ML20236X655
| ML20236X655 | |
| Person / Time | |
|---|---|
| Site: | Calvert Cliffs  |
| Issue date: | 07/28/1998 |
| From: | Craig C NRC (Affiliation Not Assigned) |
| To: | Essig T NRC (Affiliation Not Assigned) |
| References | |
| NUDOCS 9808100170 | |
| Download: ML20236X655 (13) | |
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G flp~jff UNITED STATES
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NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20666-0001 6p yfp
+.... Jub 28,1998
/ MEMORANDUM TO: Thomas H. Essig, Acting Chief C eneric issues and Environmental Projects Branch Dnion of Reactor Program Management ,
Office of Nuclear Reactor Regulation )
FROM: Claudia M. Craig, Senior Project Manager Generic issues and Environmental Projects Branch Md M. C C l I
Division of Reactor Program Management Office of Nuclear Reactor Pegulation
SUBJECT:
CALVERT CLIFFS NUCLEAR POWER PLANT (CCNPP) SITE VISIT TO SUPPORT REVIEW OF LICENSE RENEWAL APPLICATION The Nuclear Regulatory Commission (NRC) staff and its contractors, Pacific Northw:ft National )
Laboratory (PNNL), were at the CCNPP during July 7-10,1998, to perform a site visit in support l of the review of the CCNPP license renewal app!ication. The site visit focused on the environmental requirements of license renewal. The teant reviewed the environmental report (ER) submitted by Baltimore Gas and Electric (BGE) and examined how BGE met the requirements of 10 CFR Part 51.
I The team held an introductory meeting with the BGE staff (Attachment 1 is the list of attendees) to discuss the purpose of the visit and the schedule of activities. Following the introductory meeting, tho team went on an extensive site tour. The team visited a number of locations at the j CCNPP site, including Old Bay Farm, the sedimentation pond, reclaimed ground under the transmission lines, Lake Davies, Camp Canoy, and the intake structure. The tour familiarized the team with the site and provided an opportunity to discuss general site characteristics and site management activities. After the site tour, the various members of the team met with their BGE counterparts and discussed the BGE application, performed more detailed onsite and offsite tours, and reviewed documentation. Site activities included tours of the intake structure I and effluent discharge points, the sewage treatment facility, the Chesapeake Bay beach area at the CCNPP site, th transmission line corridor, the hydrologic features of the site, and the Chesapeake Bay in the vicinity of the site. Discussions were held regarding the radiological monitoring program, the meteorological monitoring program, and, as discussed in the staff's letter to BGE of May 22,1998, the process BGE used to become aware of any new and significant information. As a result, the staff now has a better understanding of these programs and processes and the information will be helpful in aeveloping the draft plant-specific !
supplement to the ge.:aric environmentalimpact statement. Attachment 2 is a list of BGE documents the team made copies of to support its review. Offsite activities included: a tour of hydiologic features, meetings with the State historic preservation office and the historical trust
- of Maryland, meetings with local planning and zoning officials in the surrounding counties, l meetings with local charities, and visits to local real estate offices.
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- T. Essig -2 July 28, 1998 At the conclusion of the week the staff held an exit meeting (Attachment 3 is a list of attendees).
The staff discussed each of the specific areas reviewed. The staff stated it would review information gathered during the visit regarding radiologicalimpacts, aquatic impacts, terrestrial impacts, archaeological impacts, socioeconomic impacts, and land use impacts and informed BGE that the staff will issue a request for additional information to obtain any additional information needed as a result of the ongoing review. 1 Docket Nos. 50-317, 50-318 Attachments: 1. Entrance Meeting Attendees
- 2. List of Documents {
- 3. Exit Meeting Attendees cc w/atts: See next page J l
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T. E. ?? July 28, 1998 At the conclusion of the week the staff held an exit meeting (Attachment 3 is a list of attendees).
The staff discussed each of the specific areas reviewed. The staff stated it would review information gathered during the visit regarding radiological impacts, aquatic impacts, terrestrial impacts, archaeological impacts, socioeconomic impacts, and land use impacts and informed BGE that the staff will issue a request for additional information to obtain any additional information needed as a result of the ongoing review.
Docket Nos. 50-137,50-318 Attachments: 1. Entrance Meeting Attendees
- 2. List of Documents
- 3. Exit Meeting Attendees cc w/atts: See next page Distribution: See next page DOCUMENT NAME: G:\ CMC 1\SITEREPT OFFICE PM:PGEB (A)SC:PGEB BC:PDLR tA)BC:PGF) OGC QQ NAME hh Mb7 TEssig /[ CGrimeh /Gdf3h r DATE 'l @ 98 '\/d;O f, 1 / 73 /98 }/M/98 7/M/98 OFFICIAL RECORD COPY I
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1-DISTRIBUTION: Mtg. Summary w/Calvert Cliffs Dated _ July-28,_1998-Hard. Copy Central Files I Docket Files Local PDR PUBLIC PGEB r/f -
CCraig MMalloy EMail FMiraglia i JRoe DMatthews CGrimes TEssig THiltz, EDO (Rlli Coordinator) l
'JMoore - !
RWeisman MZobier DMartin, OlG WMcDowell, OlG :
DSolorio . I, KCampbell RJolly JWilson BZaleman
- ADromerick '
LDoerflein, Region I i JStewart, Sr. Resident inspector BBores, Region I CSochor .
' HBrammer CGratton RLatta i
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ENTRANCE MEETING ATTENDEES JULY 7,1998 NAME ORGANIZATION Neil haggedy Baltimore Gas and Electric (BGE)
Brenda Nuse BGE Julea Bradley BGE David Solorio NRC/NRR Karl R. Eser BGE Jim Wilson NRC/NRR Sue Blanton Pacific Northwest National Laboratory (PNNL)
Jeff Ward PNNL Kim Campbell NRC/NRR Rob Jolly . . NRC/NRR Scott Stewart NRC/ Senior Resident inspector Mike Scott PNNL Charles Brandt PNNL Paul Nickens PNNL Lance Vail PNNL B.W. Doroshuk BGE Claudia Craig NRC/NRR Barry Zalcman NRC/NRR Ted Ringger BGE ;
Frank Sears . BGE Greg Barley BGE I John Smith BGE Dickie Horsmon BGE Matt Carr BGE j Rich Stattel BGE )
Dave Furst BGE Chuck Rayburn BGE Jeff O'Neill BGE Mary Ann Parkhurst PNNL John Quinn BGE Evertt Smith BGE Patrick Doran BGE David Austin BGE Becky Harty PNNL Eva Hickey PNNL Paul Hendnckson PNNL L
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Attachment 1 l I
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LIST OF DOCUMENTS Already oubliciv available Radiological Environmental Monitoring Program: 1993,1994,1995,1996,1997 Calvert Cliffs Unit 1 Amendment No. 216 - changes to tecnical specifiestions: Chapter 6,
" Administrative Controls",6.5 " Programs and Manuals," and 6.5.1, "Offsite Dose Calculation Manual (ODCM)"
UFSAR Sections 2.3.7,2.3.8 i
Not vet oubliclv available New and significant information process (copy attached)
OTHER DOCUMENTS (also publicly available)
NPDES permit dated June 16,1994 l Assessment of Thermal Entrainment and Impingement Impacts on Chesapeake Bay, Academy of Natural Sciences,1981 1997 Comprehensive Plan, Calvert County Zoning ordinance and map, Calvert County l
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Attachment 2 i
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BALTIMORE GAS AND ELECTRIC COMPANY New and Significant Information Process For License Renewal Of Calvert Cliffs Nuclear Power Plant INTRODUCTION This paper summarizes the process that Baltimore Gas and Electric Company (BGE) has used to become aware of any new and significant information that might result in Calvert Cliffs Nuclear Power Plant (CCNPP) license-renewal-related impacts being beyond the bounds of the NRC's generic findings presented in the Generic Environmental Impact Statement (GEIS) and codified by 10 CFR Part 51. The objective is to illustrate the process sufficiently to support the conclusion that BGE is aware of no new and significant information relative to CCNPP that would negate the NRC's findings.
HACKGROUND The U.S. Nuclear Regulatory Commission (NRC) licenses the operation of domestic nuclear power plants and provides for license renewal, requiring a license renewal application to include an environmental report.' U.S. Nuclear Regulatory Commissis i regulations,10 CFR Part 51, prescribe the environmental report content and identify the specific analyses the applicant must perform. In an effort to streamline the environmental review, the NRC has resolved most of the environmental issues generically and limits an e ,;,licant's review to the remainder.
While the NRC regulations do not require an applicant's environmental report to contain analyses of the impacts of those environmental issues that have been generically resolved (10 CFR 51.53(c)(3)(i)), the NRC regulations do require an applicant to identify any new and significant information of which the applicant is aware (10 CFR 51.53(c)(3)(iv)). The purpose of this requirement is to alert the NRC staff to such information so that the NRC staff can determine whether to seek the Commission's approval to waive or suspend application of the rule with respect to the affected generic analysis. The NRC's draft environmental standard review plan suggest that a license renewal applicant should have a process to become aware of new and significant information. NUREG-1555 (Draft) at p. B.3. The NRC has explicitly indicated, however, that an applicant is not required to perform a site-specific validation of GEIS conclusions. NUREG-1529 at p.C9-14.
Neither the regulation nor NUREG-1555 define the phrase "new and significant information."
Therefore, to determine what information, if any, is new and significant, BGE established working definitions of"new" and "significant" in the manner discussed below.
"New Information" In establishing a working definition of"new information," BGE sought answecs to the following questions:
- Would CCNPP license renewal cause an environmental impact that Table B-1 and the GEIS e
did not address?
' Title 10, Code of Federal Regulations, Part $4, Section 54.23 (10 CFR 54.23).
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BALTIMORE GAS AND ELECTRIC COMPANY Are any of the Table B-1 Dndings or GEIS analyses for Category 1 issues invalid as applied to CCNPP?
e Are any GEIS analyses for Category 2 issues invalid as applied to CCNPP?2 If BGE found the answer to any of these questions to be "yes," then BGE would conclude the information was new information, and BGE would analyze whether it was significant information.
"Significant Information" The National Environmental Policy Act (NEPA) requires federal agencies to evaluate the environmental impact of their activities and authorizes the President's Council on Environmental Quality (CEQ) to establish implementing regulations. The NRC is requiring license rer,ewal applicants to provide the NRC with input, in the form of an environmental report, as part of the NRC process to meet NEPA and CEQ requirements.' Although not binding on independent agencies such as the NRC, CEQ regulations call for federal agencies to prepare environmental impact statements for actions that would significantly affect the environment,' to focus on significant environmental and issues,5 to eliminate from detailed study issues which are not significant. The regulations include a lengthy discussion of what i.:
considered to "significantly cffect the environment." Significance would be determined by considering the context of the action and the intensity, or severity, of the impact (s).7 In establishing a working definition of"significant information," BGE sought the answer to the following question:
- Would the new information be significant within the meaning of the CEQ definition of "significantly affect the environment"?
If the answer to this question would be "yes," then BGE would include the information in the CCNPP license renewal environmental report.
DISCUSSION Baltimore Gas and Electric Company implemented its process to become aware of new and significant information in conjunction with its preparation of the environmental report for CCNPP license renewal.
The development of this environmental review included several integrated elements that are described in the following paragraphs.
A Qualified Investigative Team with knowledge of plant systams, the site environment, plant environmental issues, the NRC environmental review process, and NEPA environmental analysis was formed to conduct the environmental review and develop the er.vironmental report. Baltimore Gas and Electric Company assembled a License Renewal Environments Core Team, comprised ofindividuals who represent the principal BGE organizations that have areas af responsibility encompassing the 2
The GEIS coocludes that aspects of some Category 2 issues do not warrant further analysis.
l ' 10 CFR 51.10.
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- 40 CFR 1502.3.
' 40 CFR 1502.1.
' 40 CFR 1501.7(a)(3).
' 40 CFR 1508.27.
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BALTIMORE GAS AND ELECTRIC COMPANY majority of the NRC license renewal environmental issues. These individuals are described in the following table.
Core Team Member Department Responsibility License Renewal Project Life Cycle License renewal application and Dlrector Management Unit environmental report preparation Water and Natural Resources Environmental Affairs Corporate environmental staff Unit Supervisor Counsel Legal Environmental law Environmental Specialist Chemistry Programs Plant environmental monitoring Mechanical Maintenance Facilities Non-power block operations Supervisor Radiological Specialist Radiological Technical Radwaste, occupational exposure Services management Nuclear Regulatory Analyst Nuclear Regulatory NRC interface, CCNPP docket Matters MDNR representative PPRP director State review of power plant issues and Cumulative Environmental Impact Report Vendor Halliburton NUS Data retrieval and review, pre 7 tion of environmental rarrt The State representative on the Core Team provided BGE with a s i w ..,r receiving input and ;
comments from the State at each stage of the environmental repoa development. In addition to providing the team with NRC environmental regulatory expertise and experience in performing NEPA analyses, the vendor also provided an independent review of plant-related information. The combination of subject expertise, plant-specific, NPC, and NEPA knowledge outlined above was an important key to the development of the environmental report. The Core Team provided a multi-discipline approach to recognition of any potentially new information and its significance.
Site Inspections were performed to identify environmental impact initiators. The GEIS introduces the concept of environmental impact initiators as plant features that could impact the environment. The Core Team conducted several walkdowns of various areas of the plant and the plant site to identify potential impact initiators. This familiarization with the plant and the plant site provided the Core Team with input to direct further investigations, verify existing information, and identify whether additional efforts might be warranted to evaluate new information and its significance.
Record and Document Reviews we.re performed to identify, consolidate, and review CCNPP permits, monitoring activities, repoc, and other environmental records and documents. An environmental operating baseline was estab!ished that identified all permits and responsibilities associated with plant ;
and site environmental activities. These items were reviewed and up-to-date copies of responsive reports were obtained to verify compliance. In addition, a link was established between the license renewal I regulatory requirements, NRC environmental issues for license renewal, GEIS analyses, and information presented in existing BGE environmental submittals to State and Federal agencies.
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j This review also included approximately 350 BGE's Environmental Affairs Demrtment documents of pre- and post-CCNPP construction environmental studies and reports. These records and documents were reviewed by the Core Team for applicability to the NRC !! cense renewal environmental issues or other aspects of the CCNPP environmental report preparation. The past 10 years of monthly discharge monitoring reports were reviewed and a search was made for correspondence regarding notices of non- !
compliance. Correspondence was reviewed to identify any pattern or frequency of violations and exceedances. This effon identified caly random and infrequent violations that were not considered to be !
significant issues. i External documents were also reviewed. Reports and studies conducted by the Maryland Department of Natural Resources Power Plant Research Program (PPRP) were reviewed to identify any CCNPP-related environmental issues tracked by the State and those under current investigation. In 1971, the PPRP was
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established by Maryland law to review and evaluate the potential impacts to Maryland's air, water, land, j and cultural resources from the construction and operation of electric power generating and transmission l systems. The PPRP publishes the results in a biennial cumulative environmental impact report and !
address many of the issues identified by the NRC. The Core Team also identified and reviewed other l CCNPP-specific studies published by the PPRP. )
The Academy of Natural Sciences of Philadelphia Benedict Dtuarine Research Center (A'NSP) has l performed extensive ecological research on Chesapea!; Bay resources for over 25 years. An ANSP bibliographic review was performed to identify studies on Chesapeake Bay resources in the vicinity of CCNPP, as well as those evaluating the CCNPP discharge impacts. Additional literature reviews were conducted to identify studies performed by other research organizations. State and County planning documents were reviewed for input to the socioeconomic issues. The review process for the documents held at BGE's Environmental Affairs Department, the Maryland Department of Natural Resources, and ANSP provided the Core Team with an understanding of CCNPP environmental issues that have been addressed by BGE, as well as the State and other research organizations.
Interviews were conducted with several BGE and BGE vendor staff. Initially, key staff members that had been with the BGE since initial CCNPP start-up were identified as potential se mes for plant information. These key sources represent a " corporate memory" of CCNPP environraental issues. Other interviewees included corporate subject matter experts for environmental topics, systems engineers, and i BGE staff responsible for every environmental compliance report submitted to a regulatorv agency. The Core Team asked each interviewee about their areas of responsibility and about CCNPP environmental issues that they have addressed, as well as for input regarding specific NRC issues related to their area of l' expertise . The interview process and the record- and document-review process were simultaneous and interactive; many interviews identified additional records and documents and many of these such documents helped identify prospective interviewees or new questions for pre t s interviewees.
A CCNPP Docket Review was also performed. Since the Atomic Energy Commission issued a final environmental statement (FES), CCNPP has undergone many structural and operational changes.
Baltimore Gas and Electric Company has submitted documentation regarding plant ci;anges with potential environmental impacts in accordance with NRC regulations. In turn, the NRC has prepared related NEPA documentation (e.g., negative declarations, environmental assessments). In order to be )
able to document that these changes and their related environmental impacts are not new information, the Core Team searched the NRC docket and compiled a list of the CCNPP post-FES NEPA documentation.
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SUMMARY
AND CONCLUSION The multi-disciplinary and integrated approach BGE employed to develop the environmental report not only addresses the plant-specific information required by 10 CFR Part 51, but also established an environmental operating baseline from which the Core Team could evaluate the environmental impacts oflicense renewal. The elements of BGE's environmental review process described in this paper were used to conduct a thorough environmental review that would allow BGE to become aware of any new and significant information. Based on the process described by this paper, BGE concludes that there is no new and significant information that negates the NRC's generic findings codified by 10 CFR Part 51, l
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EXIT MEETING ATTENDEES JULY 10,1998 NAME ORGANIZATION Neil Haggerty Baltimore Gas and Electric (BGE)
Brenda Nuss BGE Chris Earls - BGE Julca Bradley BGE Fred Bower NRC/ Region I David Solorio NRC/NRR Don L. Shaw - BGE Karl R. Eser BGE Melinda Malloy NRC/NRR Jim Wilson NRC/NRR Sue Blanton PNNL Jeff Ward PNNL Kim Campbell NRC/NRR Rob Jolly NRC/NRR Alexander Dromerick NRC/NRR
' Scott Stewart NRC/ Senior Resident inspector Mike Scott PNNL Charles Brandt PNNL Paul Nickens PNNL Lance Vail PNNL R.P Heibel BGE B.W. Doroshuk BGE q Thomas Essig NRC/NRR ;
Claudia Craig NRC/NRR l Barry Zaleman NRC/NRF l u
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i Attachment 3 l I
- i Baltimore Gas & Electric Company cc:
Mr. Joseph H. Walter, Chief Engineer President Public Service Commission of Calvert County Board of Maryland Commissioners Engineering Division 175 Main Street 6 St. Paul Centre Prince Frederick, Md 20678 Baltimore, MD 21202-6806 James P. Bennett, Esquire Kr' sten A. Burger, Esquire Counsel Maryland People's Counsel Baltimore Gas and Electric Compeny 6 St. Paul Centre P.O. Box 1475 Suite 2101 Baltimore, MD 21203 Baltimore, MD 21202-1631
~ Jay E. Silb' erg, Esquire Patricia T. Birnie, Esquire Shaw, Pittman, Potts and Trowbridge Co-Director 2300 N Street, NW Maryland Safe Energy Coalition Washington, DC 20037 P.O. Box 33111 Baltimore, MD 21218 Mr. Thomas N. Pritchett, Director NRM- Mr. Loren F. Donatell Calvert Cliffs Nuclear Power Plant NRC Technical Training Center 1650 Calvert Cliffs Parkway 5700 Brainerd Road Lusby, MD 20657-4702 Chattanooga, TN 37411-4017 Resident inspector Mr. Charles H. Cruse c/o U.C. Nuclear Regulatory Vice President - Nuclear Energy Commission Baltimore Gas and Electric Company P.O. Box 287 Calvert Cliffs Nuclear Power Plant St. Leonard, MD 20685 1650 Calvert Cliffs Parkway Lusby, MD 20657-4702 Mr. Richard I. McLean, Manager Nuclear Programs Mr. David Lewis Power Plant Research Program Shaw, Pittman, Potts, and Trowbridge Maryland Dept. of Natural Resources 2300 N _ Street, NW Tawes State Office Building, B3 Washington, DC 20037 Annapolis, MD 21401 Doug Walters Regional Administrator, Region i Nuclear Energy Institute U.S. Nuclear Regulatory Commission 17761 Street, N.W.
475 Allendale Road Suite 300 King of Prussia, PA 19406 Washigtsen, DC 20006 Bart Doroshuk Baltimore Gas and Electric Company Calvert Cliffs Nuclear Power Plant 1650 Calvert Cliffs Parkway
- Lusby, MD 20657-4702 l