NRC: Generic Environmental Impact Statement for License Renewal of Nuclear Plants (NUREG-1437 Supplement 2, Part 4)
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By letter dated July 7, 1998, Duke Energy Corporation (Duke) submitted an application to the U.S. Nuclear Regulatory Commission (NRC) to renew the operating licenses for Units 1, 2, and 3 of the Oconee Nuclear Station (ONS) for an additional 20-year period. If the operating licenses are renewed, Federal (other than NRC) agencies, State regulatory agencies, and the owners of the plant will ultimately decide whether the plant will continue to operate. This decision will be based on factors such as the need for power or other matters within the State's jurisdiction or the purview of the owners. If the operating licenses are not renewed, Units 1, 2, and 3 will be shut down on or before the expiration of the current operating licenses, which are February 6, 2013, October 6, 2013, and July 19, 2014, respectively.
Under the National Environmental Policy Act of 1969 (NEPA), an environmental impact statement (EIS) is required for major Federal actions significantly affecting the quality of the human environment. The NRC has implemented Section 102 of NEPA in 10 CFR Part 51. In 10 CFR 51.20(b)(2), the Commission requires preparation of an EIS or a supplement to an EIS for renewal of a reactor operating license; 10 CFR 51.95(c) states that the EIS prepared at the operating license renewal stage will be a supplement to the Generic Environmental Impact Statement for License Renewal of Nuclear Plants (GEIS), NUREG-1437.(1)
Upon acceptance of the Duke application, the NRC staff began the environmental review process described in 10 CFR Part 51 by publishing a notice of intent to prepare an EIS and to conduct scoping. The staff visited the ONS site in October 1998 and held public scoping meetings on October 19, 1998, in Clemson, South Carolina. The staff reviewed the Duke environmental report (ER) and compared it to the GEIS, consulted with Federal, State, and local agencies, conducted an independent review of the issues following the guidance set forth in the draft Standard Review Plans for Environmental Reviews for Nuclear Power Plants, Supplement 1: Operating License Renewal, NUREG-1555, Supplement 1, and considered the public comments from the scoping process and the comment period for the draft Supplemental Environmental Impact Statement (SEIS) for ONS (that was issued on May 20, 1999). Two public meetings were held in Clemson, South Carolina, on July 8, 1999, during which the staff described the preliminary results of the NRC environmental review and answered questions related to it in order to provide members of the public with information to assist them in formulating their comments. This SEIS includes the NRC staff's analysis that considers and weighs the environmental effects of the proposed action, the environmental impacts of alternatives to the proposed action, and alternatives available for reducing or avoiding adverse effects. It also includes the staff's recommendation regarding the proposed action.
The Commission has adopted the following definition of purpose and need for license renewal from the GEIS:
The purpose and need for the proposed action (renewal of an operating license) is to provide an option that allows for power generation capability beyond the term of a current nuclear power plant operating license to meet future system generating needs, as such needs may be determined by State, utility, and, where authorized, Federal (other than NRC) decisionmakers.
The goal of the staff's environmental review, as defined in 10 CFR 51.95(c)(4) and the GEIS, is to determine:
... whether or not the adverse environmental impacts of license renewal are so great that preserving the option of license renewal for energy planning decisionmakers would be unreasonable.
Both the statement of purpose and need and the evaluation criterion implicitly acknowledge that there are factors, in addition to license renewal, that will ultimately determine whether ONS continues to operate beyond the period of the current operating licenses.
The GEIS contains the results of a systematic evaluation of the consequences of renewing an operating license and operating a nuclear power plant for an additional 20 years. It evaluates 92 environmental issues using a three-level standard of significance--SMALL, MODERATE, or LARGE--based on Council on Environmental Quality guidelines. These significance levels are as follows:
SMALL: Environmental effects are not detectable or are so minor that they will neither destabilize nor noticeably alter any important attribute of the resource.
MODERATE: Environmental effects are sufficient to alter noticeably, but not to destabilize, important attributes of the resource.
LARGE: Environmental effects are clearly noticeable and are sufficient to destabilize important attributes of the resource.
For 69 of the 92 issues considered in the GEIS, the analysis in the GEIS shows that
(1) the environmental impacts associated with the issue have been determined to apply either to all plants or, for some issues, to plants having a specific type of cooling system or other plant or site characteristics
(2) a single significance level (i.e., SMALL, MODERATE, or LARGE) has been assigned to the impacts (except for collective offsite radiological impacts from the fuel cycle and from high-level waste and spent fuel disposal)
(3) mitigation of adverse impacts associated with the issue has been considered in the analysis, and it has been determined that additional plant-specific mitigation measures are likely not to be sufficiently beneficial to warrant implementation.
These 69 issues are identified in the GEIS as Category 1 issues. In the absence of significant new information, the staff relied on conclusions as amplified by supporting information in the GEIS for issues designated Category 1 in 10 CFR Part 51, Subpart A, Appendix B, Table B-1.
Of the 23 issues not meeting the criteria set forth above, 21 are classified as Category 2 issues requiring analysis in a plant-specific supplement to the GEIS. The remaining two issues, environmental justice and chronic effects of electromagnetic fields, are not categorized. Environmental justice was not evaluated on a generic basis and must also be addressed in a plant-specific supplement to the GEIS. Information on the chronic effects of electromagnetic fields was not conclusive at the time the GEIS was prepared.
This SEIS documents the staff's evaluation of all 92 environmental issues considered in the GEIS. The staff considered the environmental impacts associated with alternatives to license renewal and compared the environmental impacts of license renewal and the alternatives. The alternatives to license renewal that are considered include the no-action alternative (not renewing the ONS operating licenses) and alternative methods of power generation. Among the alternative methods of power generation, coal-fired and gas-fired generation appear the most likely if the power from ONS is replaced. These alternatives are evaluated assuming that the replacement power generation plant is located at either the ONS site or an unspecified "greenfield" site.
Duke and the staff have established independent processes for identifying and evaluating the significance of any new information on the environmental impacts of license renewal. Neither Duke nor the staff has identified any significant new information related to Category 1 issues that would call into question the conclusions in the GEIS. Similarly, neither Duke nor the staff has identified any new issue applicable to the ONS that has a significant environmental impact. Therefore, the staff relies upon the conclusions of the GEIS for all 69 Category 1 issues.
The staff has reviewed the Duke analysis for each Category 2 issue and has conducted an independent review of each issue. Five Category 2 issues are not applicable because they are related to plant design features or site characteristics not found at ONS. Four Category 2 issues are not discussed in this SEIS because they are specifically related to refurbishment. Four additional Category 2 issues that apply to both refurbishment and to operation during the renewal term are only discussed in relation to operation during the renewal term. Duke has stated that their evaluation of structures and components, as required by 10 CFR 54.21, did not identify any major plant refurbishment activities or modifications necessary to support the continued operation of ONS beyond the end of the existing operating licenses. In addition, routine replacement of components or additional inspection activities are within the bounds of normal plant component replacement and therefore are not expected to affect the environment outside of the bounds of the plant operations evaluated in the Final Environmental Statement (FES) for ONS.
Twelve Category 2 issues, as well as environmental justice and chronic effects of electromagnetic fields, are discussed in detail in this SEIS. For all 12 Category 2 issues and environmental justice, the staff concludes that the potential environmental effects are of SMALL significance in the context of the standards set forth in the GEIS. In addition, the staff determined that a consensus has not been reached by appropriate Federal health agencies that there are adverse effects from electromagnetic fields. Therefore, no further evaluation of this issue is required. For severe accident mitigation alternatives (SAMAs), the staff concludes that a reasonable, comprehensive effort was made to identify and evaluate SAMAs. Based on its review of the SAMAs for ONS, the staff concludes that none of the candidate SAMAs are cost beneficial.
Mitigation measures were considered for each Category 2 issue. Current measures to mitigate environmental impacts of plant operation were found to be adequate, and no additional mitigation measures were deemed sufficiently beneficial to be warranted.
In the event that the ONS operating licenses are not renewed and the units cease operation on or before the expiration of their current operating licenses, the adverse impacts of likely alternatives will not be smaller than those associated with continued operation of ONS. The impacts may, in fact, be greater in some areas.
The NRC staff recommends that the Commission determine that the adverse environmental impacts of license renewal for Oconee Nuclear Station Units 1, 2, and 3 are not so great that preserving the option of license renewal for energy planning decisionmakers would be unreasonable. This recommendation is based on (1) the analysis and findings in the GEIS; (2) the ER submitted by Duke; (3) consultation with other Federal, State, and local agencies; (4) the staff's own independent review, and (5) the staff's consideration of public comments.
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1. The GEIS was originally issued in 1996. Addendum 1 to the GEIS was issued in 1999. Hereinafter, all references to the "GEIS" include the GEIS and its Addendum 1.
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