ML20237B773

Comment on Relicensing of Calvert Cliffs Nuclear Power Plants

ML20237B773
Person / Time
Site:	Calvert Cliffs
Issue date:	08/06/1998
From:	Mclean R MARYLAND, STATE OF
To:	NRC
References
FRN-63FR31813 63FR31813-00003, 63FR31813-3, NUDOCS 9808190246
Download: ML20237B773 (3)

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John R. Griffin cov,roor Maryland Department of Natural Resources s,cmary POWER PLANT ASSESSMENT DIVISION carolyn o. Davi, Tawes State Office Building, B-3 D'Puty Secretary Annapolis, Maryland 21401-2397

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August 6,1998 Chief Rules and Directives Branch l j

Division of Administrative Sery ces Mailstop T-6 D 59 U.S. Nuclear Regulatory Commission Washington, DC 20555-0001

SUBJECT:

State of Maryland's Comments on the Environmental Scoping Process for the Supplement to the GEIS for relicensing Baltimore Gas and Electric Company's Calvert Cliffs l

Nuclear Power Plant, Units 1 and 2, Docket Nos. 50-317 and 50-318. ,

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Dear Secretary of the Nuclear Regulatory Commission:

The State of Maryland Power Plant Research Program (PPRP) has participated with Baltimore Gas and Electric Company (BGE) in the development ofit's relicensing application for Calvert Cliffs Nuclear Power Plant (CCNPP) over the last several years. Acting as point-of-contact for BGE, the NRC, and the other Maryland agencies, PPRP's activities focused on ensuring that the State's interests and concerns were addressed in the application. PPRP will maintain this role through the duration of proceedings for the relicensing of CCNPP. Therefore, on behalf of the State of Maryland, we offer the following comments on the environmental scoping process for the NRC staff's preparation of the supplement to the Gels in response to "TE's application to relicense CCNPP Units 1 and 2.

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Nuclear Regulatory Commission August 6.1998 Page 2 During BGE's development ofit's application for the renewal of the two CCNPP operating licenses (DPR-53 and DPR-69), PPRP was provided several opportunities to assist BGE in ensuring Maryland concerns were addressed. In consultation with other state agencies responsible for protecting Maryland's resources we provided consolidated comments to BGE which were reflected in the final version of the ER received by the NRC on April 10,1998. The State is satisfied that the ER addresses all of our concerns at this time. In addition, we have reviewed the NRC's notice ofintent (~NOI) to prepare the SEIS published in the Federal Register on June 10,1998 and attended the July 9,1998 scoping meeting for the SEIS. We believe that the scope of the SEIS as indicated at the scoping meeting captures Maryland's environmental concerns and we offer no additional comment on issues that need to be addressed in the SEIS at this time.

Maryland, however, takes this opportunity to reiterate its position regarding the management and disposal of high level radioactive waste (llLRW). This position was documented in correspondence and comment presented during the 1992 licensing proceedings (NRC Docket No 72-8 (50-317/318) for the CCNPP independent spent fuel storage installation (ISFSI), in our March 1992 comments on the NRC's Generic EnvironmentalImpact Statement (GE/S)for License Renewal ofNuclear Plants (NUREG-1437), and our July 1996 comments on the NRC's final rule to amend 10 CFR Part 51.

The issue of HLRW disposal - and its potential impact on the future operating life of Maryland's only nuclear power plant - remains an open issue and an important concern to the State. As the NRC is aware, the State of Mary!and participated extensively in the licensing of CCNPP's ISFSI in 1992 that resulted in a 1, cense for at-reactor storage of spent fuel for 20 years.

Because a federal (DOE) repository was not available to accept CCNPP's spent fuel at that time, the licensing of the ISFSI was an appiapriate action and was supported by the State. During the ISFSI proceedings, the State expressed its concern that CCNPP not become a pennanent repository for spent fuel-we regarded the twenty-year license as a short-term solution to the longer term problem of nuclear waste management It is Maryland's position that the federal i government has a legal responsibility to proceed as expeditiously as possible toward resolving outstanding issues related to the interim and final disposition of spent fuel and other HLRW. To this end, the State is a participant in litigation to require DOE to comply with the requirements of ,

the Nuclear Waste Policy Act.

We understand the NRC's rationale for it's determination that IILRW is a generic, l Category i issue, and that it should be decoupled from DOE's time frame for developing a IILRW repository so that the relicensing process could proceed. The State provided comments on the GEIS in 1992, and on the final rule to amend 10 CFR 51, that concurred with the NRC's  :

reliance on available environmental analyses of potential IILRW impacts such as the Waste l I

Confidence Rule (10 CFR 51.23), and Uranium Fuel Cycle Environmental Data (10 CFR 51.51, l

g 8 Nuclear Regulatory Commission August 6,1998 { '

Page 3 Table S-3), for providing background information to evaluate potential impacts of HLRW at-reactor storage and agreed with the classification of HLRW as a Category 1 issue. At the time, this determination seemed reasonable.

Ilowever, given the current status of progress toward the development of the DOE HLRW repository, and the ever-emerging uncertainties associated with the project, we are not as confident with this determination as we had been previously. Because of this increased uncertainty, we believe that it is particularly important to evaluate llLRW issues every 10 years as required in the final rule to amend 10 CFR 51. In addition, if during the course of developing the SEIS and evaluating the license renewal alternatives it appears that HLRW may not be j disposed ofin the DOE-constructed faci y, the State would view this development as new and i significant information and reserves the ."ght to request that disposal of HLRW be changed from a Category I to a Category 2 issue.

The State of Maryland appreciates the opportunity to participate fully in the license renewal process for Calvert Cliffs and we look forward to further participation in the NRC's l

development of the SEIS.

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Richard I. McLean Y I Manager, Nuclear Programs RIM:rd l

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