ML20148H221

Summary of 970519 Meeting W/Bge in Rockville,Md to Discuss License Renewal Er Template Process.List of Attendees Encl

ML20148H221
Person / Time
Site:	Calvert Cliffs
Issue date:	05/27/1997
From:	Craig C NRC (Affiliation Not Assigned)
To:	Matthews D NRC (Affiliation Not Assigned)
References
NUDOCS 9706090282
Download: ML20148H221 (6)

Text

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nog p UNITED STATES j

g NUCLEAR REGULATORY COMMISSION

• WASHINGTON, D.C. 20666-0001 I

• • • +* May 27, 1997 i ,

MEMORANDUM TO: David B. Matthews, Chief

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. Generic Issues and Environmental  :

l Projects Branch. ')

L Division of Reactor Program Management l Office of Nuclear Reactor Regulation i FROM: Claudia M. Craig, Senior Project Manage da, ,

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Generic Issues and Environmental l Projects Branch i

! Division.of Reactor Program Management Office of Nuclear Reactor Regulation *  ;

SUBJECT:

SUMARY OF MEETING WITH BALTIMORE GAS & ELECTRIC (BGE) TO DISCUSS LICENSE RENEWAL ENVIRONMENTAL REPORT (ER)-TEMPLATE PROCESS The subject meeting was held at the Nuclear Regulatory Commission (NRC) offices in Rockville, Maryland on May 19, 1997, _ between representatives of BGE and the NRC staff. 'The purpose of the meeting was for_the staff to provide:

BGE comments on the revised ER template, the four examples of the level of detail of the ER, and to discuss selected issues. 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. l 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, 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 objective that the completed environmental report template outline 'a format and content. such that' if an ER is -submitted whkh follows the template and l contains sufficient information, it is =likely the report 'would be accepted for i review. ,

I The staff and BGE discussed issues'regarding the BGE responses to the-NRC questions and comments and the examples provided by BGE. Discussions included NRC's preference that the specific impacts of alternative energy sources be-assessed separate from the no-action alternative such that a comparison of the alternative energy sources and license renewal may be made. The staff recognizes that as a result of the no-action alternative, replacement power  ;

-will be needed and therefore, alternative energy sources should addressed -!

I under the no-action alternative .as well. Additionally, the no-action I alternative should include decommissioning and termination of the license L impacts. . The staff also agreed that the level of detail in the ER should be i

.such that a comparison can be made between the alternatives and license renewal. A(

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i D. Matthews May 27, 1997 Regarding mitigative measures, the staff agreed with BGE's position that mitigative measures need not be considered for impacts resulting from Category 2 issues that are not applicable to BGE. However, the staff disagreed with BGE on the position that for Category 2 issues that meet certain criteria, such as providing the appropriate Clean Water Act 316 documentation, no ,

mitigative measures need to be considered. The staff recognizes that even I while operating within the bounds of a permit issued by the State under the Clean Water Act, there are impacts and mitigative measures should be considered. If the best available technology is being implemented, there may l be no mitigative measures available, but that needs to be discussed.

Additionally, the staff disagreed with BGE position that mitigative measures l need not be discussed for de minimis impacts. The staff believes that NEPA and CEQ guidance states that even for impacts that by themselves would not be considered significant, mitigative measures need to be considered. The level of detail for addressing mitigative measures, however, should be commensurate with the level of impact.  ;

i The staff agreer that BGE is not required to include further analyses in the  !

ER for Category 1 tssues. However, in fulfilling our NEPA responsibilities, l NRC would rely, in part, on information and representations made by the applicant. To do so, the staff would likely determine whether the applicant has objective evidence to support a determination under 10 CFR 51.53(c)(3)(iv) that it is not aware of new and significant information. The objective evidence may be in the form of a systematic process to ensure that new and significant information may be identified by an applicant. The staff would review the process to gain confidence in the completeness of the information provided in the ER. Although the staff did not review the basis for the BGE statement addressing 10 CFR 51.53(c)(3)(iv) fer new and significant information as part of the template effort, the staff would find the BGE proposed language to be acceptable.

The staff agrees that BGE need only address transportation impacts on public services for license renewal refurbishment activities. A possible rule modification may add a requirement to address transportation impacts on public services for the license renewal term. The Generic Environmental Impact Statement (GEIS) supports this rule modification. It was stated that NEI has identified several areas where the Part 51 rule and GEIS appear inconsistent.

Staff stated they would like to have dialogue with industry to identify those areas such that a revision to the rule would capture all of them.

The staff understands BGE's unique transmission line situation and at this time considers BGE's treatment of electric shock to be consistent with the rule.

The staff informed BGE of its intent to initiate a generic transportation analysis to address the generic and cumulative environmental impacts of transportation operation in the vicinity of a high-level waste repository. It is envisioned that this generic analysis could be referenced by future license renewal applicants. It is hoped that information will be publicly available in the next several months.

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t D. Matthews May 27, 1997  ;

l The staff also discussed comments on the examples BGE provided to demonstrate  ;

the level of detail that will appear in the ER. Based on the-examples  !

reviewed, the ER appears to be of sufficient level of detail and addresses the  !

, appropriate issues such that it is likely it would be accepted for review. i i The staff stated requests for additional information based on technical questions during the ER review would be generated.  ;

l' A senior management meeting has been scheduled for June 5, 1997, to inform '

upper levels ~ of BGE and NRR management of the ER template effort and the resul ts. After that meeting, it is not anticipated that further interactions  :

between the staff and BGE will be needed as part of the template process.  ;

Docket Nos. 50-317, 50-318

Attachment:

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l D. Matthews -3_ May 27, 1997

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The staff also discussed comments on the examples BGE provided to demonstrate the level of detail that will appear in the ER. Based on the examples reviewed, the ER appears to be of sufficient level of detail and addresses the appropriate issues such that it is likely it would be accepted for review.

The staff stated requests for additional information based on technical questions during the ER review would be generated.

i A senior management meeting has been scheduled for June 5,1997, to inform

! upper levels of BGE and NRR management of the ER template effort and the i

results. After that meeting, it is not anticipated that further interactions

, between the staff and BGE will be needed as part of the template process. i l

Docket Nos. 50-317, 50-318 t

Attachment:

As stated  :

cc w/att: See next page ,

Q1SIRIBUTION:w/ attachment:

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/ Central File i PUBLIC i PGEB R/F RArchitzel CCraig E-Mail SCollins/FMiraglia RZimmerman TMartin MSlosson PTKuo SFlanders DMatthews BZalcman l LChandler, OGC JMoore, OGC GHoller, OGC CMarco, OGC DCleary, RES JWilson SBajwa ADromerick DOCUMENT NAME: G:\ CMC 1\5 19 97. MIN To seesive e oopy of this document,inecate liithebs: C" = Copy without ett d vnent/ enclosure *E" = Copy with ettschment/ enclosure n = w. y o (x{ j / )

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NAME CCrakgs k er& Witwel DMatt kqMs l l DATE 5/J)/97 5/u /97 5/ff97 OFFICIAL RECORD COPY l

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I BGE / NRC MEETING l i

ENVIRONMENTAL REPORT TEMPLATE PROCESS MAY 19, 1997 l

l MEETING PARTICIPANTS i

i NAME ORGANIZATION -

Claudia Craig NRC/NRR/PGEB  !

Barth W. Doroshuk BGE ,

Julea Bradley. HNUS/BGE l

( - Robert Tucker BGE  ;

j Jim Bennett BGE i Scott Flanders-NRC/NRR/PDLR l Frank Akstulewicz NRC/NRR/PGEB l l Jim Wilson NRC/NRR/PGEB i

! ' Don Cleary NRC/RES/DRA  :

l - Gene Holler NRC/0GC i

, Catherine Marco NRC/0GC i l Barry Zalcman_ NRC/NRR/PGEB- l Steve Mixon NUS Information Services i Tricia Heroux for EPRI t-k i

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ATTACHMENT 1

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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 i Baltimore, MD 21202-6806 O. A. Brune, Esquire .

General Counsel Kristen A. Burger, Esquire  !

Baltimore Gas and Electric Company Maryland People's Counsel l P.O. Box 1475 6 St. Paul Centre '

Baltimore, MD 21203 Suite 2102 Baltimore, MD 21202-1631 l Jay E. Silberg, Esquire l Shaw, Pittman, Potts, and Trowbridge Patricia T. Birnie, Esquire l 2300 N Street, NW Co-Director Washington, DC 20037 Maryland Safe Energy Coalition P.O. Box 33111 Mr. Thomas N. Pritchett, 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 l Resident Inspector i 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 j 580 Taylor Avenue Lusby, MD 20657-47027 Tawes State Office Building, B3 Annapolis, MD 21401 Mr. Doug Walters Nuclear Energy Institute Regional Administrator, Region I 1776 I Street, NW U.S. Nuclear Regulatory Commission Suite 400 475 Allendale Road Washington, DC 20006-3708 King of Prussia, PA 19406 l