ML24313A101
| ML24313A101 | |
| Person / Time | |
|---|---|
| Site: | Peach Bottom  |
| Issue date: | 11/13/2024 |
| From: | Kevin Folk NRC/NMSS/DREFS/EPMB1 |
| To: | Wilson C Constellation Energy Company |
| References | |
| EPID 2024-SLE-0003 | |
| Download: ML24313A101 (1) | |
Text
UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 Christopher D. Wilson Director, License Renewal Constellation Energy Generation, LLC 200 Exelon Way Kennett Square, PA 19348
SUBJECT:
PEACH BOTTOM NUCLEAR PLANT, UNITS 2 AND 3 - LICENSE RENEWAL REGULATORY AUDIT REGARDING THE ENVIRONMENTAL REVIEW OF THE SUBSEQUENT LICENSE RENEWAL APPLICATION (EPID NUMBER: L-2024-SLE-0003) (DOCKET NUMBERS: 50-0277 AND 50-0278)
Dear Christopher D. Wilson:
By letter dated September 6, 2024, (Agencywide Documents Access and Management System (ADAMS) ML24221A258), the U.S. Nuclear Regulatory Commission (NRC) staff responded to a request from Constellation Energy Generation, LLC for the NRC staff to provide a plan for completing the environmental review for the Peach Bottom subsequent Incense renewal application and for restoring the end dates for the subsequent renewed licenses. The response provided information regarding the staffs plan for completing the required regulatory activities subsequent to the NRCs issuance of a final rule (89 FR 64166) on August 6, 2024 revising its regulations in Part 51 of Title 10 of the Code of Federal Regulations, Environmental Protection Regulations for Domestic Licensing and Related Regulatory Functions and supporting NUREG-1437, Revision 2, Generic Environmental Impact Statement for License Renewal of Nuclear Plants (ML24087A133).
The NRC staff has initiated a supplemental environmental review. A virtual environmental audit will be conducted the week of November 18, 2024, by the NRC staff (see Enclosure 1). As necessary, the NRC will request any in-person breakouts following the virtual audit.
To the extent possible, the NRC staff requests the information identified in the Environmental Audit and Information Needs list (Enclosure 2) be made available on the Peach Bottom online reference portal prior to the audit. A draft schedule of tours and meetings is also provided in this enclosure.
November 13, 2024
2 C. Wilson If you have any questions, please contact me via email at Kevin.Folk@nrc.gov.
Sincerely, Kevin T. Folk Senior Environmental Project Manager Environmental Project Management Branch 1 Division of Rulemaking, Environmental, and Financial Support Office of Nuclear Material Safety and Safeguards Docket Nos. 50-0277 and 50-0278
Enclosures:
As stated Signed by Folk, Kevin on 11/13/24
ML24313A101 OFFICE NE/PM:EPMB1 LA:REFS BC:EPMB1 NE/PM:EPMB1 NAME KFolk AWalker-Smith SKoenick KFolk DATE 11/8/2024 11/8/2024 11/8/2024 11/13/2024 Audit Plan License Renewal Environmental Review Peach Bottom Atomic Power Station, Units 2 and 3 November 2024
2 License Renewal Environmental Review Peach Bottom Nuclear Plant, Units 2 and 3
1. Background
On August 6, 2024, the U.S. Nuclear Regulatory Commission (NRC) published a final rule (89 FR 64166) revising its environmental protection regulation, Title 10 of the Code of Federal Regulations (10 CFR) Part 51, Environmental protection regulations for domestic licensing and related regulatory functions. Specifically, the final rule updates the potential environmental impacts associated with the renewal of an operating license for a nuclear power plant for up to an additional 20 years, which could either be an initial license renewal or subsequent license renewal (SLR). The updates to Table B-1 are supported by the revised NUREG-1437, Revision 2, Generic Environmental Impact Statement for License Renewal of Nuclear Plants (LR GEIS)
(Agencywide Documents Access and Management System [ADAMS] package ML24087A133).
The final rule became effective on September 5, 2024, and staff must consider the new and modified issues, as applicable, as well as any new and significant information for Category 1 issues.
By letter dated September 6, 2024 (ML24221A258), the U.S. Nuclear Regulatory Commission (NRC) staff provided a response to a request from Constellation Energy Generation, LLC for NRCs plans for completing the SLR and related regulatory activities for Peach Bottom Atomic Power Station, Units 2 and 3 (Peach Bottom) following publication of the referenced final rule and in conformance with the direction provided by the Commission in CLI-22-04 (ML22055A557).
Therefore, the NRC staff is conducting a supplemental environmental audit of the Peach Bottom site to improve understanding, to verify information, and to evaluate applicable pertinent new or revised information for docketing.
2.
Environmental Audit Bases License renewal requirements for environmental reports are specified in 10 CFR 51, Postconstruction environmental reports. As specified by 10 CFR 51.53(c): Operating license renewal stage, (1) Each applicant for renewal of a license to operate a nuclear power plant under Part 54 of this chapter shall submit with its application a separate document entitled "Applicant's Environmental ReportOperating License Renewal Stage." Review guidance for the staff is provided in NUREG-1555, Supplement 1, Revision 2, Standard Review Plans for Environmental Reviews for Nuclear Power Plants: Supplement 1 - Operating License Renewal.
The NRC staff is required to prepare a supplement to the January 2020 final supplemental environmental impact statement (NUREG-1437, Supplement) (ML20023A937) for Peach Bottom in accordance with 10 CFR 51.92.
3.
Environmental Audit Scope The scope of this supplemental environmental audit is to consider new and significant circumstances or information including new and revised environmental issues contained in the final rule and revised LR GEIS. The staff must specifically consider any new and significant information with respect to generic (i.e., Category 1) environmental issues.
Audit team members will review the documents and other requested information made available
3 on the Peach Bottom online reference portal identified on the environmental audit needs list (Enclosure 2) and discuss any questions and additional information needs with the applicants subject matter experts.
4.
Information and Other Material Necessary for the Environmental Audit As identified on the environmental audit needs list (Enclosure 2).
5.
Environmental Audit Team Members and Resource Assignments The environmental audit team members and their assignments are shown in the table below.
Discipline Team Members Environmental Review Supervisor Steve Koenick Environmental Project Manager Kevin Folk Backup Environmental Project Manager Karen Loomis Air Quality and Noise Nancy Martinez Aquatic Resources Briana Arlene Cumulative Impacts Brian Glowacki Environmental Justice Jeff Rikhoff Federally Protected Ecological Resources Briana Arlene Geologic Environment Kevin Folk Greenhouse Gases/Climate Change Nancy Martinez Groundwater (Hydrology and Hydrogeology)
Kevin Folk Historic and Cultural Resources Jeff Rikhoff Human Health Dr. Donald Palmrose Land Use and Visual Resources Jeff Rikhoff Meteorology and Climatology Nancy Martinez Postulated Accidents Jerry Dozier Replacement Power Alternatives Brian Glowacki Severe Accident Mitigation Alternatives Jerry Dozier Socioeconomics Jeff Rikhoff Spent Nuclear Fuel Leah Parks Surface Water Kevin Folk
4 Termination of Operations and Decommissioning Leah Parks Terrestrial Resources (Land Cover and Habitat)
Briana Arlene Uranium Fuel Cycle Leah Parks Waste Management (rad and non-rad)
Leah Parks 6.
Logistics An environmental audit will be conducted by NRC staff virtually the week of November 18, 2024.
The severe accident mitigation alternatives portion will be conducted the same week. An entrance meeting will be held with plant management at the beginning of the environmental audit and an exit meeting will be held at its conclusion. As necessary, the NRC will request any in-person breakouts.
7.
Special Requests Constellation staff and contractors who are subject matter experts in the disciplines identified on the environmental audit needs list should be available for interviews and tours.
8.
Deliverables An audit summary report will be issued by the NRC staff within 90 days from the end of the environmental audit.
Peach Bottom Nuclear Plant, Units 2 and 3 Environmental Audit Information and Needs Described below in three categories (i.e., virtual tours, meetings, and information needs and document requests, as applicable) are the supplemental environmental information needs of the U.S. Nuclear Regulatory Commission (NRC) staff for the Peach Bottom Nuclear Plant, Units 2 and 3 subsequent license renewal (SLR) application. Please arrange for the tours and meetings specified below to occur during the virtual environmental audit. Additionally, the NRC staff requests that access to the documents and other additional information needs be made available through an online portal via the internet. The staff further requests that subject matter experts be available to discuss requested needs with the NRC staff.
The following conditions associated with the online portal must be maintained throughout the duration of the audit that the NRC staff has access to the online portal:
The online portal will be password-protected, and separate passwords will be assigned to the NRC staff who are participating in the audit.
The online portal will be sufficiently secure to prevent the NRC staff and any contractors from printing, saving, downloading, or collecting any information on the online portal.
Conditions of use of the online portal will be displayed on the login screen and will require acknowledgement by each user.
Username and password information should be provided directly to the NRC staff. The NRC environmental project manager will be responsible for providing the applicant (Constellation Energy Generation, LLC (CEG)), with the names and contact information of the NRC staff who will be participating in the environmental audit. All other communications should be coordinated with the NRC environmental project manager.
Virtual Tours Please arrange for, and provide appropriate subject matter experts to contribute to, the following virtual tours. For the virtual tours, please provide photographs, diagrams, location maps, and/or callouts for specific components that would be of interest for the features noted.
Number and Title Features Observed NRC Participants
- 1. Virtual Tour-General site Virtual walk-through of the following via photographs and/or diagrams:
Exterior grounds Transmission lines Historic and cultural sites Possible alternative power generation locations Independent Spent Fuel Storage Installation (ISFSI)
Radwaste/mixed waste storage locations Radiological effluent release points Cooling water intake and discharge locations and permitted outfalls Plant views from publicly accessible areas Any new plant project or construction areas (since
~2019)
All
2 Meetings Please be prepared to schedule the specified breakout meetings with the appropriate subject matter expert(s) and/or contractor(s) concerning the following topics. Those in attendance should be prepared to discuss the corresponding questions as described in the Information Needs and Document Requests section below. The staff intends to use these breakout meetings, as needed, to resolve or clarify any outstanding data needs or questions arising from the supplemental environmental audit.
Tuesday, November 19, 2024 [All times are Eastern Standard; end times are tentative]
START END ACTIVITY ATTENDEES/Technical Lead 9:00 am 9:30 am Entrance Meeting NRC and CEG project managers (PMs) and subject matter experts 9:30 am 10:30 am Virtual Tour All 10:30 am 11:00 am Overview/General Topics All 11:00 am 11:30 pm Geologic Environment, Surface Water Resources, and Groundwater Kevin Folk, Sam Cohen 11:30 am 12:00 pm Socioeconomics, Cumulative Effects Jeff Rikhoff, Brian Glowacki 12:00 pm 3:00 pm Break 3:00 pm 4:00 pm Postulated Accidents/severe accident mitigation alternatives (SAMA)
Jerry Dozier 4:00 pm 4:30 pm Daily Closeout NRC and CEG PMs Wednesday, November 20, 2024 START END ACTIVITY ATTENDEES 1:00 pm 2:00 pm Air Quality, Noise, Greenhouse Gases/Climate Change, Ecological Resources Nancy Martinez, Briana Arlene 2:00 pm 2:30 pm Human Health Don Palmrose 2:30 pm 3:00 pm Daily Closeout NRC and CEG PMs Friday, November 22, 2024 START END ACTIVITY ATTENDEES 9:00 am 11:00 am Uranium Fuel Cycle, Waste Management Leah Parks and Don Palmrose 11:00 am 12:00 pm Audit Closeout NRC and CEG PMs Information Needs and Document Requests Information needs and document requests are identified below by topic. Issues applicable to these questions are provided below along with the responsible NRC subject matter expert, as appropriate.
General (All)
The following requests are generic to more than one environmental resource area.
GEN-1 Provide a status update (i.e., existing permits including associated renewal application or anticipated reissuance date) for all active permits/authorizations. For those slated to
3 expire in the next 12 months, provide a brief description of CEGs plans for renewing them, as applicable.
GEN-2 Section 2.1.3 of the January 2020 final supplemental environmental impact statement (final SEIS) (NUREG-1437, Supplement 10, Second Renewal) (Agencywide Documents Access and Management System (ADAMS) ML20023A937), in referencing the applicants 2018 SLR environmental report (ML18271A185), states that no refurbishment or other nuclear plant modifications to support extended operations during the SLR term are planned that could directly affect the environment or plant effluents. Confirm that this information remains accurate. If not, provide a description of what refurbishment activities or plant modifications have been initiated since 2018 or are planned and their status.
Document Needs None at present.
Subject Matter Area-Specific The following requests are specific to a single environmental review area. If a topic is not provided below, the discussions held in response to the generic requests above are expected to fully cover that topic.
Replacement Energy Alternatives (Brian Glowacki)
Audit Needs Document Needs None at present.
Land Use and Visual Resources (Jeff Rikhoff)
Audit Needs Document Needs None at present.
Air Quality (Nancy Martinez)
Audit Needs AQN-1 Table 3-3 of the January 2020 final SEIS provides estimated air pollutant emissions from Peach Bottom for years 2013 through 2017. Provide estimated air pollutant emission from Peach Bottom for years 2018 through 2023.
AQN-2 Indicate whether CEG has received any notices of violation or non-compliance with respect to Peach Bottoms air pollutant emissions permit (number 67-05020) since 2018 and inclusive of the last 5 years (2020-2024). If any infractions have been issued, provide a brief description of the issue(s) and describe any corrective actions taken by CEG.
4 Document Needs None at present.
Meteorology and Climatology (Nancy Martinez)
Audit Needs Document Needs None at present.
Noise (Nancy Martinez)
Audit Needs NOI-1 Indicate whether CEG has conducted or sponsored any ambient noise studies in the immediate vicinity of the Peach Bottom site since submitting the July 2018 SLR environmental report (ML18271A185)? If any, provide a brief description of the studies performed and provide a copy on the portal.
NOI-2 Indicate whether CEG has received any noise complaints associated with operation of Peach Bottom since 2018 and inclusive of the last 5 years (2020-2024. If complaints have been received, provide a brief description of the issue(s) and describe any corrective actions taken by CEG.
Document Needs None at present.
Geologic Environment (Kevin Folk, Sam Cohen)
Audit Needs Document Needs None at present.
Water Resources - Surface Water (Kevin Folk, Sam Cohen)
Audit Needs SW-1 Available information on the portal provides a summary of average and peak daily surface water withdrawal as well as average and peak daily consumptive use for Peach Bottom (for the period 2018-2023). Provide available data for 2024 to date.
SW-2 Based on the available information on the portal and as discussed in the 2020 final SEIS, the Pennsylvania Department of Environmental Protection has not renewed (as of November 2024) National Pollutant Discharge Elimination System (NPDES) permit number PA0009733 for Peach Bottom, which expired in 2019. Provide a status update for this permit including when CEG expects to receive the renewed permit.
5 SW-3 Indicate whether CEG has received any notices of violation or non-compliance with respect to NPDES permit number PA0009733 for Peach Bottom since 2018 and inclusive of the last 5 years (2020-2024). If any infractions have been issued, provide a brief description of the issue(s) and describe any corrective actions taken by CEG.
SW-4 As described in Section 4.5.1.2 of the 2020 final SEIS, the Susquehanna River Basin Commission docket governing permissible withdraw and consumption of water from Conowingo Pond authorizes Peach Bottom to withdraw up to 2,363.62 million gallons per day (MGD) of surface water, and to consume water up to 49 MGD. The plants Consumptive Use Mitigation Plan (CUMP) requires that consumptive use of water during the months of August, September, and October must be mitigated under certain low flow conditions.
Available information on the portal describes two instances during August 15-22 and September 2-3 of 2022, in which low flow conditions warranted CUMP mitigation via the operation of the Conowingo Hydro Station. Provide the reports for review on the portal confirming CUMP execution. In addition, indicate whether CEG has needed to implement the consumptive use provisions from 2022 to date. If so, provide a brief description of the date, circumstances, and associated reports on the portal.
Document Needs None at present.
Water Resources - Groundwater Resources (Kevin Folk, Sam Cohen)
Audit Needs GW-1 Based on the available information on the portal and as documented in CEGs 2023 Annual Radiological Environmental Operating Report for Peach Bottom, several groundwater protection monitoring wells have continued to exhibit elevated tritium concentrations. Provide the monthly tritium results for wells MW-PB-25, MW-PB-28, and MW-PB-30 for 2024 (year to date).
GW-2 Section 3.5.2.2 of the 2020 final SEIS describes groundwater use and groundwater supply wells at Peach Bottom. Based on the available information on the portal, CEG continues to maintain three active groundwater supply wells with a maximum groundwater production capacity of 15 gallons per minute (gpm) for the three wells.
The yard drain sump and dewatering system also remains in operation with a discharge capacity of up to 50 gpm to an NPDES-permitted outfall. Provide confirmation that this information remains accurate.
Document Needs None at present.
Terrestrial Resources (Briana Arlene)
Audit Needs Document Needs None at present.
6 Aquatic Resources (Briana Arlene)
Audit Needs Document Needs None at present.
Federally Protected Ecological Resources (Briana Arlene)
Audit Needs FPE-1 On October 23, 2024, the U.S. Fish and Wildlife Services (FWS) released the Northern Long-eared Bat and Tricolored Bat Rangewide Determination Key (DKey). Federal agencies can use the DKey, as appropriate, to seek the FWSs concurrence that Federal actions are not likely to adversely affect these species. The NRC staff requires additional information on the proposed Peach Bottom SLR to complete the DKey.
Please provide responses to the questions in the FWSs Northern Long-eared Bat and Tricolored Bat Rangewide DKey for the proposed Peach Bottom SLR. The DKey is available through the FWSs Information for Planning and Consultation website:
https://ipac.ecosphere.fws.gov/.
Document Needs None at present.
Historic and Cultural Resources (Jeff Rikhoff)
Audit Needs Document Needs None at present.
Socioeconomics (Jeff Rikhoff)
Audit Needs SOC-1 Provide updated real estate (property) tax payment information for the last 5 years (2020-2024). (See 2020 final SEIS Table 3-23, Local Taxing Jurisdiction Real Estate Tax Revenue and Exelon Tax Payments for Peach Bottom (in millions of dollars),
2013-2017).
Document Needs None at present.
7 Human Health (Don Palmrose)
Audit Needs HH-1 Provide knowledgeable expert(s) to discuss human health information. Specific items for discussion include:
a.
Procedures for personnel protection regarding microbiological hazards; b.
Any changes to or future updates to Peach Bottoms safety programs with respect to occupational and electrical safety; and c.
Implementation of the National Electrical Safety Code for in-scope transmission lines.
Document Needs None at present.
Environmental Justice (Jeff Rikhoff)
Audit Needs None at present.
Document Needs None at present.
Waste Management (Leah Parks)
Audit Needs WM-1 Based on the review of available effluent reports from 2019-2023, there have been abnormal releases of radioactive gaseous and liquid effluents at Peach Bottom.
However, the information in the reports seems to conflict with other information which indicates, there have been no inadvertent releases of radiological or non-radiological materials at PBAPS since 2010. Indicate whether there have been any reportable abnormal or unplanned (inadvertent) releases of radioactive materials (other than those documented in the Effluent reports) from Peach Bottom that would trigger a notification requirement from 2019-2023 and since December 31, 2023.
WM-2 Indicate whether CEG anticipates making any changes or upgrades to the effluent or environmental monitoring program at Peach Bottom during the SLR term. If changes are anticipated, provide a brief description.
WM-3 Indicate whether CEG anticipates making any changes or upgrades to the mixed waste management program at Peach Bottom during the SLR term. If changes are anticipated, provide a brief description.
WM-4 The portal additional information indicates that there have been no non-radiological releases at Peach Bottom that impacted soil or groundwater since 2010.
Indicate/confirm that there have been no other reportable spills of nonradioactive material at Peach Bottom to date.
WM-5 Indicate whether CEG anticipates making any changes or upgrades to the non-
8 radiological waste program at Peach Bottom during the SLR term. If changes are anticipated, provide a brief description.
WM-6 Peach Bottom is subject to the reporting provision of Title 40 of the Code of Federal Regulations Part 110 as it relates to the discharge of oil in such quantities as may be harmful pursuant to Section 311 (b)(4) of the Federal Water Pollution Control Act.
Indicate whether there have been any reportable discharges at Peach Bottom since 2018 that would trigger this notification requirement. If any discharges have occurred, provide a brief description of the circumstances and describe any corrective actions taken by CEG.
WM-7 Indicate whether CEG anticipates making any changes or upgrades to the low-level radioactive waste program at Peach Bottom during the SLR term. If changes are anticipated, provide a brief description.
Document Needs:
WM-8 Provide procedures related to the radioactive and nonradioactive Waste Management Program, Waste Minimization Program, and Stormwater Pollution Prevention Plan.
WM-9 Provide available drawings and photos that are highlighted/marked showing the flow paths for releases for both radiological and non-radiological wastes. Provide knowledgeable expert(s) during the audit to discuss the flow paths.
WM-10 Provide the log of currently approved waste vendors used to manage and dispose of hazardous and non-hazardous waste from Peach Bottom.
Spent Nuclear Fuel (Leah Parks)
Audit Needs SNF-1 Section 3.1.4.4 of the 2020 final SEIS states, Exelon projects that the current ISFSI
[independent spent fuel storage installation] will be full on or before the year 2020 (Exelon 2018a). To accommodate storage of spent fuel through the current license terms for both Units 2 and 3 (2033 and 2034, respectively), Exelon is expanding the current ISFSI storage pad and expects to complete construction in 2019. Exelon also stated that spent fuel management beyond 2034 may be at a second onsite ISFSI pad or at an offsite facility if one becomes available. Exelon states that it has adequate space onsite to accommodate the construction of a new ISFSI pad if necessary (Exelon 2018c).
A statement provided in the portal additional information indicates that: The current ISFSI pad does not have adequate storage to accommodate spent fuel beyond 2034, when a third ISFSI pad would be needed. When expansion is required, construction would likely occur to the north of the existing pads, which is previously disturbed land near the existing ISFSI and would not be expected to have any significant environmental impacts.
The ER supplement states that, Should CEG need to go forward with a third ISFSI pad, CEG would conduct a siting study to identify candidate sites within PBAPSs site licensed by the NRC (the host area required by 10 CFR 72.106, for an ISFSI general license under 10 CFR 72.210). The site selection process would consider regulations for, and commitments to, the protection of endangered species, wetlands, and archeological findings.
9 Provide confirmation of this information regarding the second ISFIS location (third ISFSI pad).
Document Needs None at present.
Uranium Fuel Cycle (Leah Parks)
Audit Needs UFC-1 Provide a knowledgeable expert to discuss the burnup levels of spent fuel being stored in the spent fuel pools and the ISFSI, given that average peak rod fuel burnup levels could be between 33,000 to 62,000 megawatt-days per metric tonne of uranium (MWd/MTU). The portal information states that, CEG has indicated that PBAPS has no plan to increase average peak rod fuel burnup beyond 62 GWd/MTU (EGC 2019c).
Please confirm there are no plans to extend the increase average peak rod fuel burn up above 62,000 MWd/MTU during the license renewal term.
Document Needs None at present.
Termination of Operations and Decommissioning (Leah Parks)
Audit Needs Document Needs None at present.
Greenhouse Gas Emissions and Climate Change (Nancy Martinez)
Audit Needs GHG-CC-1 Additional information provided on the portal includes a tabular summary of direct and indirect greenhouse gas (GHG) emissions resulting from operation at Peach Bottom for the period 2018-2023.
a.
For direct emissions, provide the relative percentage each source (stationary combustion sources, sulfur hexafluoride, process carbon dioxide (CO2) and refrigerants) contributed to the annual total.
b.
Identify site-equipment/sources that are not included in the air emissions permit but were accounted for in the direct GHG emissions.
c.
Provide additional information about where sulfur hexafluoride (SF6) is used (identify the sources/equipment) and if and how fugitive emissions of SF6 are mitigated.
d.
Identify the sources/equipment that use CO2.
e.
Provide calculations used in quantifying the direct and indirect emissions.
10 Document Needs None at present.
Cumulative Effects (Brian Glowacki)
Audit Needs CI-1 Based on the available information on the portal, CEG has two identified two onsite projects either completed or planned that include a new package sewage treatment plant and a cable installation project. Provide a detailed description of these projects including location, schedule, area disturbed, impacts to any environmental resources, and permits/authorization obtained to support the projects.
Document Needs None at present.
Postulated Accidents/Severe Accidents Mitigation Alternatives (SAMA) (Jerry Dozier)
Audit Needs SAMA-1 Based on the available information on the portal, CEG has considered new and significant information, including for external and internal events, regarding postulated accidents and SAMA relative to the Peach Bottom 2020 final SEIS and the 2024 Generic Environmental Impact Statement for License Renewal of Nuclear Plants (ML24087A133). Provide a summary of this new information for review on the portal and for discussion with experts during the audit.
Document Needs None at present.