ML23109A109
| ML23109A109 | |
| Person / Time | |
|---|---|
| Issue date: | 04/18/2023 |
| From: | Jennifer Davis, Kevin Folk, Yanely Malave-Velez Office of Nuclear Material Safety and Safeguards |
| To: | Hadden K Sustainable Energy & Economic Development Coalition |
| References | |
| Download: ML23109A109 (1) | |
Text
From: Kevin Folk To: KarenD Hadden Cc: Jennifer Davis; Yanely Malave-Velez
Subject:
RE: Questions regarding GEIS revisions for Reactor License Renewals Date: Tuesday, April 18, 2023 5:02:56 PM Good evening, Ms. Hadden.
Thank you for your questions on the License Renewal GEIS revisions and proposed rule.
Our responses are provided below for each question you asked.
- 1. Does the revision in ANY way allow for reactors to operate for 80 years total instead of 60?
Response: The draft revision to the license renewal generic environmental impact statement (LR GEIS) (NUREG-1437, Revision 2) and the associated revisions to environmental findings contained in Table B-1 in Appendix B to Subpart A of 10 CFR Part 51 do not, alone, authorize NRC licensing renewal actions for any specific nuclear power plant sites. As stated in the proposed rule (88 Federal Register 13329, March 3, 2023), the revisions provide analyses of some environmental issues under the National Environmental Policy Act (NEPA) and would be used in reviews of site-specific applications for initial license renewal or one-term of subsequent license renewal. Plants that receive both an initial and a subsequent license renewal may operate for up to 80 years.
For the convenience of the public, these materials and additional background information are all available on the NRCs License Renewal Generic Environmental Review website at https://www.nrc.gov/reactors/operating/licensing/renewal/sled.html.
- 2. Please explain the significance of Category 1 vs. Category 2. Does Category 2 mean that the issue can be included as an issue in a contested case hearing?
Can Category 1 be included in such a hearing?
Response: As detailed in the LR GEIS, the NRC designates issues as Category 1 when the analyses for those issues in the LR GEIS can be applied to all nuclear power plants (or plants with specified design or site characteristics). For issues that meet the Category 1 criteria specified in the LR GEIS, no additional plant-specific analysis is required by the applicant in its license renewal environmental report or by the NRC staff in future plant-specific supplemental environmental impact statements to the LR GEIS, unless new and significant information is identified. Consistent with the existing requirements of 10 CFR 51.53(c)(3)(iv), an applicant is required to describe in its environmental report any new and significant information of which it is aware.
Category 2 issues are those that do not meet one or more of the criteria of Category 1, and therefore, require additional plant-specific review.
Questions regarding the inclusion of issues within the context of a specific contested hearing are outside the scope of the Proposed Rule, Renewing Nuclear Power Plant Operating LicensesEnvironmental Review.
- 3. Why would Severe Accidents go from Category 2 to Category 1? What is the reason for this change, and the significance of the change?
Response: The NRCs current NEPA regulation at 10 CFR 51.53(c)(3)(ii)(L) requires a consideration of alternatives to mitigate severe accidents if the NRC staff has not previously performed a Severe Accident Mitigation Alternatives Analysis (or SAMA analysis) for the applicants plant. The staff is not proposing to change this requirement. However, the proposed rule reclassifies severe accidents from Category 2 to Category 1 because the vast majority of applicants who will likely reference the LR GEIS will have previously completed a SAMA analysis. In the event a license renewal applicant referencing the revised LR GEIS had not previously completed a SAMA analysis, the applicant would need to do so and SAMAs would be the functional equivalent of a Category 2 issue under the proposed rule for that proceeding. Therefore, reclassifying severe accidents as Category 1 more accurately reflects the expectation that future license renewal applicants will not need to address the issue under existing policy. Under the proposed rule, future applicants would still have to identify any new and significant information (as for any Category 1 issue), subject to independent review by the NRC staff.
Additionally, the proposed revisions to the LR GEIS and Table B-1 are informed, in part, by lessons learned and knowledge gained from initial and subsequent license renewal environmental reviews performed by the NRC since development of the 2013 LR GEIS.
Specifically, as detailed in Appendix E of the draft revised LR GEIS, the NRCs understanding of accident risk has evolved since issuance of the 1996 and 2013 LR GEISs. Appendix E describes improvements in plant safety, improved plant operational performance, and associated lessons learned and knowledge gained that support a conclusion that severe accident risk is significantly lower than stated in the 1996 and 2013 LR GEISs. This new information in the draft revised LR GEIS further supports the NRCs existing rule to only require one SAMA analysis per facility because it indicates the likelihood of finding additional cost-effective significant plant improvements is smaller than previously expected.
- 4. Are comments due by midnight (EST) on May 2?
Response: Comments are due by 11:59 PM (EDT) May 2nd via the means specified in the Federal Register notice. As stated in the notice, comments received after May 2nd will be considered if it is practical to do so, but the NRC is able to ensure consideration only for comments received on or before May 2nd. If you prefer, you may email your comments directly to one of the points of contact for the rulemaking as follows: Yanely.Malave-Velez@nrc.gov, Jennifer.Davis@nrc.gov, or Kevin.Folk@nrc.gov, with the NRCs Office of Nuclear Material Safety and Safeguards.
- 5. Is there a written transcript from any of the public meetings that were held? Are they available to watch online?
Response: Yes, the public meetings were transcribed but not video recorded. The written transcripts will be accessible through the NRCs Agencywide Documents Access and Management System (ADAMS). They will also be posted to the NRCs License Renewal Generic Environmental Review website at https://www.nrc.gov/reactors/operating/licensing/renewal/sled.html. The transcripts are currently being processed and will be available shortly.
We have tried to respond as clearly as possible. Of course, please let us know if you
require any further clarification.
Thank you.
Kevin T. Folk Senior Environmental Project Manager/
Contracting Officers Representative Subsequent License Environmental Directorate Office of Nuclear Material Safety & Safeguards U.S. Nuclear Regulatory Commission (301) 415-6944 Kevin.Folk@nrc.gov
Original Message-----
From: KarenD Hadden <karendhadden@gmail.com>
Sent: Saturday, April 15, 2023 3:15 PM To: Yanely Malave-Velez <Yanely.Malave-Velez@nrc.gov>
Cc: Jennifer Davis <Jennifer.Davis@nrc.gov>; Kevin Folk <Kevin.Folk@nrc.gov>
Subject:
[External_Sender] Questions regarding GEIS revisions for Reactor License Renewals Hi Yanely, Jennifer and Kevin, I have a few questions to ask you regarding the license renewal GEIS revisions.
- 1) Does the revision in ANY way allow for reactors to operate for 80 years total instead of 60?
- 2) Please explain the significance of Category 1 vs. Category 2. Does Category 2 mean that the issue can be included as an issue in a contested case hearing? Can Category 1 be included in such a hearing?
- 3) Why would Severe Accidents) go from Category 2 to Category 1? What is the reason for this change, and the significance of the change?
- 4) Are comments due by midnight (EST) on May 2?
- 5) is there a written transcript from any of the public meetings that were held? Are they available to watch online?
Your help is greatly appreciated. Please feel free to call me, to set up a time to talk, or to reply by email.
Thank you so very much.
Karen Hadden, Executive Director Sustainable Energy & Economic Development (SEED) Coalition 512-797-8481