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NUREG/BR-0058, Rev. 5, Appendix I National Environmental Policy Act Cost-Benefit Analysis - Dfc

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NUREG/BR-0058, Rev. 5
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1 APPENDIX I 2 NATIONAL ENVIRONMENTAL POLICY ACT 3 COST-BENEFIT ANALYSIS GUIDANCE

1 TABLE OF CONTENTS 2

3 ABBREVIATIONS AND ACRONYMS .......................................................................... I-v 4 I.1 PURPOSE ........................................................................................................... I-1 5 I.2 COST-BENEFIT ANALYSIS FOR NATIONAL ENVIRONMENTAL POLICY 6 ACT REVIEWS .................................................................................................... I-2 7 I.2.1 Regulatory Requirements .......................................................................................I-2 8 I.2.1.1 Environmental Reports Prepared by License Applicants............................I-2 9 I.2.1.2 National Environmental Policy Act Documents Prepared by the NRC 10 Staff ............................................................................................................I-3 11 I.2.2 NRC Guidance .......................................................................................................I-3 12 I.2.2.1 Regulatory Guide 4.2 - Preparation of Environmental Reports for 13 Nuclear Power Stations ..............................................................................I-4 14 I.2.2.2 NUREG-1555 - Standard Review Plans for Environmental Reviews 15 for Nuclear Power Plants: Environmental Standard Review Plan ............. I-4 16 I.2.2.3 NUREG-1748 - Environmental Review Guidance for Licensing 17 Actions Associated with Office of Nuclear Material Safety and 18 Safeguards Programs .................................................................................I-6 19 I.3 ENVIRONMENTAL JUSTICE ............................................................................. I-7 20 I.3.1 The Commissions Policy Statement ......................................................................I-7 21 I.3.2 NRC Guidance .......................................................................................................I-7 22 I.3.2.1 Guidance for Preparing Environmental Assessments for Reactors............ I-7 23 I.3.2.2 Guidance for Preparing Environmental Assessments for Nuclear 24 Materials Uses ............................................................................................I-8 25 I.3.2.3 Procedures for Rulemaking Activities .........................................................I-8 26 I.4 SEVERE ACCIDENT MITIGATION ALTERNATIVES ...................................... I-10 27 I.4.1 Analysis Methodology ..........................................................................................I-11 28 I.4.1.1 Identification and Characterization of Leading Contributors to Risk ......... I-11 29 I.4.1.2 Identification of Candidate Severe Accident Mitigation Alternatives ......... I-11 30 I.4.1.3 Estimation of Risk Reduction and Implementation of Cost Estimates ...... I-12 31 I.4.1.4 Identification of Severe Accident Mitigation Alternatives That Are 32 Potentially Cost Beneficial ........................................................................I-12 33 I.4.1.5 Screening Analysis for Remaining Severe Accident Mitigation 34 Alternatives ...............................................................................................I-13 35 I.4.1.6 Disposition of Potentially Cost-Beneficial Severe Accident 36 Mitigation Alternatives ..............................................................................I-13 37 I.4.2 Specific Considerations for Severe Accident Mitigation Design Alternatives ....... I-14 38 I.4.2.1 Adequacy of the Probabilistic Risk Assessment .......................................I-14 39 I.4.2.2 Considerations Regarding Sources of Site Information ............................I-14 I-iii NUREG/BR-0058, Rev. 5, App. I, Rev. 0

1 I.4.2.3 Construction Permits and Operating Licenses .........................................I-15 2 I.4.3 Nuclear Material Licenses ....................................................................................I-15 3 I.5 REFERENCES .................................................................................................. I-17 4

NUREG/BR-0058, Rev. 5, App. I, Rev. 0 I-iv

1 ABBREVIATIONS AND ACRONYMS 2

3 ADAMS Agencywide Documents Access and Management System 4 CEQ Council on Environmental Quality 5 CFR Code of Federal Regulations 6 COL combined license 7 CP construction permit 8 EA environmental assessment 9 EIS environmental impact statement 10 EO Executive order 11 EPRI Electric Power Research Institute 12 ER environmental report 13 ESRP environmental standard review plan 14 FONSI finding of no significant impact 15 FR Federal Register 16 FSAR final safety analysis report 17 IPE individual plant examination 18 LWR light water reactor 19 NEI Nuclear Energy Institute 20 NEPA National Environmental Policy Act of 1969 21 NMSS Office of Nuclear Material Safety and Safeguards 22 NRC U.S. Nuclear Regulatory Commission 23 NRR Office of Nuclear Reactor Regulation 24 NUREG NRC technical report designation 25 NUREG/BR NUREG brochure 26 OL operating license 27 PRA probabilistic risk assessment 28 RG regulatory guide 29 SAMA severe accident mitigation alternative 30 SAMDA severe accident mitigation design alternative 31 SECY Office of the Secretary of the Commission, NRC Commission paper 32 SER safety evaluation report 33 SOARCA State-of-the-Art Reactor Consequence Analyses 34 U.S.C. United States Code I-v NUREG/BR-0058, Rev. 5, App. I, Rev. 0

1 NATIONAL ENVIRONMENTAL POLICY ACT 2 COST-BENEFIT ANALYSIS GUIDANCE 3

4 I.1 PURPOSE 5

6 This appendix describes the methods used by the U.S. Nuclear Regulatory Commission (NRC) 7 when conducting cost-benefit analyses to satisfy the requirements of the National 8 Environmental Policy Act of 1969, as amended (NEPA) (42 U.S.C. 4332 et seq.) during 9 rulemaking or licensing reviews. The purpose of NEPA is to ensure that each Federal agency 10 considers, along with other factors, the impacts of its actions on the environment and the health 11 and welfare of the public. In implementing NEPA, Federal agencies must evaluate the 12 environmental effects of their actions before they make decisions and prepare a detailed 13 statement for major Federal actions that significantly affect the quality of the human 14 environment.

15 16 Title 10 of the Code of Federal Regulations (10 CFR) Part 51, Environmental Protection 17 Regulations for Domestic Licensing and Related Regulatory Functions, contains the NRCs 18 regulations for implementing NEPA. NEPA requires Federal agencies to conduct a detailed 19 assessment of the environmental effects of a proposed action, alternatives to the action, and 20 irreversible commitments of resources involved with the action. A comparative evaluation of the 21 proposed action and alternatives includes the identification, characterization, and analysis of 22 both monetized (i.e., those measured in dollars) and qualitative (i.e., descriptive or 23 nonmonetized) costs and benefits of environmental effects.

24 25 A cost-benefit analysis is one component of the NRCs analytical requirements under NEPA.

26 Unless exempt under 10 CFR 51.71, Draft environmental impact statementcontents, or 27 10 CFR 51.75, Draft environmental impact statementconstruction permit, early site permit, or 28 combined license, the NRCs regulations require the staff to consider and weigh the 29 environmental, technical, and other costs and benefits of a proposed action and alternatives, 30 and, to the fullest extent practicable, quantify the various factors considered 31 (10 CFR 51.45(c)). The Commission has found that if important factors cannot be quantified, 32 they may be discussed qualitatively (Louisiana Energy Services (Claiborne Enrichment Center),

33 CLI-98-03, 47 NRC 77 (1998)).

34 35 At the license renewal stage for a nuclear power plant under 10 CFR 51.95(c), a discussion of 36 the economic or technical costs and benefits of either the proposed action or alternatives is not 37 required unless costs and benefits are either (1) essential for determining whether to include an 38 alternative in the range of alternatives considered or (2) relevant to mitigation of severe 39 accidents. 1 1 According to Table B-1, Summary of Findings on NEPA Issues for License Renewal of Nuclear Power Plants, in Appendix B to Subpart A, Environmental Effect of Renewing the Operating License of a Nuclear Power Plant, of 10 CFR Part 51, severe accident mitigation alternatives (SAMAs) must be considered for all plants that have not considered such alternatives.

I-1 NUREG/BR-0058, Rev. 5, App. I, Rev. 0

1 I.2 COST-BENEFIT ANALYSIS FOR NATIONAL ENVIRONMENTAL 2 POLICY ACT REVIEWS 3

4 This section describes the process for conducting cost-benefit analyses in support of NEPA 5 reviews for NRC licensing actions.Section I.4 presents the methods used for conducting 6 cost-benefit analyses in evaluations of SAMAs and severe accident mitigation design 7 alternatives (SAMDA).

8 9 I.2.1 Regulatory Requirements 10 11 The regulations at 10 CFR Part 51 provide the NRCs requirements for implementing NEPA.

12 The regulations at 10 CFR 51.20, Criteria for and identification of licensing and regulatory 13 actions requiring environmental impact statements, list the actions that require an 14 environmental impact statement (EIS). Similarly, 10 CFR 51.21, Criteria for and identification 15 of licensing and regulatory actions requiring environmental assessments, lists the actions that 16 require an environmental assessment (EA). In 10 CFR 51.22, Criterion for categorical 17 exclusion; identification of licensing and regulatory actions eligible for categorical exclusion or 18 otherwise not requiring environmental review, the NRC lists the actions eligible for categorical 19 exclusion from the requirement to prepare an EIS or EA or otherwise not requiring an 20 environmental review.

21 22 I.2.1.1 Environmental Reports Prepared by License Applicants 23 24 By regulation, the NRC requires applicants that request NRC licensing actions to consider 25 economic, technical, and other costs and benefits of the proposed action and its alternatives in 26 environmental reports (ER). The regulations at 10 CFR 51.45(c) state:

27 28 Except for an environmental report prepared at the early site permit stage, or an 29 environmental report prepared at the license renewal stage under 51.53(c), the analysis 30 in the environmental report should also include consideration of the economic, technical, 31 and other benefits and costs of the proposed action and its alternatives. Environmental 32 reports prepared at the license renewal stage under 51.53(c) need not discuss the 33 economic or technical benefits and costs of either the proposed action or alternatives, 34 except if these benefits and costs are either essential for a determination regarding the 35 inclusion of an alternative in the range of alternatives considered or relevant to 36 mitigation.

37 38 The NRC is responsible for the independent evaluation of all information used in a NEPA review 39 (see 10 CFR 51.41, Requirement to submit environmental information).

40 41 For reactor license renewal, 10 CFR 51.53(c)(3)(ii)(L) requires the applicant to consider the 42 costs and benefits of SAMAs in its ER if SAMAs were not previously considered in an EIS, a 43 related supplement, or an EA. Conversely, a license renewal applicant for a nuclear power 44 plant that has already conducted a SAMA analysis as part of an EIS, a supplement to an EIS, or 45 an EA, does not need to provide another SAMA analysis in the subsequent or second license 46 renewal (SLR) ER. Nevertheless, 10 CFR 51.53(c)(3)(iv) requires the applicants ER to include 47 any new and significant cost-benefit information of which the applicant is aware that may affect 48 a prior SAMA analysis. Guidance is provided in Nuclear Energy Institute (NEI) 17-04, Revision 49 1, Model SLR New and Significant Assessment Approach for SAMA, dated August 2019.

50 Under 10 CFR 51.45, Environmental report, 10 CFR 51.54, Environmental report NUREG/BR-0058, Rev. 5, App. I, Rev. 0 I-2

1 manufacturing license; and 10 CFR 51.55, Environmental reportstandard design 2 certification, the NRC requires new reactor applicants to address the costs and benefits of 3 SAMDAs and the bases for not incorporating SAMDAs in the design.

4 5 I.2.1.2 National Environmental Policy Act Documents Prepared by the NRC Staff 6

7 The regulations at 10 CFR 51.71 require an EIS to include the consideration of the economic, 8 technical, and other benefits and costs of the proposed action and alternatives. The EIS 9 includes recommendations regarding the proposed action based on the information collected 10 and the independent analyses conducted. These recommendations are generally based on the 11 environmental effects of the proposed action, the consideration of reasonable alternatives, and 12 an assessment of the costs and benefits of the proposed action.

13 14 Some differences in requirements exist depending on application type. Under 10 CFR 51.75(b),

15 the NRC does not require an assessment of the economic, technical, or other costs and benefits 16 of the proposed action in early site permit EISs unless the applicant chooses to include this 17 information in the ER. Exceptions to the need for a cost-benefit analysis include supplemental 18 EISs prepared at the license renewal stage under 10 CFR 51.95(c) and EISs developed for an 19 early site permit under 10 CFR 51.75(c) unless these matters are addressed in the early site 20 permit environmental report, in which case, the early site permit EIS must include a cost-benefit 21 analysis. The regulations at 10 CFR 51.30(d) require the design certification EA to consider the 22 costs and benefits of SAMDAs and the bases for not incorporating SAMDAs in the design 23 certification. Similar to a standard design certification, an EA for a manufacturing license must 24 conduct a cost-benefit analysis in accordance with 10 CFR 51.30(e) under Subpart F, 25 Manufacturing Licenses, of 10 CFR 52, Licenses, Certifications, and Approvals for Nuclear 26 Power Plants.

27 28 I.2.2 NRC Guidance 29 30 Regulatory Guide 4.2, Preparation of Environmental Reports for Nuclear Power Stations, and 31 NUREG-1555, Standard Review Plans for Environmental Reviews for Nuclear Power Plants:

32 Environmental Standard Review Plan, provide guidance on how to conduct cost-benefit 33 analyses in support of NEPA reviews for new nuclear power reactors. NUREG-1748, 34 Environmental Review Guidance for Licensing Actions Associated with NMSS Programs, 35 provides guidance for both applicants and NRC staff on how to conduct cost-benefit analyses in 36 support of NEPA reviews for nuclear material license actions.

37 I-3 NUREG/BR-0058, Rev. 5, App. I, Rev. 0

1 I.2.2.1 Regulatory Guide 4.2 - Preparation of Environmental Reports for Nuclear Power 2 Stations 3

4 In Regulatory Guide (RG) 4.2, the NRC provides general procedures to applicants for preparing 5 cost-benefit analyses for ERs for the construction or operation of new nuclear power plants in 6 accordance with 10 CFR Part 52. The environmental impacts of constructing and operating the 7 new nuclear power plant, including the costs and benefits of the proposed action, must be 8 assessed before the NRC can issue a combined license (COL), construction permit (CP), or 9 operating license (OL). Therefore, the NRC requires applicants to include cost-benefit 10 information in ERs to assist the agency in analyzing the costs and benefits of the proposed 11 action. Analysts should verify that the applicants are applying the guidance from the latest 12 version of RG 4.2, or that an acceptable alternative approach is justified.

13 14 The companion document to RG 4.2 is NUREG-1555, which describes the types of information 15 and the level of detail needed by the NRC to support the development of cost-benefit analyses 16 in EISs for COL, CP, and OL applications. Applicants are encouraged to confer with the NRC 17 as early as possible to avoid issues related to cost-benefit information in the ERs (see 18 10 CFR 51.40, Consultation with NRC staff).

19 20 I.2.2.2 NUREG-1555 - Standard Review Plans for Environmental Reviews for Nuclear 21 Power Plants: Environmental Standard Review Plan 22 23 The environmental standard review plans (ESRP) in NUREG-1555 consist of a series of 24 instructions for conducting environmental reviews and preparing EISs and EAs for new reactor 25 licensing actions. The use of these ESRPs provides for completeness and consistency of the 26 environmental review, including the cost-benefit analyses prepared for EISs and EAs. The 27 analyst should apply the guidance from the latest version of NUREG-1555.

28 29 After receiving a new reactor licensing application, the NRC performs an acceptance review to 30 determine whether the information (including cost-benefit information) in the ER is sufficient to 31 complete the NEPA review. Based on the NEPA review, the EIS and the cost-benefit analysis 32 present the NRC staffs recommendations on the proposed licensing action.

33 34 The following sections summarize the applicable ESRPs in NUREG-1555 that direct the 35 analysis, evaluation, and balancing of costs and benefits.

36 37 ESRP 10.4 Benefit-Cost Balance 38 39 In ESRP 10.4, the NRC provides guidance for identifying, characterizing, and gathering the 40 expected costs and benefits associated with the proposed project from other parts of the EIS.

41 In addition, the ESRP provides guidance on gathering the expected costs and benefits of any 42 environmentally preferable alternatives, including energy alternatives, alternative sites, and 43 system design alternatives. The analyst should follow the guidance in NUREG-1555, 44 ESRP 10.4, for the assessment of costs and benefits.

45 46 ESRP 10.4.1 Benefits 47 48 In ESRP 10.4.1, the NRC describes the identification, evaluation, and tabulation of the benefits 49 resulting from the construction and operation of the proposed project. The analyst may rely on 50 an independent analysis of benefits by State or regional authorities, may review the applicants 51 analysis, or may prepare an independent assessment. If a review of the applicants analysis is NUREG/BR-0058, Rev. 5, App. I, Rev. 0 I-4

1 conducted, the analyst must ensure that the applicants assumptions, data, and methods are 2 acceptable. The scope should include the nuclear power plants average annual 3 electrical-energy generation in kilowatt-hours, enhanced reliability of the electrical distribution 4 system, technical benefits such as development of technology, the quantities of other products 5 produced (e.g., steam used for commercial processes), and other benefits that have been 6 identified (e.g., increased regional productivity, tax revenues, or new or improved recreational 7 facilities). Benefits should be identified for the applicants proposed project and for any of the 8 NRC staffs identified alternatives to mitigate adverse impacts.

9 10 At the early site permit stage, 10 CFR 51.75(b) states that the draft EIS must not include an 11 assessment of the economic, technical, or other benefits . . . unless these matters are 12 addressed in the early site permit environmental report.

13 14 The benefits of plant construction and operation should be summarized in tabular form similar to 15 that shown in the benefits summary table in Chapter 10 of the EIS. Each benefit identified by 16 the analyst should be discussed in the text and presented in the table.

17 18 ESRP 10.4.2 Costs 19 20 In ESRP 10.4.2, the NRC describes the identification and evaluation of the internal and external 21 costs of construction and operation of the proposed project. The analyst may rely on any 22 reasonable independent analysis of costs by State or regional authorities or on the applicants 23 analysis. The analyst may also prepare an independent assessment. The analyst must ensure 24 that the applicants assumption, data, and methods are acceptable. The scope should include 25 (1) capital costs, fuel costs, operating and maintenance costs, decommissioning costs, and any 26 other identified internal costs; (2) the external costs of impacts (e.g., loss of cropland 27 productivity or loss of wildlife habitat) identified in previous environmental reviews; and (3) other 28 external costs that are not associated with an identified environmental impact (e.g., effects of 29 increased traffic, medical costs). Costs should be identified for the applicants proposed project 30 and for any of the NRC staffs identified alternatives to mitigate adverse impacts. The analysis 31 should rely primarily on quantitative estimates where possible.

32 33 At the early site permit stage, 10 CFR 51.75(b) states that the draft EIS must not include an 34 assessment of the economic, technical, or other benefits . . . unless these matters are 35 addressed in the early site permit environmental report.

36 37 The costs of plant construction and operation should be summarized in tabular form similar to 38 that shown in the costs summary table in Chapter 10 of the EIS. Each cost identified by the 39 analyst should be discussed in the text and presented in the table.

40 41 ESRP 8.4 Assessment of Need for Power 42 43 The need for power is a critical component of an EIS because it establishes a framework for the 44 evaluation of project benefits and for the geographic boundaries of the relevant electricity 45 market over which costs and benefits are distributed. The ESRP sections that assess the need 46 for power discuss the proposed project in the context of the larger network of transmission and 47 generation and the loads the system serves. This includes discussions on the electrical 48 demand and demand growth in the region and electrical power supply options.

49 50 The Commission reaffirmed the importance of the NRCs need for power analyses in its 51 response to a petition for rulemaking (NRC, 2002) and stated that the principal benefit of I-5 NUREG/BR-0058, Rev. 5, App. I, Rev. 0

1 constructing and operating a power reactor is the generation of electric power. Consequently, 2 the need for a power analysis in the EIS serves to establish the benefits of the project under 3 NEPA. The analyst should note that the analysis does not need to demonstrate a service-area-4 wide capacity deficit that is equal to or greater than the capacity of the proposed project to 5 conclude that there is some need for power.

6 7 The analyst should follow the guidance in NUREG-1555, ESRP 8.4, for assessing the need for 8 power.

9 10 As stated in 10 CFR 51.71(f), a draft EIS must include a preliminary recommendation as to 11 whether to approve the permit application after weighing the results of the information and 12 analyses included in the EIS. The review conducted under the need for power will aid this 13 determination by providing input that can be used to evaluate the potential costs and benefits of 14 a COL, CP, or OL permit.

15 16 I.2.2.3 NUREG-1748 - Environmental Review Guidance for Licensing Actions Associated 17 with Office of Nuclear Material Safety and Safeguards Programs 18 19 In NUREG-1748, the NRC provides general procedures for the environmental reviews of 20 nuclear materials uses conducted by the Office of Nuclear Material Safety and Safeguards 21 (NMSS). The costs and benefits with respect to nuclear materials licenses should not be limited 22 to a simple financial accounting of project costs for the proposed action and each alternative.

23 The analysis should also consider costs and benefits that are analyzed qualitatively, such as 24 mitigation, environmental degradation, and enhancement. Project costs can be reviewed using 25 cost-estimating databases. Socioeconomic costs and benefits should be reviewed and 26 compared against those of similar projects to determine their reasonableness. For each 27 alternative, the analysis should include a quantitative discussion of the costs and benefits and a 28 qualitative discussion of environmental impacts, including assumptions and uncertainties. The 29 analyst should apply the guidance from the latest version of NUREG-1748.

NUREG/BR-0058, Rev. 5, App. I, Rev. 0 I-6

1 I.3 ENVIRONMENTAL JUSTICE 2

3 Executive Order (EO) 12898, Federal Actions to Address Environmental Justice in Minority 4 Populations and Low-Income Populations, mandates that Federal agencies make 5 environmental justice part of their respective missions by addressing disproportionately high and 6 adverse human health or environmental effects of Federal programs, policies, and activities on 7 minority populations and low-income populations. In December 1997, the Presidents Council 8 on Environmental Quality issued guidelines, titled Environmental Justice Guidance under the 9 National Environmental Policy Act, on how to integrate environmental justice into the NEPA 10 process. Independent agencies, such as the NRC, are not bound by the terms of EO 12898 but 11 are, as stated in paragraph 6-604 of the order, requested to comply with the provisions of [the]

12 order.

13 14 I.3.1 The Commissions Policy Statement 15 16 On August 24, 2004, the Commission issued a Policy Statement on the Treatment of 17 Environmental Justice Matters in NRC Regulatory and Licensing Actions (69 FR 52040) which 18 states, The Commission is committed to the general goals set forth in EO 12898, and strives to 19 meet those goals as part of its NEPA review process. The Commissions policy statement 20 confirms that NEPA is the legal basis for analyzing environmental justice matters, including the 21 human health and environmental effects of NRC licensing and other regulatory actions on 22 minority or low-income communities. Both the Office of Nuclear Reactor Regulation (NRR) and 23 NMSS have established procedures that incorporate the Commissions policy statement on 24 environmental justice into the NEPA review process.

25 26 I.3.2 NRC Guidance 27 28 Staff in NRR and the Office of New Reactors use Office Instruction LIC-203, Procedural 29 Guidance for Preparing Categorical Exclusions, Environmental Assessments, and Considering 30 Environmental Issues, as guidance on how to incorporate environmental justice in the NEPA 31 review process. The office instruction is the basis for the environmental justice process used for 32 new reactor licensing as provided in NUREG-1555 and in NUREG-1555, Supplement 1, 33 Standard Review Plans for Environmental Reviews for Nuclear Power Plants, Supplement 1:

34 Operating License Renewal. In addition, NUREG-1748 provides guidance on how to 35 incorporate environmental justice in the NEPA review process for materials licensing actions.

36 37 I.3.2.1 Guidance for Preparing Environmental Assessments for Reactors 38 39 Specifically, LIC-203 provides the basic framework for meeting the NRCs responsibility to 40 comply with 10 CFR Part 51. This document provides guidance for conducting environmental 41 justice reviews for all actions that require the preparation of an EIS (or a supplement thereto).

42 An environmental justice review is not usually required for an EA in which a finding of no 43 significant impact (FONSI) is made. Special circumstances may warrant an environmental 44 justice review even for actions that might result in a FONSI, typically if there will be significant 45 site modification with an identifiable impact on the environment or substantial public interest. In 46 such circumstances, NRC senior management should be informed so that it can decide, on a 47 case-by-case basis, whether the circumstances warrant an environmental justice review for an 48 EA. If there is a clear potential for significant offsite impacts from the proposed action to 49 minority and low-income communities, an environmental justice review may be appropriate to 50 provide a basis for concluding that there are no unique or significant impacts. If significant I-7 NUREG/BR-0058, Rev. 5, App. I, Rev. 0

1 impacts are identified, a FONSI may not be possible, and an EIS should be considered. The 2 LIC-203, Appendix D, Environmental Justice in NRR NEPA Documents, gives a more detailed 3 explanation of environmental justice and a flow chart characterizing the steps in an 4 environmental justice review.

5 6 I.3.2.2 Guidance for Preparing Environmental Assessments for Nuclear Materials Uses 7

8 In NUREG-1748, the NRC provides general procedures for the environmental justice review of 9 licensing actions regulated by the NRC. Specifically, the EIS should follow environmental 10 justice guidance in NUREG-1748, Chapter 5, and Appendix C, Environmental Justice 11 Procedures. Impacts that may have environmental justice implications include those 12 associated with health, ecological (including water quality and water availability), social, cultural, 13 economic, and aesthetic resources. The EIS should discuss the methods used to identify and 14 quantify impacts on low-income and minority populations, the location and significance of any 15 environmental impacts during construction on populations that are particularly sensitive, and 16 any additional information pertaining to mitigation of these impacts.

17 In addition, NUREG-1748, Appendix C, states that the results of an environmental justice 18 evaluation should be documented in the EIS or an EA conducted in special cases as described 19 above. The results should indicate whether a disproportionately high and adverse human 20 health or environmental impact is likely to result from the proposed action and any alternatives 21 that could be considered. The document should be written in nontechnical plain language. The 22 NEPA document should contain a distinct section on environmental justice even if the 23 demographics do not indicate a potential for an environmental justice concern.

24 25 I.3.2.3 Procedures for Rulemaking Activities 26 27 The staff should address environmental justice in the preamble to each proposed and final rule 28 that requires an EIS, a supplement to an EIS, or a generic EIS or, if warranted by a special case 29 or circumstance, an EA and FONSI.

30 If it is known in advance that a particular rulemaking might disproportionately affect a minority or 31 low-income population or community, the population should be made aware of the rulemaking 32 and have the opportunity to participate. Such actions may include translating the Federal 33 Register notice into a language other than English for publication in a local newspaper and 34 holding public outreach meetings in the potentially affected community.

35 If the staff performs an environmental justice review for a rulemaking activity, pages 67-68 of 36 NUREG/BR-0053, United States Nuclear Regulatory Commission Regulations Handbook, 37 provides a template to seek public comments on environmental justice. The template would be 38 part of either the proposed rule or a draft FONSI issued under 10 CFR 51.33, Draft Finding of 39 No Significant Impact; Distribution. NUREG/BR-0053, Revision 6, page 64, discusses 40 environmental justice issues in rulemaking activities. An environmental justice review 41 conducted for an operating reactor action should follow LIC-203, Appendix D, Steps 2 through 5 42 under Procedures for Licensing Actions, and NUREG-1748, Appendix C,Section III, Policy 43 Implementation for Licensing Actions, for licensing actions involving nuclear materials.

44 Public comments on the environmental justice review should be addressed in the preamble to 45 the final rule. Comments on the environmental justice review should be addressed at the same 46 level of detail and in the same location as comments received on other parts of the rule.

NUREG/BR-0058, Rev. 5, App. I, Rev. 0 I-8

1 When a rule that is under modification or development contains siting evaluation factors or 2 criteria for siting a new facility, the staff should consider including specific language in the rule or 3 supporting regulatory guidance to state that an environmental justice review will be performed 4 as part of the licensing process.

5 I-9 NUREG/BR-0058, Rev. 5, App. I, Rev. 0

1 I.4 SEVERE ACCIDENT MITIGATION ALTERNATIVES 2

3 The implementation of the NEPA requirements for certain nuclear reactor licensing reviews 4 involves an evaluation of the costs and benefits of SAMA and SAMDA, including offsite property 5 damage. Comparable analyses do not exist for the treatment of accidents and offsite 6 consequences for materials, waste, and fuel cycle facility licensing.

7 8 The SAMA analyses are a systematic search for potentially cost-beneficial enhancements to 9 further reduce nuclear power plant risk. A SAMA analysis evaluates additional features or 10 actions that would prevent or mitigate the consequences of severe accidents. The SAMA 11 analysis considers: (1) hardware modifications, procedure changes, and training program 12 improvements; (2) both prevention of core damage and mitigation of severe accident 13 consequences; and (3) the full scope of potential accidents (i.e., accidents initiated by internal or 14 external events). The scope of the analyses is the same for SAMAs and SAMDAs. The 15 SAMDAs generally focus on hardware modifications because new reactor licensing is based on 16 future reactor designs that might not have established procedures and training programs.

17 18 Current NRC policy and guidance developed after the 1989 Limerick Generating Station 19 (Limerick) court decision (Limerick Ecology Action v. NRC, 869 F.2d 719 (3rd Cir. 1989)) require 20 that EISs prepared at the OL stage and at the COL stage consider SAMAs that mitigate the 21 consequences of severe accidents. Consideration of SAMAs is required at the license renewal 22 stage for plants for which a site-specific SAMA has not been included in an EIS or supplemental 23 EIS. In addition, the NRC expects that a CP review would need to consider SAMAs; however, 24 special factors discussed below should be taken into account.

25 26 Commission paper SECY-91-229, Severe Accident Mitigation Design Alternatives for Certified 27 Standard Designs, dated July 31, 1991, identifies the design-related SAMAs or SAMDAs 28 required by 10 CFR 52.47(b)(2). The EA for each design certification rule issued under 29 10 CFR Part 52 considers SAMDAs. If a COL application references a certified design, the 30 design-related SAMDA review should focus on whether the site characteristics are within the 31 site parameters specified in the SAMDA evaluation. However, if a COL application references a 32 reactor design that is still undergoing certification review, the NRC expects the applicant to 33 provide a site-specific SAMDA analysis based on the known information of the selected design.

34 35 In NUREG-1555 for new reactor applications and NUREG-1555, Supplement 1 for license 36 renewal applications, the NRC provides guidance to the staff on how to review SAMA and 37 SAMDA analyses. NEI 05-01A, Severe Accident Mitigation Alternatives (SAMA) Analysis:

38 Guidance Document, which the NRC endorsed in license renewal Interim Staff Guidance 39 LR-ISG-2006-03: Staff Guidance for Preparing Severe Accident Mitigation Alternatives 40 Analyses, dated August 14, 2007, provides industry guidance for license renewals. For new 41 reactor applications, RG 4.2 provides guidance to industry for the assessment of SAMDAs. For 42 license renewal applications, RG 4.2, Supplement 1, provides guidance to industry for the 43 assessment of SAMAs.

44 45 The nuclear industry is developing advanced nuclear reactors with reduced risk profiles that are 46 not based on the current light water reactor (LWR) technology and could operate at power 47 levels as low as a couple of megawatt electric to power levels equivalent to the current LWRs.

48 Given that the staff may have to assess SAMAs for reactor designs with much lower risk profiles 49 than current LWRs, the staff is evaluating the need for a different SAMA methodology. If a NUREG/BR-0058, Rev. 5, App. I, Rev. 0 I-10

1 different SAMA methodology can be performed for advanced nuclear reactor designs, the staff 2 expects to develop separate supplementary SAMA guidance to address the expected unique 3 advanced nuclear reactor risk profiles.

4 5 I.4.1 Analysis Methodology 6

7 Both SAMA and SAMDA analyses follow the same methodology. The steps outlined below that 8 refer to SAMAs also apply to SAMDAs.

9 10 I.4.1.1 Identification and Characterization of Leading Contributors to Risk 11 12 The SAMA analysis begins with an offsite consequence analysis based on a plant-specific risk 13 model 2 that provides accident frequency and source term information from the applicants final 14 safety analysis report (FSAR) Chapter 19, Probabilistic Risk Assessment. In practice, 15 maximum use is made of the plant-specific probabilistic risk assessment (PRA) models 16 (e.g., Level 1 and Level 2 PRAs) for characterizing the dominant contributors to risk and 17 identifying candidate SAMAs to address these contributors. The contribution of external events 18 is considered to the extent that it can be supported by available risk methods because external 19 events can affect whether a SAMA is cost beneficial (i.e., greater reduction of risk).

20 Appendix H, Severe Accident Risk Analysis, to this document provides guidance for 21 performing the offsite consequence analysis (i.e., the limited Level 3 PRA).

22 23 I.4.1.2 Identification of Candidate Severe Accident Mitigation Alternatives 24 25 The next step is to identify the potential SAMA candidates that prevent core damage and that 26 prevent significant releases from containment. Insights from the plant-specific risk model, 27 compilations of potentially cost-beneficial SAMAs from similar reactor designs, and 28 improvements to training and procedures can inform the selection of potential SAMA 29 candidates. For license renewal, NEI 05-01A, Section 5, SAMA Identification, provides 30 guidance for developing a list of SAMA candidates. Tables 13 and 14 of NEI 05-01A provide 31 standard lists of SAMA candidates for boiling-water reactors and pressurized-water reactors, 32 respectively.

33 34 In new reactor applications, Chapter 19, Probabilistic Risk Assessment, of the FSAR typically 35 discusses potential design improvements. These potential design improvements could be 36 derived based on PRA criteria through the relative risk ranking of systems, structures, and 37 components and human actions, including the Fussell-Vesely Importance (e.g., greater than 38 0.005), Risk Reduction Worth, or Risk Achievement Worth. Other PRA-identified SAMA 39 candidates could come from a review of dominant sequences or cutsets (e.g., the top 100 40 cutsets) for failures that an enhancement to the plant could address. Additionally, an expert 41 panel that is very familiar with the reactor design could serve as a source to identify SAMAs.

42 43 Other candidate SAMAs can be considered based on input from members of the public during 44 the scoping phase of the NEPA review, if appropriate for the licensing action (see 45 10 CFR 51.27(a)(4) for a description of the scoping process).

46 2 The plant-specific risk model could be related to one of several probabilistic safety analysis methodologies that include individual plant examinations (IPE), IPE of external events recommendations, and Level 1 and Level 2 PRAs.

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1 I.4.1.3 Estimation of Risk Reduction and Implementation of Cost Estimates 2

3 With a listing of candidate SAMAs, an initial screening is performed to determine which SAMAs 4 are not cost beneficial and can be eliminated from further consideration. Section 6 of 5 NEI 05-01A, Phase I Analysis, lists screening criteria that may be applied: (1) not applicable 6 to the reactor design, (2) already implemented, (3) combined with another SAMA, (3) excessive 7 implementation cost (i.e., a dollar value of the SAMA should be given to justify elimination), and 8 (4) very low benefit. These screening criteria have been applied in most license renewal and 9 new reactor applications that require a SAMA.

10 11 For the SAMAs that remain, a rough implementation cost estimate (or cost of enhancement) is 12 developed for each SAMA (NEI, 2005). Cost estimates for hardware modifications can be 13 based on estimates from past studies performed for a similar plant or developed on a 14 plant-specific basis. These cost estimates do not include certain cost factors 15 (e.g., surveillance/maintenance, the cost of replacement power during implementation) and thus 16 tend to increase the number of potentially cost-beneficial SAMAs to provide for a full 17 consideration of alternatives. Typically, screening estimates are used for initial assessments 18 and are refined as appropriate if a SAMA is potentially cost beneficial. Hardware costs could 19 range from several hundred thousand to a few million dollars. Procedure changes could range 20 from several tens of thousands of dollars for simple changes to several hundred thousand 21 dollars for complex changes with analysis and operator training impacts.

22 23 I.4.1.4 Identification of Severe Accident Mitigation Alternatives That Are Potentially 24 Cost Beneficial 25 26 To identify SAMAs that may be cost beneficial, the estimate of the net value of each SAMA is 27 based on the maximum benefit that can be achieved by avoiding an accident using an 28 assumption that the SAMA could eliminate all risk of a severe accident. Namely, the net 29 present value of the SAMA is reached by comparing the maximum benefit to the cost of the 30 SAMA.

31 32 This portion of the SAMA methodology for the evaluation of the maximum benefit follows the 33 guidance of Section 4.6.1.2, Severe Accident Mitigation Design Alternatives, of NUREG/BR-34 0058. The analyst then assesses the appropriate attributes listed in Section 5.3, Quantification 35 of Attributes, of NUREG/BR-0058 as follows:

36 37

• APE = present value of averted public exposure (dollars) (Section 5.3.2.1) 38

• AOC = present value of averted offsite property damage costs (dollars) (Section 5.3.2.3) 39

• AOE = present value of averted occupational exposure costs (dollars) (Section 5.3.2.5) 40

• AOSC = present value of averted onsite costs (dollars), including cleanup, decontamination, 41 and long-term replacement power costs (Section 5.3.2.6) 42 43 The analyst then assesses the net present value of the SAMA by adding the four attributes 44 together and subtracting the cost of the enhancement (i.e., the implementation cost of the 45 SAMA) from this total.

46 47 Net Present Value = (APE + AOC + AOE + AOSC) - COE, NUREG/BR-0058, Rev. 5, App. I, Rev. 0 I-12

1 2 where 3

4 COE = cost of enhancement (dollars) 5 6 If the net value is positive, the SAMA is potentially cost beneficial and may be considered for 7 additional screening. If the net value is negative, the SAMA is not cost beneficial and is 8 removed from further consideration.

9 10 The NEI 05-01A, Section 4, Cost of Severe Accident Risk/Maximum Benefit, provides 11 examples of estimating these attributes to obtain the maximum benefit in regard to license 12 renewals.

13 14 I.4.1.5 Screening Analysis for Remaining Severe Accident Mitigation Alternatives 15 16 After identifying SAMAs that are potentially cost beneficial, the analyst should then perform a 17 more in-depth analysis of the SAMAs. This analysis may include a detailed (i.e., more realistic 18 and less bounding) evaluation of the potential benefits of the SAMA. Rather than assuming that 19 the SAMA eliminates all core damage frequency contributors, the analysis should include only 20 those sequences relevant to the SAMA, thus resulting in a maximum benefit according to the 21 fraction of risk that the SAMA actually can affect. It may also include a more detailed 22 development of the cost associated with the proposed modification, including engineering 23 support, training, hardware costs, and implementation costs.

24 25 Additionally, a sensitivity analysis is recommended to evaluate how changes in SAMA analysis 26 assumptions would affect the cost-benefit analysis. The NEI 05-01A, Section 8, Sensitivity 27 Analyses, provides several areas for this type of analysis, including plant modifications, 28 uncertainty, peer review findings or observations, evacuation speed, real discount rate, and 29 analysis period. However, additional sensitivity categories could be relevant depending on the 30 reactor design, bases for assumptions, the site being considered, and dollar per person-rem 31 conversion factor values.

32 I.4.1.6 Disposition of Potentially Cost-Beneficial Severe Accident Mitigation Alternatives 33 34 Any SAMAs that remain potentially cost beneficial are retained for possible implementation.

35 Given the potential for cost-beneficial risk reduction, the staff expects the applicant to evaluate 36 the remaining potentially cost-beneficial SAMA candidates to determine whether further action is 37 warranted.

38 39 For license renewals, the remaining SAMAs would be evaluated to determine whether any of 40 the potentially cost-beneficial SAMAs identified are subject to aging management such that they 41 would be within the scope of license renewal. This evaluation would consider whether any 42 structures, systems, and components associated with these SAMAs would perform their 43 intended functions without moving parts or without a change in configuration or properties and 44 would not be subject to replacement based on a qualified life or specified time period. If the 45 potentially cost-beneficial SAMAs do not relate to the adequate management of the effects of 46 aging during the period of extended operation, the licensee does not need to implement the 47 SAMAs as part of its license renewal in accordance with 10 CFR Part 54, Requirements for 48 Renewal of Operating Licenses for Nuclear Power Plants.

49 I-13 NUREG/BR-0058, Rev. 5, App. I, Rev. 0

1 For new reactor applications, PRAs have been an integral tool in the development of the reactor 2 design. Therefore, the overall severe accident risk may be significantly lower when compared 3 to the current operating reactors. As a result, generically identified SAMDAs (i.e., SAMDAs 4 previously identified for a class of reactors such as PWRs and BWRs) would likely not be 5 potentially cost beneficial at this point in the process.

6 7 I.4.2 Specific Considerations for Severe Accident Mitigation Design Alternatives 8

9 Although the assessment process for SAMDAs is essentially the same as that for SAMAs, this 10 section provides guidance for the consideration of the unique aspects of new reactor SAMDA 11 reviews.

12 13 I.4.2.1 Adequacy of the Probabilistic Risk Assessment 14 15 The NRCs Policy Statement on the Use of Probabilistic Risk Assessment Methods in Nuclear 16 Regulatory Activities encourages greater use of this analysis technique to improve safety 17 decisionmaking and regulatory efficiency. The NRC expects new reactor applications under 18 10 CFR Part 52 to have a PRA with results and insights that address the full scope of 19 operations for internal events at full power, external events at full power, and events during 20 other operating modes (e.g., low power and shutdown). The relevant regulatory requirements 21 depend on the type of application (e.g., standard design certification or COL) and are discussed 22 in NUREG-0800, Standard Review Plan for the Review of Safety Analysis Reports for Nuclear 23 Power Plants: LWR Edition, Section 19.0, Probabilistic Risk Assessment and Severe Accident 24 Evaluation for New Reactors. In addition to this guidance, RG 1.200, An Approach for 25 Determining the Technical Adequacy of Probabilistic Risk Assessment Results for Risk-26 Informed Activities, describes acceptable methods that the new reactor applicant and the 27 analyst can apply to assess the technical information in, and adequacy of, the PRA. Although a 28 license renewal application may apply RG 1.174, An Approach for Using Probabilistic Risk 29 Assessment in Risk-Informed Decisions on Plant-Specific Changes to the Licensing Basis, the 30 analyst may determine that, for an existing operating reactors PRA, this less than full scope 31 PRA information is acceptable.

32 33 The results of this difference in the adequacy of the PRA presents a unique challenge to the 34 SAMDA review in that, with a more complete set of risk information, the scope of the offsite 35 consequence analysis may be greater for a new reactor SAMDA review than it would for a 36 license renewal SAMA review given comparable design specifications (i.e., reactor power) and 37 site conditions. The NRC expects new reactor applicants to develop a reasonable set of source 38 term releases that will be more expansive over a larger set of hazard groups, including internal 39 and external release categories for at-power and low-power shutdown modes of operation.

40 41 I.4.2.2 Considerations Regarding Sources of Site Information 42 43 A key difference between the SAMDA analyses provided in a standard design certification 44 review versus a COL application is the basis for the site information being applied to the offsite 45 consequence calculation that supports the SAMDA analysis. Because the standard design 46 certification review only assesses the design itself, the site information would likely be based on 47 a reference site. This could be accomplished either by applying information based on an 48 industry document such as the Electric Power Research Institutes (EPRI) Advanced Light 49 Water Reactor Utility Requirements Document, Volume III, Annex B, ALWR Reference Site, NUREG/BR-0058, Rev. 5, App. I, Rev. 0 I-14

1 Revisions 5 and 6, or by obtaining the site information from a publicly available source. 3 For all 2 other licensing actions that require a SAMA or SAMDA analysis, the site information applied is 3 specific to the location.

4 5 Regardless of the type of application, the site information could be dated in various ways.

6 Therefore, to ensure that the submitted ER applied the best information, the staff should verify 7 that the applicant properly adjusted the relevant information to present values.

8 9 I.4.2.3 Construction Permits and Operating Licenses 10 11 Since the Limerick decision in 1989, the NRC has not received a CP application under 12 10 CFR Part 50, Domestic Licensing of Production and Utilization Facilities. Thus, all prior 13 SAMA analyses for a 10 CFR Part 50 license relate to an OL renewal under 10 CFR Part 54. If 14 an applicant submits a CP application under 10 CFR Part 50, the NRCs regulations require the 15 applicant and the staff to assess SAMAs as part of this licensing action.

16 Enclosure 1 to SECY-15-0002, Proposed Updates of Licensing Policies, Rules, and Guidance 17 for Future Reactor Applications, discusses unique challenges to assessing risks and SAMAs or 18 SAMDAs. First, the requirements in 10 CFR Part 52 for a PRA do not apply to new reactor 19 license applications submitted under 10 CFR Part 50, such as a CP. Second, a CP application 20 may only describe how the PRA will be completed analogous to the applications descriptions of 21 how other aspects of the design will be completed before the submittal of an application for an 22 OL. However, the PRA methodology has been proven to be a key reactor design tool, and a 23 full-scope PRA could still be part of the CP application. Thus, a CP application should provide 24 the best available information to assess SAMAs or SAMDAs.

25 26 For the subsequent OL, 10 CFR 51.53(b) states that, for the OL stage, each applicant for a 27 license to operate a production or utilization facility under 10 CFR 51.20 shall submit with its 28 application a Supplement to Applicants Environmental ReportOperating License Stage, 29 which will update the Applicants Environmental ReportConstruction Permit Stage. Unless 30 otherwise required by the Commission, the applicant for an OL for a nuclear power reactor 31 submits this report only in connection with the first licensing action authorizing full power 32 operation. In the report, the applicant discusses SAMAs or SAMDAs but only to the extent that 33 they differ from those discussed or reflect new information in addition to that discussed in the 34 final EIS prepared by the NRC in connection with the CP based on the completed nuclear power 35 plant.

36 37 I.4.3 Nuclear Material Licenses 38 39 The NUREG-1748 provides guidance on the review of a material licensing action to focus 40 environmental review documents (e.g., EAs and EISs) on the environmental impacts of the 41 proposed action and reasonable alternatives. Typically, the staff prepares a safety evaluation 42 report (SER) to evaluate and document the safety of the proposed action and compliance with 43 NRC regulations. The agency conducts the safety and environmental reviews in parallel.

44 Although the content of a SER and the NEPA document overlaps to some extent, each 3

Standard design certification applicants have also selected sites that were not generic but were either previously analyzed or were being evaluated under another licensing action. Examples of such sites include one of the sites analyzed in NUREG-1150, Severe Accident Risks: An Assessment for Five U.S. Nuclear Power Plants, Final Summary Report, Volume 1, or NUREG-1935, State-of-the-Art Reactor Consequence Analyses (SOARCA) Report, or the site for the first COL application for the design.

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1 document has a different purpose. The NEPA document does not address accident scenarios; 2 instead, it addresses the environmental impacts that would result from an accident and, 3 therefore, depends on certain information from the SER. The SER addresses accident 4 scenarios (i.e., frequency, probability).

5 6 The applicants ER and the NRCs NEPA document (an EIS or EA) should list reasonably 7 foreseeable and credible accidents (e.g., design-basis events for licenses under 8 10 CFR Part 72, Licensing Requirements for the Independent Storage of Spent Nuclear Fuel, 9 High-Level Radioactive Waste, and Reactor-Related Greater Than Class C Waste, and 10 credible consequence events for licenses under 10 CFR Part 70, Domestic Licensing of 11 Special Nuclear Material) identified as having a potential for releases to the environment and 12 the analysis of offsite radiological doses from these accidents. However, the environmental 13 review document would not analyze beyond-design-basis events for 10 CFR Part 72 licenses 14 and their potential environmental impacts because these events are typically not considered 15 reasonably foreseeable. Thus, material applicants and licensees do not determine whether a 16 cost-beneficial design alternative could mitigate a severe accident.

17 18 The analyst should use existing guidance from the latest version of NUREG-1748 to address 19 the environmental effects of accidents.

20 NUREG/BR-0058, Rev. 5, App. I, Rev. 0 I-16

1 I.5 REFERENCES 2

3 42 U.S.C. 4332 et seq., National Environmental Policy Act of 1969, as amended. Available at 4 https://energy.gov/nepa/downloads/national-environmental-policy-act-1969.

5 6 CFR, Domestic Licensing of Production and Utilization Facilities, Part 50, Chapter 1, Title 10, 7 Energy.

8 9 CFR, Environmental Protection Regulations for Domestic Licensing and Related Regulatory 10 Functions, Part 51, Chapter 1, Title 10, Energy.

11 12 CFR, Licenses, Certifications, and Approvals for Nuclear Power Plants, Part 52, Chapter 1, 13 Title 10, Energy.

14 15 CFR, Requirements for Renewal of Operating Licenses for Nuclear Power Plants, Part 54, 16 Chapter 1, Title 10, Energy.

17 18 CFR, Domestic Licensing of Special Nuclear Material, Part 70, Chapter 1, Title 10, Energy.

19 20 CFR, Licensing Requirements for the Independent Storage of Spent Nuclear Fuel, High-Level 21 Radioactive Waste, and Reactor-Related Greater Than Class C Waste, Part 72, Chapter 1, 22 Title 10, Energy.

23 24 Council on Environmental Quality (CEQ), Environmental Justice Guidance under the National 25 Environmental Policy Act, December 1997. Available at https://ceq.doe.gov/docs/ceq-26 regulations-and-guidance/regs/ej/justice.pdf.

27 28 EPRI, Advanced Light Water Reactor Utility Requirements Document, Volume III, Annex B, 29 ALWR Reference Site, Revisions 5 and 6, December 1993.

30 31 Limerick Ecology Action vs. NRC, 869 F.2d 719 (3rd Cir. 1989).

32 33 NEI, Severe Accident Mitigation Alternatives (SAMA) Analysis: Guidance Document, NEI 05-34 01A, November 2005. Agencywide Documents Access and Management System (ADAMS) 35 Accession No. ML060530203.

36 37 NEI, Model SLR New and Significant Assessment Approach for SAMA, NEI 17-04, Revision 1, 38 August 2019.

39 40 Office of the President, Executive Order 12898: Federal Actions to Address Environmental 41 Justice in Minority Populations and Low-Income Populations, 59 FR 7629, February 16, 1994.

42 43 NRC, Severe Accident Risks: An Assessment for Five U.S. Nuclear Power Plants, Final 44 Summary Report, NUREG-1150, December 1990. ADAMS Accession No. ML040140729.

45 46 NRC, Severe Accident Mitigation Design Alternatives for Certified Standard Designs, 47 SECY-91-229, July 31, 1991. ADAMS Accession No. ML003707922.

48 49 NRC, Policy Statement on the Use of Probabilistic Risk Assessment Methods in Nuclear 50 Regulatory Activities, 60 FR 42622, August 16, 1995.

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1 2 NRC, Standard Review Plans for Environmental Reviews for Nuclear Power Plants:

3 Environmental Standard Review Plan, NUREG-1555 (current version).

4 5 NRC, Denial of Petition for Rulemaking to Eliminate Review of Alternative Sites, Alternative 6 Energy Sources and Need for Power in Nuclear Power Reactor Siting and Licensing Reviews 7 (PRM-52-2), SECY-02-0175, September 27, 2002. ADAMS Accession No. ML022200469.

8 9 NRC, Environmental Review Guidance for Licensing Actions Associated with NMSS Programs, 10 Final Report NUREG-1748 (current version).

11 12 NRC, Policy Statement on the Treatment of Environmental Justice Matters in NRC Regulatory 13 and Licensing Actions, 69 FR 52040, August 24, 2004.

14 15 NRC, United States Nuclear Regulatory Commission Regulations Handbook, 16 NUREG/BR-0053 (current version).

17 18 NRC, Notice of Availability of the Final License Renewal Interim Staff Guidance 19 LR-ISG-2006-03: Staff Guidance for Preparing Severe Accident Mitigation Alternatives 20 Analyses, August 2, 2007. ADAMS Accession No. ML071640471.

21 22 NRC, An Approach for Determining the Technical Adequacy of Probabilistic Risk Assessment 23 Results for Risk-Informed Activities, RG 1.200 (current version).

24 25 NRC, An Approach for Using Probabilistic Risk Assessment in Risk-Informed Decisions on 26 Plant-Specific Changes to the Licensing Basis, RG 1.174 (current version).

27 28 NRC, State-of-the-Art Reactor Consequence Analyses (SOARCA) Report, NUREG-1935, 29 November 2012. ADAMS Accession Nos. ML12332A057 and ML12332A058.

30 31 NRC, Standard Review Plans for Environmental Reviews for Nuclear Power Plants, 32 Supplement 1: Operating License Renewal, Final Report, NUREG-1555, Supplement 1 33 (current version).

34 35 NRC, Procedural Guidance for Preparing Categorical Exclusions, Environmental Assessments, 36 and Considering Environmental Issues, Office of Nuclear Reactor Regulation Office Instruction 37 LIC-203 (current version).

38 39 NRC, Preparation of Environmental Reports for Nuclear Power Plant License Renewal 40 Applications, RG 4.2, Supplement 1 (current version).

41 42 NRC, Standard Review Plan for the Review of Safety Analysis Reports for Nuclear Power 43 Plants, Section 19.0, Probabilistic Risk Assessment and Severe Accident Evaluation for New 44 Reactors, NUREG-0800 (current version).

45 46 NRC, Proposed Updates of Licensing Policies, Rules, and Guidance for Future Reactor 47 Applications, SECY-15-0002, January 8, 2015 (ADAMS Accession No. ML13277A420 48 (package)).

NUREG/BR-0058, Rev. 5, App. I, Rev. 0 I-18