ML20205N300
| ML20205N300 | |
| Person / Time | |
|---|---|
| Site: | 07003089 |
| Issue date: | 04/14/1999 |
| From: | Bryce A NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
| To: | Pierson R NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
| References | |
| NUDOCS 9904160232 | |
| Download: ML20205N300 (13) | |
Text
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,# April 14, 1999 MEMORANDUM TO: Robert C. Pierson, Chief Special Projects Branch Division of Fuel Cycle Safety and Safeguards, NMSS THRU: Melanie A. Galloway, Section Chief Enrichment Section Special Projects Branch /q,g- hr Division of Fuel Cycle Safety and Safeguards, NMSS 1
I FROM: Amy L. Bryce .
Enrichment Section Special Projects Branch i Division of Fuel Cycle Safety j and Safeguards, NMSS
SUBJECT:
MEETING
SUMMARY
FOR USEC NRC AVLIS ENVIRONMENTAL MEETING ON MARCH 17,1999 On March 17,1999, representatives from the U.S. Nuclear Regulatory Commission (NRC) and i United States Enrichment Corporation (USEC) attended a public meeting at NRC Headquarters in Rockville, Maryland. The purpose of the meeting was to discuss environmentalissues related to USEC's potentiallicense application for the Atomic Vapor Laser Isotope Separation (AVLIS) Facility. The meeting attendance list and NRC slides are attached.
The major points of discussion were:
Environmental Justice. Area for Evaluatina Impacts. and Socioeconomics The Office of Nuclear Material Safety and Safeguards (NMSS) issued Policy and Procedure (P&P) Letter 1-50 as interim guidance on environmental justice (EJ) in 1995. NMSS planned to revise the P&P Letter when the Council on Environmental Quality (CEO) issued final EJ guidance. The CEO issued final guidance in 1998, and NMSS is in the process of revising P&P Letter 1-50.
USEC requested clarification on the P&P Letter guidance for the assessment area to determine if regional demographic data support further EJ analysis. The 1995 P&P Letter recommends an assessment radius of 0.56 or 4 miles for a facility located in urban or rural areas, respectively; however, the P&P Letter further states that the geographic scale for the assessment irea should be commensurate with the potentialimpact area. NRC staff informed USEC that the revised NMSS guidance recommends the assessment area be consistent with the impact area and include a sample of the surrounding population, e.g., several block groups or a census tract.
NRC and USEC discussed the definition of an impact and the appropriate area of assessment for any impact. NRC and USEC similarly defined an impact as a change in the status quo that ,
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9904160232 990414 .I PDR ADOCK 07003009 i
2 results from an action. NRC staff indicated that it may be appropriate for USEC to analyze impacts over an assessment area that encompasses all impacts or to establish a unique assessment area for each impact. Staff emphasized that although the NRC can provide some guidance, NRC cannot make decisions for USEC.
The NRC addressed socioeconomics, specifically: If USEC constructs AVLIS several states away from the enrichment plants located in Paducah, Kentucky, and Portsmouth, Ohio, does USEC's Environmental Report (ER) have to evaluate economic impacts to Paducah and Portsmouth as part of EJ7 The NRC stated that in the event that the economic impacts to Paducah and Portsmouth are far removed from the general area of assessment, this impact would be evaluated as part of the ER, but not analyzed under EJ. This interpretation follows a recommendation from the NRC's Office of General Counsel where proximity is required for an EJ analyses.
Environmental Impact Statement (EIS)
NRC staff described the current status of planning the EIS for AVLIS and placing a contractor to assist with preparing the EIS. Amy Bryce and Ted Bowling were identified as the points of contact on environmental matters for the NRC and USEC, respectively. i The NRC outlined how the timing for announcing USEC's site selection could impact NRC's l procurement process to place a contractor to assist with the EIS. NRC expects to begin l hearing oral presentations from prospective offerors at the beginning of April 1999. If USEC l announces a site before the presentations are complete, offerors who made presentations before the site location was publicly known would have grounds for a protest. A protest could delay contrador placement substantially. USEC indicated that it would coordinate the announcement with the NRC to the degree possible; USEC does not anticipate announcing the site until June 1999.
USEC has not announced if it will co-locate pre- and post-enrichment processes with the AVLIS facility. The NRC noted that if the processes were not co-located the impacts of pre- and post-enrichment processing would still be considered as part of the EIS.
USEC's ER The NRC considers development of the EIS critical path for the licensing process. Because the EIS uses information submitted in USEC's ER, the NRC expects that the quality of the ER will determine the number of requests for additionalinformation (RAls) from the NRC. Moreover, if USEC's response time to an RAI exceeds 20 business days, USEC's response becomes critical path for developing the EIS. To aid in the development of a high quality ER ana to minimize the number of RAls, the NRC suggested that USEC take advantage of consultation with NRC to the extent possible. USEC committed to full coordination to avoid surprises that have the potential to delay the EIS.
USEC currently plans to submit the ER with the license application. NRC described the advantages of submitting the ER before the license application and suggested that USEC consider submitting portions of the ER before the license application. USEC agreed to evaluate this further and suggested that this question be explicitly addressed at a future meeting. NRC requested that USEC submit electronic files (including data files).
3 USEC has prepared a detailed outline of the ER and has written portions that do not depend on site selection or process design. However, because the design and site have not been selected, the outline is fluid. To the extent possible, USEC plans to use existing data but is also planning for data collection as necessary. USEC has begun limited data collection such as the impact AVLIS may have on local employment.
For preparation of the ER, USEC is following the outline and guidance that the NRC provided in a letter from R. Pierson to R. Wcolley on June 23,1998. USEC commented that NRC's guidance lacks detail, with the exception of draf t NUREG-1555, " Environmental Standard Review Plan." Draft NUREG-1555 was developed by the Office of Nuclear Reactor Regulation for licensing actions related to nuclear power plants. USEC believes that draf t NUREG-1555 may require extraneous information for the lmpacts from its facility, particularly as these impacts relate to water use. NRC prefers to evaluate USEC's concern when additional information on USEC's site and facility is available.
USEC plans to use 1990 census data in its ER but is considering other sources of data. USEC has not formally evaluated how the year 2000 census may affect the ER. NRC indicated that if the regional population changes, USEC likely will have to supplement its ER.
USEC was not prepared to discuss the ER in detail prior to the Apnl 1,1999, management meeting.
AVLIS Standard Review Plan NRC provided USEC with a copy of the AVLIS Standard Review Plan (SRP) at the meeting.
USEC inquired if there were major differences between the AVLIS SRP and the SRP for fuel fabrication facilities. NRC stated that some differences did exist. For example, the NRC removed guidance on the National Environmental Policy Act process from the AVLIS SRP.
USEC expressed a high level of interest in the NRC finalization of regulatory requirements by which the AVLIS facility will be licensed, i.e., as related to 10 CFR Part 70 revisions. NRC informed the USEC representatives that they should use the AVLIS SRP as the basis for developing the AVLIS licensing submittal and that any changes made to the AVLIS SRP are not expected to have a major impact on the licensing of this facility. NRC indicated that it would have a much better understanding of any anticipated changes by the summer of 1999.
Docket 70-3089 Attachments: As stated cc: R. Woolley, USEC
, Aprillj, 1%9 USEC has prepared a detailed outline of the ER and has written portions that do not depend on site selection or process design. However, because the design and site have not been selected, the outline is fluid. To the extent possible, USEC plans to use existing data but is also planning for data collection as necessary. USEC has begun limited data collection such as the impact AVLIS may have on local employment.
For preparation of the ER, USEC is following the outline and guidance that the NRC provided in a letter from R. Pierson to R. Woolley on June 23,1998. USEC commented that NRC's ,
guidance lacks detail, with the exception of draft NUREG-1555," Environmental Standard I Review Plan." Draft NUREG-1555 was developed by the Office of Nuclear Reactor Regulation for licensing actions related to nuclear power plants. USEC believes that draft NUREG-1555 j may require extraneous information for the impacts from its facility, particularly as these impacts relate to water use. NRC prefers to evaluate USEC's concern when additional information on USEC's site and facility is available.
USEC plans to use 1990 census data in its ER but is considering other sources of data. USEC has not formally evaluated how the year 2000 census may affect the ER. NRC indicated that if the regional population changes, USEC likely will have to supplement its ER.
USEC was not prepared to discuss the ER in detail prior to the April 1,1999, management meeting.
AVLIS Standard Review Plan NRC provided USEC with a copy of the AVLIS Standard Review Plan (SRP) at the meeting.
USEC inquired if there were major differences between the AVLIS SRP and Licensing's SRP for fuel fabrication facilities. NRC stated that some differences did exist. For example, the NRC removed guidance on the National Environmental Policy Act process from the AVLIS ,
SRP.
USEC expressed a high level of interest in the NRC finalization of regulatory requirements by l which the AVLIS facility will be licensed, i.e., as related to 10 CFR Part 70 revisions. NRC informed the USEC representatives that they should use the AVLIS SRP as the basis for developing the AVLIS licensing submittal and that any changes made are not expected to have a major impact on the licensing of this facility. NRC indicated that it would have a much better understanding of any anticipated changes by the summer of 1999.
Docket 70-3089 Attachments: As stated cc: R. Woolley, USEC Distribution:
- NRC File Center PUBLIC NMSS r/f FCSS r/f SPB r/f Dockg 70-3089 G
- \u _er. sum.wpd OFC SPB C SPR E SPBj _
SPB b NAME ABryce:al k JDavis b hk bhy DATE 4/6/99 4 / u /99 4/h/99 4/h/99 C = COVER E = COVER & ENCLOSURE N = NO COPY OFFICIAL RECORD COPY l
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USEC NRC AVLIS ENVIRONMENTAL MEETING ATTENDANCE LIST March 17,1999 NAME AFFILIATlON PHONE e-MAIL
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. .. l USEC NRC AVLIS Environmental Meeting 1
Enrichment Section Special Projects Branch U.S. Nuclear Regulatory Commission March 17,1999 Environmental Justice (EJ)
= NMSS Interim Guidance: April 1995
= CEQ Final Guidance: December 1997
= NMSS Revised Guidance: In preparation l
- Changes reflect CEQ final guidance
- Expected to go to the Commission Spring 1999 uncauu ,
Socioeconomic Issues
_ . _ . ,-._.,-____m. . , - . _ _._,. _ ._ _ _,_.
Hypothetical Analysis .
= AVLIS facility sited in Boise, ID
= Economic impact on communities in Paducah and Portsmouth Socioeconomic Issues
- . . . , , , . - . . . . . . . . - . ~ - - - . , . . ~ - - . _ - , . . . _ , - ~
NRC Recommended Approach :
= The impact is analyzed as part of the EIS BUT
= Is NOT analyzed under EJ (. lack of proximity) 1 l
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EIS I
= EIS considered critical path to meet j 18 month schedule. i l
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l EIS Planning '
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1 Contractor Placement 1
a Request For Proposals closes March 18,1999
= NRC begins reviewing offerors April 5,1999 i
! = RFP assumes AVLIS site location TBD 1
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EIS Schedule
. . . . _ . ~ . . . . . . . . .. -
Planning
= Start pre-EIS work 6 months prior to receipt of application (~ September 1999)
- Public participation plan
- Publicly available information
- Agency Coordination j
EIS Schedule Preparation
= Start EIS work upon receipt of application
- Preparation of Draft EIS (~10 months) )
- Public Comment Period (~3 months)
Preparation of Final EIS (~4 months)
Total prep time: 17 months plus 1 MONTH FLOAT
EIS Uncertainties
- - .. - - , , . . . . . ~ .
License
- = Co-located Site
- Scope of EIS (?)
- Black-box processes
= Site Location
- Potential affect on NRC contractor procurement ,
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EIS Uncertainties i
, _ , _.~ . . . . . . . _ . . _ _ _ _ , . . . . . - _ _ . ~ _ - _ _ _ _ _ _
Environmental Report (ER) )
l = Requests for Additional Information (RAIs) l l
- Minimum Number of RAls (< or = 2)
- High quality ER
- Referenced and supported
- Complete information
- Consultation (10 CFR 51.40)
Timeliness of RAls
i EIS Uncertainties Environmental Report (ER)
= A poor quality ER will DELAY the EIS
- NRC returns application and does not start the safety i CValuation l
- Increased number of follow-up RAls
.