ML23118A221
| ML23118A221 | |
| Person / Time | |
|---|---|
| Issue date: | 05/02/2023 |
| From: | Tanya Hood Reactor Decommissioning Branch |
| To: | |
| Hood T | |
| References | |
| Download: ML23118A221 (9) | |
Text
Lessons Learned:
Environmental Review of PSDARs and LTPs Decommissioning Lessons Learned Workshop May 2, 2023
PSDAR Environmental Review
- The regulation at 10 CFR 50.82(a)(4)(i) states, in part, that the post-shutdown decommissioning activities report (PSDAR) must contain a discussion that provides the reasons for concluding that the environmental impacts associated with site-specific decommissioning activities will be bounded by appropriate previously issued environmental impact statements
- The regulation at 10 CFR 50.82(a)(6) states, in part, that licensees shall not perform any decommissioning activities that result in significant environmental impacts not previously reviewed 2
PSDAR Environmental Review
- NUREG-0586, Final Generic Environmental Impact Statement on Decommissioning of Nuclear Facilities, (Decommissioning GEIS)
- Identifies activities that can be bounded by the generic evaluations in the Decommissioning GEIS
- Identifies activities that could exceed generic environmental impacts and require site-specific analysis:
- Threatened and Endangered Species
- Land use involving offsite areas to support decommissioning activities
- Aquatic ecology for activities beyond the operational area
- Terrestrial ecology for activities beyond the operational area
- Cultural and Historical Resources for activities beyond the operational area 3
- Cultural, Historic, and Archeological Resources
- Consideration of the facility itself being eligible for inclusion on the National Register of Historic Places
- Endangered Species Act (ESA)
- Compliance with existing biological opinions during decommissioning
- Consultations necessary to obtain take authorization under ESA Section 7 4
PSDAR Lessons Learned
- Licensees may review previous PSDAR RAIs to determine appropriate information and data to provide in initial submittals
- Contact and consult with the state historic preservation officer
- License renewal supplemental environmental impact statements do not reach conclusions with respect to generic decommissioning issues identified in the decommissioning GEIS 5
PSDAR Lessons Learned
- Licensees may request that NRC initiate ESA Section 7 consultation with the Services to address effects to listed species and critical habitats.
- This ensures that any take is authorized under a biological opinion.
- Most already-existing biological opinions for operating reactors do not address decommissioning impacts.
- Consultation may be appropriate to revise existing biological opinions to address decommissioning and remove or modify terms and conditions that no longer apply due to plant shut down.
6
License Termination Plan (LTP)
Environmental Review
- 10 CFR 50.82 (a)(9)(ii) - License Termination Plan must include a supplement to the environmental report, pursuant to § 51.53, describing any new information or significant environmental change associated with the licensee's proposed termination activities
- NUREG-0586, Final Generic Environmental Impact Statement on Decommissioning of Nuclear Facilities, (Decommissioning GEIS) 7
LTP Environmental Review Areas requiring Areas bounded by GEIS site specific analysis
- Land use (on-site)
- Off-site land use
- Water use and quality (Surface
- Ecological resources (activities and Groundwater) beyond operational area)
- Air quality
- Cultural and Historic resources
- Aquatic and Terrestrial Ecology (activities beyond operational
- Public and Occupational Health area)
(Radiological)
- Threatened and Endangered
- Socioeconomics Species
- Cultural and Historic Resources
- Aesthetics
- Noise
- Transportation 8
LTP Lessons Learned
- Radiological and Non-radiological (solid and hazardous) waste
- Impacts from disposal on the capacity of receiving waste management facilities
- Cumulative Impacts
- Characterization of affected environment
- Provide most up-to-date information
- Including most recent NEPA document (e.g. license renewal EIS)
- Consultation - Early engagement with State Historic Preservation Officer to support NHPA Section 106 review 9