatives in the GEIS Chapter 8, Alternatives to License 3

Renewal

  • Describe significant issues addressed in f 4.1 plus any other applicable Category 2 or 1 issue for I

which impact would be moderate or large

. Provide sufficient detail for NRC to determine whether or not environmental impacts oflicense l 2

renewal are so great, compared to the Alternatives, that preserving the option oflicense renewal for future decision makers would be unreasonable [10 CFR 51.95(c)(4)].

4 4.3 Committed resources l

'l

} 4.3.1 Unavoidable adverse impacts [ required by 10 CFR 51.45(bX2) as referenced in 10 CFR31.53(c)(2)]

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

  • Note that Category I adverse impacts covered by GEIS 1

i 4.3.2 Irreversible or irretrievable resource commitments [ required by 10 CFR 51.45 (b)(5) as referenced in 10 CFR 51.53(c)(2)]

s e Identify subset of f 4.3.1 impacts that are permanent or of such long-term impact as to be considered pennanent.

j e Note that discussion does not include Category I commitments covered by GEIS 4.4 Short-term use versus long-tenn productivity [ required by 10 CFR 51.45 (bX4) as referenced in 10 CFR  !

51.53(c)(2)]

t

  • Describe GEIS Category 1 impacts and % 4.1 Lategory 2 impacts as local short-term uses of man's environment (or identify any that are not short-tenn).  !

i

  • Identify any ways that these short-term u: es affect the maintenance and enhancement oflong-term productivity of man's environment.
5. Compliance status [ required by 10 CFR S t.45(d) as referenced in 10 CFR S t.53(c)(2)]

5.1 Proposed action e List approvals Federally required for license renewal. Identify compliance status e include, as Appendix 11, copy of any approvals received and applicable State regulations e Discuss status of compliance with Federal, State, and local environmental protection requirements.

Use table to illustrate compliance status 8 2/5/97

l i

5.2 Alternatives e identify whether the feasible Alternatives would comply with Federal, State, and local environmental J

protection requirements  ;

1

6. References Appendix A NRC NEPA issues for License Renewal of Nuclear Power Plants  ;

- i e List and number each issue from 10 CFR 51 Table B-1 j

= For each issue, identify where in the ER the issue is discussed '

e Identify issues not applicable to CCNPP (e.g., due to physical characteristics of the plant)

Note: Referred to in ER { 4.1.1 Appendix B 316(a) and 316(b) documentation e Provide copy of pages from CCNPP 1982 discharge permit that mention 316(b) study and that documents 316(a) compliance _

l Note: Referred to in ER { 4.1.2 and 4.1.4 Appendix C Offsite well impact calculation e include well impact calculation Note: Referred to in ER 4.1.5 Appendix D Special status species consultation l

  • Include copies of BGE request for consultation and agencies' responses Note: Referred to in ER { 4.1.7 Appendix E Cultural resources consultation e include copies of BGE request for consultation and agency response Note: Referred to in ER { 4.1.16 Appendix F Severe accidents e include detailed severe accidents discussion Note: Referred to in ER { 4.1.17 Appendix G NRC Transportation Assessments e include copies of relevant NRC Transportation Assessments published in the Federal Register Note: Referred to in ER { 4.1.18 Appendix 11 Approvals 9 2/5/97
  • Provide copies of any other agency approvals Note: Referred to in ER f 5.1 I

e 1

l i

i 10 2/5/97 I i

e el o

RULE- ER CROSS REFERENCE TABLE .

No. 10 CFR 51.53 Requirement Environsental Report Action i

l. (c) Operating license renewalstage. (1) Each applicant for renewal of a license to operate a nuclear power plant BGE would submit 41 copies of the under part 54 of this chapter shall submit with its application the number of copies specified in f 51.55 of a separate " Applicant's Environmental Report-Operating document emitted " Applicant's Environmental Report--Operating License Renewal Stage." License Renewal Stage" to the Director of the Office of Nuclear Reactor Regulation and

[Q 51.55 included below for case of reference]

g 51.55 Environmental report - number of copies; distribution would retain 104 copies pending uTitten (a) Each applicant for a license to construct and operate a production or utilization facility covered by distribution instructions from the Director.

paragraphs (bX1), (b)(2),(b)(3), or (bX4) of f 51.20, each applicant for renewal of an coerating 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 operating license for the nuclear power plant shall submit to the Director of the Office of Nuclear Reactor Reculation or the Director of the Office of Nuclear Material Safety and Safeguards, as appropriate,4 I conies of an environmental recort or supplement to an ensironmental report. The applicant shall retain an additional 109 cooies of the environmental report or any supplement to the environmental report for distribution to carties and Boards in the NRC proceedines: Federal. State _ and local officials: and any affected Indian tribes. in accordance with written instructions issued by the Director of the Oflice of Nuclear Reactor Regulation or the Director of the Office of Nuclear Material Safety and Safeguards, as appropriate. [ underlined highlights added for emphasis]

2. (2) The report must contam a desenption of the proposed action, including the applicant's plans to modify the { 2.1 would desenbe the proposed action.

facility or its administrative control procedures as described in accordance with { 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 effluents that affect the environment.

3. In addition, the applicant shall discuss m this report the environmental impacts of alternatives 6 2.2.1 would identify feasible Alternatives, and

{ 4.2 would analyze their environmental impacts. <

4. and any other matters desenbed in 9 51.45. BGE would submit signed original and copies

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

g 51.45 Environmental report.

(a) General. As recuired by (( 51.50,51.53. 51.54 51.60,51.61. 51.62 or 51.68, as appropriate ca.c h >

apphcant or petitioner for a rulemaking shall submit with its application or petition for rulemaking one siened oricinal of a separate document entitled "Apolicant's" or " Petitioner's Environmental Reoort." as anpropriate and the number of conies soecified in if 51.55. 51.66, or 9 51.69. An applicant or petitioner for rulemaking may submit a supplement to an environmental report at any time. [ underlined highlights added for emphasis]

5. (b) Environmental considerations. De environmental report shall contain a desenption of the proposed {2.1 would desenbe the proposed action.

action.

6. a statement ofits purposes, t Chapter I would identify the purpose.
7. a desenption of the environment afTected, I Chapter 3 would desenbe the affected environment.

1-1 2/5/97

t &

RULE - ER CROSS REFERENCE TABLE . continued.

No. 10 CFR 51.53 Requirement Environmental Report Action

8. and discuss the following considerations: {4.1 would discuss environmental impacts from (1) The impact of the proposed action on the environment. Impacts shall be discussed in proportion to the proposed action. {4.1.1 would adopt by their significance; reference, as appropriate, GEIS conclusions for Category 1 issues.
9. (2) Any adverse environmental c!Tects 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 of attematives shall be sulliciently complete to {2.2.1 would diwuw feasible Alternatives, and aid the Commission in developing and exploring, pursuant to section 102(2)(E) of NEPA," appropriate { 2.2.2 would discuss non-feasible Alternatives.

alternatives to recommended courses of action in any proposal w hich involves unresolved conflicts concerning { 23 would present impacts from the proposed alternative uses of available resources." To the extent practicable, the environmental impacts of the proposal action and feasible Altematives in comparative and the alternatives should be presented in comparative form; fashion.

(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 I1.

enhancement orlong-term productivity; and issues.

12. (5) Any irreversible and irretrievable commitments of resources which would be involved in the proposed {4.3.2 would address resource commitments.

action should it be implemented.

13. (c) Analpis. 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 environmer tal impacts of alternatives to the proposed action, including mitigative alternatives. The chapter and attematives available for reducing or avoiding adverse environmental effects. 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 attematives as non-feasible, alternatives from further except insofar as such benefits and costs are either essential for a determination regarding the inclusion of an analysis.

alternative 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 facters considered. To the extent that there are important qualitative considerations or factors that cannot be quantified, those considerations or factors shall be discussed in qualitative terms. The environmental report should contain sulTicient data to aid the Commission in its development of an independent analysis.

14. (d) Status ofcompliance. The environmental report shall list all Federal permits, licenses, approvals and other { 5.1 would include list of Federal and other entitlements which must be obtained in cormection with the proposed action and shall describe the status of permits, etc., for the proposed action, and compliance with these requirements. Appendix II would provide agency approvals.
15. 1he environmental report shall also include a discussion of the status of compliance with applicable { 5.1 would discuss compliance status of environmental quality standards and requirements including, but not limited to, applicable zoning and land-use proposed action.

regulations, and thermal and other water pollution limitations or requirements which have been imposed by I

Federal, State, regional. and local agencies having responsibility for environmental protection.

16. The discussion of altematives in the report shall include a discussion of whether the attematives will comply { 5.2 would discuss compliance of the feasible with such applicable environmental quality standards and requirements. Alternatives.

1-2 2/5/97

, j .

RULE- ER CROSS REFERENCE TABLE ^

Attachment 1. continued.

No. 10 CFR 51.53 Requirement Environmental Report Action (c) Adverse information. The information submitted pursuant to paragraphs (b) through (d) of this section BGE would include adverse information, as 17.

should not be confined to information supporting the proposed action but should also include adverse applicable.

information.

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

proposed action or of attematives 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 altematives considered or relevant to economic benefits only in relation to mitigation.

j mitigation. Tne 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 facihty within the The ER would not discuss spent fuel storage in scope of the generic determination in i 51.23(a) and in accordance with l 51.23(b). the spent fuel pool or Independent Spent Fuel Storage Installation after the license renewal  ;

term.

(3) For those applicants seekmg an initirl renewal license and holding either an operating license or construction ne ER would not contain analyses of Category 20.

permit as of June 30,1995, the environmental report shall include me information required in paragraph (c)(2) of this I issues unless, pursuant to 51.53(c)(3)(iv), new and significant information made an NRC GEIS '

section subject to the following conditions and considerations:

(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 1 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), 6 4.1.1 ,

would adopt by reference NRC GEIS analyses (contra new and significant information).

(n) The environmental report must contain analyses of the environmental impacts of the proposed action, De ER would not include this analysis because 21.

CCNPP does not have cooling towers or r 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 Category 2 issues in appendix B to subpart A of this part. He cooling ponds. Appendix A would indicate this required analyses are as follows: for the underlying issues (13 and 34). l l

(A) If the applicant's plant utilizes coolingtowers or cooling ponds and withdraws make-up water from a river whose annual flow rate is less than 3.15 x 10 ff/ 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 provided. i The applicant shall also provide an assessment of the impacts of the withdrawal of water from the river on alluvial aquifers during low flow. l

22. (B) If the apphcant's plant utilizes once-through cooling or cooling pond heat dissipation systems, the applicant i 2.1.3 would describe 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 i 3.1.1 would describe accordance with 40 CFR part 125, or equivalent State permits and supporting documentation, if the applicant can not aquatic ecology; Q 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 Q 4.1.3 would show from heat shock and impingement and entrainment. impingement trending to demonstrate that  ;

Chesapeake Bay improvments have not resulted  !

I in increasing problem at.CCNPP. 9 4.1.4 would I document that a 316(a) sariance was not necessary for CCNPP. Appendix B would provide portions of the CCNPP 1982 discharge permit relative to 316(b) and 316(a),

respectively.

l-3 2/5/97

. e RULE - ER CROSS REFERENCE TABLE Attachment 1. continued.

10 CFR 51.53 Requirement Environmental Report Action No.

(C)If the applicant's plant uses Ranney wells or pumps more than 100 gallons of ground water per minute, an Appendix A would indicate that, because 23.

assessment of the impact of the proposed action on ground-water use must be provided. CCNPP does not use Ranney wc!Is, the underlying issue (35) is not applicable to CCNPP. $ 2.1.4 would demonstrate that CCNPP pumps more than 100 gallons of groundwater per minute, Q 3.2 would describe the pertinent geology and hydrogeology, and ,

f 4.1.5 would assess impacts. Appendix C would provide well impact calculations.

24. (D) If the applicant's plant is located at an inland site and utiltzes cooling ponds, an i-ument of the impact of the Appendix A would indicate that, because CCNPP does not utilize cooling ponds, the proposed action on groundwater quality must be provided.

underlying issue (39) is not applicable to CCNPP. i

25. (E) All license renewal applicants shall assess the impact of refurbishment and other license-renewal-related g 3.1.2 would Mbe terrestrial ecology, and i construction actisities on important plant and animal habitats. Additionally, the applicant shall assess the impact of 6 4.1.6 would assess refurbishment impacts to the proposed action on threatened or endangered species in accordance with the Endangered Species Act. terrestrial resources. 6 3.1.3 would identify  ;

special status species, and 6 4.I.7 would address impacts to special status species, and Appendix D would provide special status ,

species consultations.

26. (F) If the applicant's plant is located in or near a nonattainment or maintenance area, an assessment of vehicle 9 3.3 would desenbe air quality of CCNPP area, exhaust emissions anticipated at the time of peak refurbishment workforce must be provided in accordance with the and 6 4.1.8 would address vehicle exhaust emissions.  ;

Clean Air Act as amended.

27. (G) If the apphcant's plant uses a cooling pond, lake, or canal or discharges into a river having an annual average Appendix A would indicate that, because flow rate ofless than 3.15 x 10'8 f/f year (9 x 10" m'/ year), an assessment of the impact of the proposed action on CCNPP does not use a cooling pond, lake, or public health from thermophilic organisms in the affected water must be provided. canal and does not discharge into a river, the  !

underlying issue (57) is not applicable to '

CCNPP.

28. (11) If the apphcant's transmission hnes that were constructed for the specific purpose of connecting the plant to g 2.1.5 would hbe the CCNPP transmission the transmission system do not meet the recommendations of the National Electric Safety Code for preventing electric lines and changes since original licensing, and shock from induced currents, an assessment of the impact of the proposed action on the potential shock hazard from $ 4.1.9 would provide basis for concluding that ,

the transmission lines must be provided. the underlying issue (59) is not applicable to i CCNPP. I

29. (1) An assessment of the impact of the proposed action on housing availability, land-use, and public schools g 3.4 would desenbe CCNPP area housing (impacts from refurbishment activities only) within the vicinity of the plant must be provided. Additionally, the availability, and i 3.5 would describe public  ;

applicant shall provide an assessment of the impact of population increases attributable to the proposed project on the services. (( 4.1.10,4.lil2,and 4.1.1I and

.! I would assess housing, schools, and water L public water supply.

supply impacts, respectively. g 3.6 would describe offsite land use, and {$ 4.1.13 and 4.1.14 would assess refurbishment and renewal-term impacts, respectively.

i 1-4 2/5/97 .

RULE - ER CROSS REFERENCE TABLE . continued.

10 CFR 51.53 Requirement Environmental Report Action No.

(J) All apphcants shall assess the impact of the proposed project on local transportation durmg periods oflicense i 3.5 would desenbe local transportation, and 30.

$ 4.1.15 would assess impacts.

renewal refurbishment activities.

(K) All applicants shall assess uhether any historic or archaeological properties will be affected by the proposed { 3.7 would describe CCNPP cultural resources, 31.

$ 4.1.16 would describe impacts, and project.

Appendix E would provide cultural resources consultations.

(L) If the staff has not previously considered severe accident mitigation alternatives for the applicant's plant in an f 3.8 would provide demographic information, 32.

environmental impact statement or related supplement or in an environmental assessment, a consideration of { 4.1.17 would discuss severe accident alternatives to mitigate severe accidents must be provided. mitigation alternatives, and Appendix F would provide detailed severe accident discussion.

(M) The environmental effects of transportation of fuel and waste shall be reviewed in accordance with 6 51.52. CCNPP does not meet conditions m paragraph 33.

[i 51.52 included below for case of reference] The review ofimpacts shall also discuss the generic and (a), because CCNPP fuel enrichment is 5% and cumulative impacts associated with transportation operation in the vicinity of a high-level waste repository site. average level ofirradiation for irradiated fuel The candidate site at Yucca Mountain should be used for the purpose ofimpact analysis as long as that site is can be up to 60,000 megawatt-days per metric under consideration for licensing. ton. Therefore, i 2.1.2 would describe CCNPP l 51.52 Environmental effects of transportation of fuel and waste-Table S-4 fuel enrichment and average level ofirradiation, Every environmental report prepared for the construction permit stage of a light-water cooled nuclear and { 4.I.18 would analyze transportation power reactor, and submitted -Aer February 4,1975, shall contain a statement concerning transportation of fuel impacts. Appendix G would provide relevant and radioactive wastes to and from the reactor. That statement shall indicate that the reactor and this NRC transportation assessments.

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)(1) 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 enrichment not exceeding 4% by weight, and the pellets are encapsulated in zircaloy rods; (3) The average level ofirradiation of the irradiated fuel from the reactor does not exceed 33,000 megawatt-days per metric ton, and no irradiated fuel assembly is shipped until at least 90 days aller it is discharged from the reactor, (4) With the exception ofirradiated fuel, 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 ensironmental impacts of transportation of fuel and waste to and from the reactor, with respect to normal conditions of transport and possible accidents in transport, are as set forth in Summary table S-4 in paragraph (c) of this section; and the values in the table represent the contribution of the traneportation to the environmental costs oflicensing the reactor.

(b) For reactors not meeting the conditions of paragraph (a) of this section, the statement shall contain a full ,

description and detailed analysis of the environmental effects oitransportation of fuel and wastes to and from the reactor, including values for the environmental impact under normal conditions of transport 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 2/5/97

~

RULE - ER CROSS REFERENCE TABLE Attachment 1. continued.

No. 10 CI'R 51.53 Requirement Environmental Report Action (c)

Summary Table S Environmental Impact of Transportation of Fuel and Waste to and from One Light-Water-Cooied Nuclear Power Reactor' Normal Conditions ofTransport Environmental impact llent (per irradiated fuel cask in transit) - 250,000 Btwhr.

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

Truck Less than I per day Rail .. Less than 3 per month Exposed population Estimated number Range of doses to exposed Cumulatrve does to exposed of persons exposed individuals'(per reactor population (per reactor year)'

year)

'lransportation workers 200 0.01 to 300 millirem 4 man-rern General public Onlookers I,100 0.003 to I.3 millirem. 3 man-rem Along route. 600.000 0.000I to 0.06 millirem._

Accidents in Transport Environmental nsk Radiological eficcts Small' Common (nonradiological) causes I fatal injury in 100 reactor years; I nonfatal injury in 10 reactor years; $475 property damage per reactor year "Jata supportmg this table are given in the Commission's Environmental Survey of Transportation of Radioactive Materials to and from Nuclear Power Plants," WASil-1238, December 1972, and Supp. I NUREG-75/038 April 1975.

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

WASII.1238 is available from NTIS at a cost of $5.45 (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 of a population group of 1,000 peopic were to receive a dose 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. (in) The report must contain a consideration of alternatives for reducing adverse impacts, as required by Chapter 4 would include consideration of f 51.45(c), for all Category 2 license renewal issues in Appendix B to Subpart A of this part. No such consideration is mitigation alternatives.

required for Category 1 issues in Appendix B to Subpart A of this part.

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

35. (iv) The environmental report must contain any new and significant information regarding the environmental 9 4.1.19 would address new and significant impacts oflicense renewal of which the applicant is aware. infonnation.

1-6 2/5/97

4 l-

  • I Severe Accident Mitigation Alternatives 2

3 4 Requirement: Consideration of alternatives to mitigate severe accident impacts' 5

6 Implementation Options:

7 -

2 8 1. Follow approach used in precedent Limerick analysis ;

9 10 a. Use Individual Plant Examination (IPE) probabilistic risk assessment source terms and release 1I rates, site meteorology, and site population data to model individual and cumulative dose from 12 unmitigated accidents 13 14 b. Perform design review and literature search to identify preliminary mitigation alternatives 15 16 c. Rerun IPE code using each preliminary mitigation alternative to identify source term and release 17 rate reduction. Alternatives that effect reductions become candidate mitigation attematives 18 19 d. Evaluate cost ofimplementing candidate mitigation alternatives 20 21 e. Re-model individual and cumulative doses for each candidate mitigation alternative 22 23 f. Identify implementation cost per person-rem averted for each candidate mitigation alternative.

24 Compare'to NRC standard of $2,000 per averted person-rem (i.e., if cost is greater than standard, 25 implementation is not jus'tified).' ,

1 26 27 g. Treat externally-initiated events qualitatively 28 29 2. Follow Limerick approach except remain silent on externally-initiated events. When BGE completes 30 CCNPP IPEEE (approximately one year), submit an environmental report revision that contains a 31 quantitative analysis of externally-initiated events severe accidents mitigation alternatives (SAMAs).

32 33 3. Perform bounding analysis that demonstrates applicability of Limerick and Comanche Peak 34 analyse d to CCNPP.(Limerick population density twice CCNPP; Comanche Peak a pressurized 35 water reactor like CCNPP).

36 37 4. Other.  :

38 i

l

' 10 CFR 51.53(c)(3)(ii)(L).

' Final Environmental Statement Related to the Operation ofLimerick Generating Station, NUREG-0974 j

Supplement, August 1989. '

' At time of Limerick evaluation, standard was $1,000 per avened person-rem.

" Final Environmental Statement Related to the Operation ofComanche Peek Steam Electric Station,'NUREG-0775 Supplement, October 1989, l

1 1/23/97 l

I Seven Accident Mitigation Alternatives, Continued 2

3 4 Question:

S 6 1. Would NRC use input from a BGE site-specific analysis (e.g., Option 1) or does NRC intend to 7 perform its own general analysis (e.g., bounding analysis similar to Option 3)? ^

8 9 2. Does NRC have another approach for consideration?

10 11 Need: Discussion, during template efforts, of NRC expectations.

12

=

2 1/23/97

1 Transportation 2

3 4 Requirement: Evaluation of environmental effects from transporting fuel and waste, including 5 comparison to Table S-4 and generic and cumulative transportation operation impacts at Yucca 6 Mountain.5 7

8 Implementation Issues: -

9 10 1. Table S CCNPP fuel enrichrtent (5%) and burnup rate (60,000 mwd /MTU) exceed Table S-4 11 fuel enrichment (4%) and burnup rate (33,000 mwd /MTU) criteria. NRC has performed an 12 environmental assessment of the higher CCNPP enrichment and burnup rate and has determined that 13 Table S-4 still bounds CCNPP transportation impacts.'

14 15 2. Table S Preamble to final rule states that applicant can incorporate in analysis the discussion 16 presented in GEIS Section 6.2.3 " Sensitivity to Recent Changes in the Fuel Cycle."7 17 18 3. Yucca Mountain - Predicting industry cumulative impacts could require input on schedule 3 and 19 source terms for all utility and DOE shipments to and from Yucca Mountain and the adjacent Nevada 20 Test Site. BGE does not believe that it or any single utility can obtain the required input or perform 21 such an analysis.

22 23 4. Yucca Mountain - The CCNPP Unit I license expires July 31,2014, which woeld be the earliest that 24 BGE could ship heense renewal term spent fuel to Yucca Mountain. DOE anticipates that it will 8

25 complete its Yucca Mountain environmental impact statement (EIS) in the year 2000 and that the 26 EIS will cover transportation impacts.'

27 28 Implementation Options:

29 30 1. Table S Explain that CCNPP is outside of Table S-4 fuel enrichment and burnup-rate criteria but 31 that NRC has determined that resultant transportation impacts are bounded by the Table S-4 analysis.

32 Demonstrate how this conclusion is consistent with GEIS sensitivity discussion.

33 34 2. Yucca Mountain - Defer discussion of generic and cumulative transportation impacts to DOE EIS.

35 36 Question: Does NRC have any comments on BGE approaches?

37 38 39 Need: NRC position on how to address requirement.

' 10 CFR S t.53(c)(3)(ii)(M).

' 61 FR 66538, December 18,1996, Column 3. i

' lbid. at page 40167.

3 1/23/97 i

1 Environmental Justice 2

3 4 Requirement: Analysis ofimpacts on minority and low-income populations not required but "will be 5 addressed in individual license renewal reviews.""

6 7 Questions:

8 9 1. Would NRC Office of Nuclear Reactor Regulation follow the environmentaljustice polic 10 the NRC Office of Nuclear Material Safety and Safeguards (NMSS) has imple 1I 12 2. What input does NRC need from BGE:

13 14 a. Demographic information on minority and low-income populations (NMSS policy would -

15 require only if significant environmental impacts)?

16 17 b. Evaluation for disproportionate impacts (NMSS policy would require only iflocal minority 18 population percentage significantly exceeds county and state percentages)? For Ca tegory 1 19 and 2 issues?

20 21 Need: NRC identification ofin;;;t r. ceded from BGE.

10 CFR 51 Subpart A, Appendix B, Table B-1, Footnote 6.

" Memorandum, Linehan to NMSS Division Directors, Branch Chiefs, and Section Leaders,4/21/95, NMSS Policy

& Procedures Letter 1-30, Revision 1, "EnvironmentalJustice in NEPA Documents. "

l 4 1/23/97

l I

. 1 1

1 Electrie Shock 2

3  :

4 Requirement: Assessment ofimpact of proposed action on potential transmission line induced shock 5 hazard or demonstration that lines meet National Electric Safety Code (NESC) recommendations for 6 preventing induced shock.i2 ,

7 8

Background:

Implicit in the regulation and the supporting GEIS analysis" appears to be the assumpt.,n f 9 that, if the transmission lines were used (i.e., energized) during the license renewal term, the usage would l 10 be attributable to license renewal and that, conversely, the lines would not be used (i.e., would be de- l 11 energized) iflicense renewal was not granted. This assumption might not be correct. If, for example, a 12 plant has two transmission lines that go to separate substations, intertie operations might dictate that the ,

13- lines remain in use (i.e., energized) as a way of transferring current between the substations even if the  ;

14 plant ceased to generate. In such a case, the proposed action, license renewal, has no effect on whether ,

15 the lines remained in use, and impacts ca ased by line usage would not be attributable to the proposed 16 action, in other words, the proposed action would have no impact on the potential shock hazard.

17 18 Implementation Options. '

19 20 1. If CCNPP transmission line usage is no longer dependent on CCNPP operation, !nclude in l 21 environmental report an explanation that, because the transmission lines would remain energized )

22 regardless oflicense renewal, the proposed action would have no impact and that democtration of- '

23 NESC compliance is not needed.  ;

24 l 25 2. If CCNPP transmission line usage is dependent on CCNPP operation, include in the environmental 26 report a demonstration of NESC compliance.

27 28 Need: Verif'ication of NRC expectation.  ;

29 30 E

r

" 10 CFR Sl.53(c)(3)(ii)(ll).

" Deneric Environmental Imnact Statement for License Renewal of Nuclear Plants, NUREG-1437, Section 4.5, Transmission Lines.

5 1/23/97

.f w

  • om ar%

J

-Y9..

\ ... United States b Nuclear Regulatory Commission I

BGE TEMPLATE PROCESS MEETING i

, February 5,1997 l

Claudia Craig i Generic issues and Environmental Projects Branch Division of Reactor Program Management Office Of Nuclear Reactor Regulation i

1 MAJOR MILESTONES

  • Receive draft template
  • NRC review and comment on template
  • Technical meetings on selected issues to provide guidance
  • Select examples
  • NRC review and comment on examples
  • Complete template process i

1 t

NRC ASSUMPTIONS FOR TEMPLATE PROCESS e Template process does not constitute formal NRC review and i approval e BGE template represents, for the most part, industry view Need to understand what is unique to BGE e Examples will come from a spectrum: easy, hard with a given success path, hard with unknown success path e Examples will provide estimates for resources and will provide insights for future application review e Other work going on at same time - ESRP, RG i Template seen as a benefit to ensure consistency, but also added resource commitments i t

Have a commitment to Commission regarding ESRP and RG - no l similar commitment for template i

2

NRC STATUS

  • SECY-96-259 e Regulatory Guide 7/97 -issue draft RG for public comment i 3/98 -issue final RG
  • ESRP Update 2/97 - staff review of draft 6/97 - ACRS/CRGR review (if requested) 8/97 -issue draft for public comment '

1/98 - resolve public comments 8/98 -issue updated ESRP i

8 h

3

PROPOSED NRC SCHEDULE  !

FOR TEMPLATE REVIEW 2/5/97 - NRC receives first draft of template .

1 2/6/97 - 3/7/97 - NRC review / comment on first draft (3 wks) 2/97 and 3/97 - technical meetings (as needed) -

wk of 3/10/97 - meet with BGE on first draft of template (optional!

3/17/97 - 4/4/97 - BGE to revise template (3 wks) i 4/7/97 - 5/2/97 - NRC review / comment on revised template (3 wks) -

- BGE and NRC decide on examples 5/5/97 - 5/16/97 - NRC review / comment on revised template ,

- BGE to work on examples (2 wks)

[

4 .

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

_ a :p 2

PROPOSED NRC SCHEDULE FOR TEMPLATE REVIEW (Continued)

I 5/23/97 - NRC receives draft examples 5/27/97 - 6/13/97 - NRC review / comment on draft examples (3 wks) wk of 6/16/97 - meet with BGE to discuss comments (optional) 6/23/97 - 7/11/97 - BGE to incorporate comments (2 wks) 7/14/97 - NRC review / comment on revised examples 7/25/97 - Complete template and example process r

s t

5 i

_. . _ _ _ _ _ _ _ _ _ - _ _ - _ _ _ _ - _ _ _ _ - - - - - - - - _ _ _ _ _ _ - - . --__--_ - - - _ _ - _ _ - - _ _ _ _ .

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