Generic Determinations Regarding the Environmental Impacts of Spent Fuel Storage and Disposal When Considering Nuclear Power Reactor License Applications, 31532-31542 [2016-11820]
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Proposed Rules
Federal Register
Vol. 81, No. 97
Thursday, May 19, 2016
This section of the FEDERAL REGISTER
contains notices to the public of the proposed
issuance of rules and regulations. The
purpose of these notices is to give interested
persons an opportunity to participate in the
rule making prior to the adoption of the final
rules.
NUCLEAR REGULATORY
COMMISSION
10 CFR Part 51
[Docket Nos. PRM–51–30 and PRM–51–31;
NRC–2014–0014 and NRC–2014–0055]
Generic Determinations Regarding the
Environmental Impacts of Spent Fuel
Storage and Disposal When
Considering Nuclear Power Reactor
License Applications
Nuclear Regulatory
Commission.
ACTION: Petitions for rulemaking; denial.
AGENCY:
The U.S. Nuclear Regulatory
Commission (NRC) is denying two
petitions for rulemaking (PRMs), PRM–
51–30 and PRM–51–31, submitted by
Diane Curran on behalf of 34
environmental organizations (the
petitioners). The petitioners request that
the NRC revise certain regulations that
concern the environmental impacts of
spent fuel storage and disposal for
nuclear power plant license
applications. The NRC is denying the
petitions because they provide an
insufficient basis to consider a
rulemaking to revise such regulations.
DATES: The dockets for the petitions,
PRM–51–30 and PRM–51–31, are closed
on May 19, 2016.
ADDRESSES: Please refer to Docket IDs
NRC–2014–0014 and NRC–2014–0055,
as appropriate, when contacting the
NRC about the availability of
information regarding these petitions.
You can access publicly-available
documents related to the petitions using
any of the following methods:
• Federal Rulemaking Web site: Go to
https://www.regulations.gov and search
for Docket IDs NRC–2014–0014 and
NRC–2014–0055. Address questions
about NRC dockets to Carol Gallagher;
telephone: 301–415–3463; email:
Carol.Gallagher@nrc.gov. For technical
questions, contact the individual listed
in the FOR FURTHER INFORMATION
CONTACT section of this document.
• NRC’s Agencywide Documents
Access and Management System
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SUMMARY:
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(ADAMS): You may obtain publiclyavailable documents online in the
ADAMS Public Documents collection at
https://www.nrc.gov/reading-rm/
adams.html. To begin the search, select
‘‘ADAMS Public Documents’’ and then
select ‘‘Begin Web-based ADAMS
Search.’’ For problems with ADAMS,
please contact the NRC’s Public
Document Room (PDR) reference staff at
1–800–397–4209, 301–415–4737, or by
email to pdr.resource@nrc.gov. The
ADAMS accession number for each
document referenced (if it is available in
ADAMS) is provided the first time that
it is mentioned in the SUPPLEMENTARY
INFORMATION section. For the
convenience of the reader, instructions
about obtaining materials referenced in
this document are provided in the
Section IV, Availability of Documents.
• NRC’s PDR: You may examine and
purchase copies of public documents at
the NRC’s PDR, Room O1–F21, One
White Flint North, 11555 Rockville
Pike, Rockville, Maryland 20852.
FOR FURTHER INFORMATION CONTACT:
Jenny C. Tobin, Office of Nuclear
Reactor Regulation, telephone: 301–
415–2328, email: Jennifer.Tobin@
nrc.gov; U.S. Nuclear Regulatory
Commission, Washington, DC 20555–
0001.
SUPPLEMENTARY INFORMATION:
Table of Contents
I. The Petitions
II. Reasons for Denial
III. Determination of Petitions
IV. Availability of Documents
I. The Petitions
Section 2.802 of title 10 of the Code
of Federal Regulations (10 CFR),
‘‘Petition for rulemaking,’’ provides an
opportunity for any interested person to
petition the Commission to issue,
amend, or rescind any regulation. The
NRC has consolidated its response to
PRM–51–30 and PRM–51–31 because
both petitions make similar rulemaking
requests. The NRC did not request
public comment on PRM–51–30 and
PRM–51–31 because there was
sufficient information for review and
these issues have been well-vetted in
past NRC proceedings.
PRM–51–30
The petitioners filed the first of their
two petitions on December 20, 2013, as
a part of their comments on the NRC’s
proposed Continued Storage Rule
(formerly known as the Waste
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Confidence Decision and Rule) and that
rule’s associated generic environmental
impact statement (Continued Storage
Generic Environmental Impact
Statement (GEIS)).1 The petitioners filed
a corrected version of the first petition
on January 7, 2014. The NRC published
a notice of receipt of the first petition in
the Federal Register (FR) on April 21,
2014, and assigned it Docket No. PRM–
51–30 (79 FR 22055).
The petition requests that the NRC
revise certain regulations in 10 CFR part
51 that concern the environmental
impacts of spent fuel storage and
disposal for nuclear power plants. The
NRC implements its responsibilities
under the National Environmental
Policy Act (NEPA) through its 10 CFR
part 51 regulations. The petitioners
assert that the NRC’s 10 CFR part 51
regulations are ‘‘balkanized’’ and
‘‘disparate and inconsistent,’’ and that
these regulations should be made into a
‘‘cohesive and consistent whole.’’ The
petitioners identified the following NRC
regulations as being within the scope of
their request: 10 CFR 51.53(c),2 10 CFR
51.51 (Table S–3),3 10 CFR 51.71(d),4
and Table B–1, ‘‘Summary of
1 The NRC published the Continued Storage Rule
as a proposed rule on September 13, 2013 (78 FR
56776), and as a final rule on September 19, 2014
(79 FR 56238). As part of the final rule, all of the
public comments on the proposed rule were
addressed in NUREG–2157, ‘‘Generic
Environmental Impact Statement for Continued
Storage of Spent Nuclear Fuel.’’
2 Section 51.53 is entitled ‘‘Post construction
environmental reports.’’ Paragraph (c) describes the
contents of the required environmental report
submitted by an applicant in support of its
application to renew a nuclear power plant’s
operating license.
3 Table S–3 is entitled ‘‘Table of Uranium Fuel
Cycle Environmental Data’’ and is set forth at 10
CFR 51.51. Table S–3 shows the maximum
environmental effect per annual fuel requirement
for an operating reactor and is the basis for
evaluating the contribution of the environmental
effects of uranium mining and milling, the
production of uranium hexafluoride, isotopic
enrichment, fuel fabrication, reprocessing of
irradiated fuel, transportation of radioactive
materials and management of low-level wastes and
high-level wastes related to uranium fuel cycle
activities to the environmental costs of licensing a
nuclear power reactor.
4 Section 51.71 is entitled ‘‘Draft environmental
impact statement—contents.’’ Paragraph (d)
describes the analysis required to be included in
draft EISs. For license renewal actions, the
supplemental draft EIS relies on the findings and
other supporting information in NUREG–1437,
Revision 1, ‘‘Generic Environmental Impact
Statement for License Renewal of Nuclear Plants—
Final Report’’ (2013).
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Findings on NEPA Issues for License
Renewal on Nuclear Power Plants,’’ in
appendix B to subpart A of 10 CFR part
51 (Table B–1), as well as the NRC’s
proposed amendments to 10 CFR 51.23,
as set forth in its September 13, 2013,
proposed rule (78 FR 56776).5
Section 51.53(c) and a portion of 10
CFR 51.71(d) are premised upon
NUREG–1437, ‘‘Generic Environmental
Impact Statement for License Renewal
of Nuclear Plants,’’ an environmental
impact statement (EIS) initially
published in May 1996 and then revised
and updated in June 2013 (License
Renewal GEIS).6 The License Renewal
GEIS describes the potential
environmental impacts of renewing the
operating license of a nuclear power
plant for an additional 20 years. The
NRC classifies the license renewal
issues described in the License Renewal
GEIS as either generic or site-specific.
Generic issues concern environmental
impacts that are common to all nuclear
power plants. Site-specific issues are
addressed initially by the license
renewal applicant (i.e., a nuclear power
plant licensee seeking a renewal of its
operating license under the NRC’s
license renewal regulations in 10 CFR
part 54) in its environmental report,
which is required by 10 CFR 51.45, and
then by the NRC, in its supplemental
environmental impact statement (SEIS)
to the License Renewal GEIS prepared
for each license renewal application.7
For any given license renewal action,
the License Renewal GEIS together with
the site-specific SEIS (along with any
other applicable generic EISs)
documents the NRC’s NEPA analysis.
In Table B–1, generic issues are
designated as ‘‘Category 1’’ issues and
site-specific issues are designated as
‘‘Category 2’’ issues. Absent new and
significant information, Category 1
issues are not required to be re-analyzed
for an applicant’s environmental report
or the staff’s SEIS. Table B–1 codifies
the findings of the License Renewal
GEIS and is wholly concerned with
nuclear power plant license renewal.8
5 The proposed amendments to 10 CFR 51.23
were adopted in the final rule (79 FR 56238;
September 19, 2014). Section 51.23 is entitled
‘‘Environmental impacts of continued storage of
spent nuclear fuel beyond the licensed life for
operation of a reactor’’ and states that the
Commission ‘‘has generically determined that the
environmental impacts of continued storage of
spent nuclear fuel beyond the licensed life for
operation of a reactor are those impacts identified
in NUREG–2157 [the Continued Storage GEIS]’’ (10
CFR 51.23(a)).
6 The current version of the License Renewal
GEIS is NUREG–1437, Revision 1.
7 10 CFR 51.95(c).
8 Table B–1 was amended to reflect the June 2013
License Renewal GEIS update. The NRC rule
amending Table B–1 and other 10 CFR part 51
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The purpose of Table S–3 is to
support the environmental review for
new reactor license applications. In
addition to considering the
environmental impacts of the
construction and operation of a
commercial nuclear power reactor, the
NRC considers the contributions from
the uranium fuel cycle activities.9 Table
S–3 identifies the uranium fuel cycle
impacts, generically, for new reactor
license applications.
The petitioners also assert that the
NRC’s proposed amendments to 10 CFR
51.23, as set forth in the NRC’s proposed
rule of September 13, 2013 (78 FR
56776), are ‘‘confusing’’ to the extent
that the proposed continued storage
regulation included safety findings,
which should be placed in either 10
CFR parts 50 or 52, and because the
proposed regulation no longer includes
the ‘‘reasonable assurance’’ finding. The
petitioners also assert that Table S–3 has
been ‘‘repudiated’’ and that it is
inconsistent with the findings in Table
B–1. In addition, the petitioners assert
that Table B–1 does not include a
finding as to whether offsite spent fuel
disposal impacts are significant or not.
The petitioners further assert that 10
CFR 51.53(c) and 51.71(d) ‘‘excuse’’
license renewal applicants and the NRC,
respectively, from addressing spent fuel
storage impacts in individual license
renewal cases. As both regulatory
provisions are premised upon the
findings in the License Renewal GEIS,
the petitioners, essentially, object to the
finding that impacts of spent fuel
storage during the license renewal
period are a Category 1, or generic, issue
and have a ‘‘small’’ impact. Finally, the
petitioners assert that the economic
costs of spent fuel storage and disposal
should be incorporated into reactor costbenefit analyses and that the need for
power should be considered in license
renewal decisions.
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expedited spent fuel transfer analysis),
and NUREG–2161, ‘‘Consequence Study
of a Beyond-Design-Basis Earthquake
Affecting the Spent Fuel Pool for a U.S.
Mark I Boiling Water Reactor,’’ 11
constitute new and significant
information. The petitioners request that
the NRC ‘‘duly modify NRC’s
regulations that make or rely on findings
regarding the environmental impacts of
spent fuel storage during reactor
operation, including Table B–1 and all
regulations approving standardized
reactor designs.’’
The NRC published a notice of receipt
of the second petition in the Federal
Register on May 1, 2014, and assigned
it Docket No. PRM–51–31 (79 FR
24595). The petitioners subsequently
submitted an ‘‘amended petition’’ for
rulemaking on June 26, 2014, seeking to
add ‘‘the observations made by [former]
Chairman Macfarlane in her dissenting
comments’’ on the expedited spent fuel
transfer analysis. The petitioners assert
that the former Chairman’s dissenting
vote on the expedited spent fuel transfer
analysis provides ‘‘new and significant’’
information that would affect the NRC’s
environmental reviews. The NRC
treated the ‘‘amended petition’’ as a
supplement to the February 18, 2014,
petition and re-noticed the petition,
along with the supplement, for
informational purposes only (79 FR
42989; July 24, 2014).
II. Reasons for Denial
The petitioners filed their second
petition on February 18, 2014. The
petitioners’ second petition asserts that
COMSECY–13–0030, ‘‘Staff Evaluation
and Recommendation for Japan LessonsLearned Tier 3 Issue on Expedited
Transfer of Spent Fuel’’ 10 (the
The NRC is denying the petitions
because the petitioners have not
presented a sufficient basis to amend
the regulations. The petitioners largely
contend that they present new and
significant information that requires the
agency to revisit its previous NEPA
analyses that form the bases for the
challenged regulations. Under
Commission precedent, information that
provides a ‘‘seriously different picture’’
of the environmental consequences than
previously considered is new and
significant information.12 As explained
below, the NRC finds that the
petitioners’ information does not
provide a ‘‘seriously different picture’’
of the environmental consequences of
spent fuel storage. As a result, the NRC
concludes that the current technical
regulations was published in the Federal Register
on June 20, 2013 (78 FR 37282).
9 Uranium fuel cycle activities include ‘‘uranium
mining and milling, the production of uranium
hexafluoride, isotopic enrichment, fuel fabrication,
spent fuel storage and disposal’’ (44 FR 45362;
August 2, 1979).
10 COMSECY–13–0030, ‘‘Memorandum from
Mark Satorius, Executive Director for Operations, to
NRC Commissioners Re: Staff Evaluation and
Recommendation for Japan Lessons-Learned Tier 3
Issue on Expedited Transfer of Spent Fuel’’
(November 12, 2013), and documents cited therein.
11 NUREG–2161, ‘‘Consequence Study of a
Beyond-Design-Basis Earthquake Affecting the
Spent Fuel Pool for a U.S. Mark I Boiling Water
Reactor’’ (September 2014).
12 Hydro Res. Inc., CLI–99–22, 50 NRC 3, 14
(1999) (quoting Sierra Club v. Froehike, 816 F.2d
205, 210 (5th Cir. 1987)); see generally Marsh v.
Oregon Natural Resources Council, 490 U.S. 360
(1989).
PRM–51–31
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Federal Register / Vol. 81, No. 97 / Thursday, May 19, 2016 / Proposed Rules
bases for those regulations challenged
by the petitioners remain sound.
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The petitioners assert that the NRC’s
environmental review regulations are
‘‘balkanized’’
The petitioners assert that ‘‘[t]he
NRC’s piecemeal and disjointed
approach to the consideration of spent
fuel storage and disposal impacts
violates the NEPA principle that an
agency may not segment its analysis in
a manner that conceals the
environmental significance of its
action.’’ Segmentation refers to
instances where a Federal agency splits
a project into smaller components to
avoid preparing an EIS, or where an
agency does not consider related actions
in a single EIS.13 The NRC does not
agree that its approach to the
consideration of spent fuel storage and
disposal impacts is piecemeal and
disjointed or that NRC’s environmental
review regulations in 10 CFR part 51 are
‘‘balkanized’’ or result in NEPA
segmentation.
While the petitioners have pointed to
some instances where the agency relies
on generic analyses as part of its overall
NEPA review for certain licensing
actions, the petitioners have not shown
any case where the NRC artificially
divided a licensing action into smaller
components. Rather, as discussed
below, the NRC fully considers the
environmental impacts of each licensing
action through a combination of sitespecific EISs and, where appropriate,
GEISs. The use of generic analyses by
the NRC to support licensing decisions
has been upheld by the U.S. Supreme
Court.14
In addition to the License Renewal
GEIS and the Continued Storage GEIS,
the NRC prepares EISs for all new
reactor and license renewal
applications. Within the umbrella of
both its generic and site-specific EISs,
the NRC adequately considers the spent
fuel storage impacts of its licensing
decisions. The EISs for new nuclear
power reactors describe the
environmental impacts from the onsite
storage and management of spent
13 Delaware Riverkeeper Network v. FERC, 753
F.3d 1304, 1313 (D.C. Cir. 2014) (‘‘An agency
impermissibly ‘segments’ NEPA review when it
divides connected, cumulative, or similar federal
actions into separate projects and thereby fails to
address the true scope and impact of the activities
that should be under consideration.’’); see also
Council on Environmental Quality (CEQ)
regulation, 40 CFR 1508.25.
14 In a 1983 decision concerning a challenge to
Table S–3, the U.S. Supreme Court stated that ‘‘[t]he
generic method chosen by the agency is clearly an
appropriate method of conducting the hard look
required by NEPA.’’ Baltimore Gas & Elec. Co. v.
NRDC, 462 U.S. 87, 101, 103 S.Ct. 2246, 2254
(1983).
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nuclear fuel and offsite disposal based
on 40 years of reactor operation, which
is the maximum initial term of a reactor
license.15 The License Renewal GEIS
describes the environmental impacts
from the onsite storage and offsite
disposal of spent nuclear fuel generated
during an additional 20 years of reactor
operation (i.e., 20 years beyond the
expiration of the initial license).16 The
Continued Storage GEIS describes the
environmental impacts of the continued
storage of spent nuclear fuel beyond the
licensed life for operation of a reactor.
Additionally, spent fuel storage and
disposal impacts are considered by the
NRC staff during each new reactor
license and license renewal
environmental review to determine if
there is new and significant information
that could alter the generic conclusions.
Moreover, the underlying technical
bases for the consideration of spent fuel
storage and disposal impacts in EISs for
new power reactor licenses and the
License Renewal GEIS are the same.
Combined with the Continued Storage
GEIS, these NEPA documents provide a
complete analysis of spent fuel storage
and disposal environmental impacts.
The regulations in 10 CFR part 51 are
premised upon, and support, this NEPA
framework of generic EISs supported by
site-specific EISs.
The NRC’s approach improves the
effectiveness of environmental reviews
by generically resolving issues that are
not substantially different from one
proposed action to another, while still
ensuring that those impacts are
considered in subsequent licensing
actions. The NRC conducts
environmental and safety reviews for
the issuance of licenses for the
operation of nuclear power plants
including the onsite storage of spent
nuclear fuel. The NRC has also
conducted separate environmental and
safety reviews for the issuance of
specific licenses for the storage of spent
nuclear fuel in independent spent fuel
storage installations (ISFSIs).17 With
respect to spent fuel disposal, an EIS
would fully discuss the environmental
impacts for any proposed action to
dispose of spent fuel in a geologic
repository. In addition, the NRC has
previously determined the potential
radiological effects of offsite spent fuel
disposal in a permanent repository or
some other permanent disposal scenario
15 10
CFR 52.104.
CFR 54.31.
17 NRC regulation, 10 CFR 72.3, defines an ISFSI
as ‘‘a complex designed and constructed for the
interim storage of spent nuclear fuel.’’
16 10
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while evaluating the environmental
effects of the uranium fuel cycle.18
The consideration of spent fuel
storage and disposal environmental
impacts builds upon the knowledge
gained from previous environmental
reviews and associated rulemakings and
is consistent throughout the NRC’s
regulations in that the NRC relies on the
same technical bases to make impact
determinations. The only differences are
the timeframes in which these impacts
occur and whether the impacts occur
during continued onsite storage or
offsite disposal. In each of these
regulatory situations, the technical bases
remain the same.
Tables S–3 and B–1 in the NRC’s
regulations were developed at separate
times for different purposes but have
common technical bases. The 2014
continued storage rule, and its
supporting Continued Storage GEIS,
updated the NRC’s NEPA findings in
Table B–1 for issues pertaining to
‘‘Onsite storage of spent nuclear fuel’’
and ‘‘Offsite radiological impacts of
spent nuclear fuel and high-level waste
disposal.’’ In doing so, the NRC
effectively incorporated the NEPA
analysis of continued spent fuel storage
into license renewal. For new reactors,
10 CFR 51.23(b) directs that the impact
determinations in NUREG–2157 shall be
deemed incorporated into the associated
EIS. And for licensing actions for which
an environmental assessment (EA) is
being prepared (such as an ISFSI built
under a specific license at a site
occupied by a nuclear power reactor),
10 CFR 51.30(b) directs that the impacts
determinations in NUREG–2157
regarding the continued storage of spent
fuel shall be considered, if such impacts
are relevant to the proposed action.
For a given future reactor licensing
action that relies on the Continued
Storage GEIS and rule, the NRC will
incorporate the environmental impacts
analyzed in the Continued Storage GEIS
into the overall licensing decision. The
NRC’s NEPA review for each licensing
action that involves either a new reactor
or a license renewal application will
fully account for the reasonably
foreseeable impacts of spent fuel storage
and disposal, including, where
applicable, the impacts that have been
analyzed generically in the Continued
Storage GEIS and License Renewal
GEIS. The NRC concludes that its 10
CFR part 51 environmental review
regulations are internally consistent and
are not inappropriately segmented, and
18 See WASH–1248, ‘‘Environmental Survey of
the Uranium Fuel Cycle,’’ April 1974, and NUREG–
0116, ‘‘Environmental Survey of the Reprocessing
and Waste Management Portions of the LWR Fuel
Cycle,’’ October 1976.
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therefore, there is no reason to amend
these regulations.
The petitioners assert that Table S–3
has been repudiated
The petitioners’ expert, Dr. Arjun
Makhijani, in a declaration attached to
the petitioners’ January 2014
submission, states that the Table S–3
finding regarding the impacts of spent
fuel disposal is no longer valid because
the finding is based upon the disposal
of spent fuel in a bedded salt repository
and that such disposal would result in
zero releases of radioactive effluents,
and therefore, zero radiological dose. Dr.
Makhijani asserts that
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[m]oreover, we note that Table S–3 at 10 CFR
51.51 is invalid for estimating high-level
waste disposal impacts. Among other things,
its underlying assumption of disposal in a
bedded salt repository for spent fuel disposal
was repudiated by the NRC itself in 2008.19
The petitioners, through Dr. Makhijani’s
declaration, assert that the NRC must
prepare a new analysis concerning the
impacts of spent fuel disposal.
Contrary to Dr. Makhijani’s assertion,
the NRC has never repudiated Table S–
3; the original assumption of spent fuel
disposal in a bedded salt repository is
not germane to the overall purpose of
Table S–3 nor does the change in media
for storing spent fuel undermine the
findings of Table S–3. Dr. Makhijani’s
statement evaluates Table S–3 in
isolation and does not consider later
developments in the NRC’s regulatory
policy and U.S. Supreme Court
precedent. The Atomic Energy
Commission, the predecessor agency of
the NRC, promulgated the initial version
of Table S–3 on April 22, 1974 (39 FR
14188). Since the promulgation of Table
S–3, the Nuclear Waste Policy Act of
1982 (NWPA) adopted deep geologic
disposal as the nation’s solution for
spent fuel disposal. Furthermore, in
1983 the U.S. Supreme Court, in its
Baltimore Gas & Elec. Co. v. National
Resources Defense Council (NRDC)
decision,20 upheld both Table S–3 and
the approach taken by the NRC in using
Table S–3 data in individual licensing
proceedings. In Baltimore Gas & Elec.
Co. v. NRDC, the U.S. Supreme Court
recognized that the purpose of Table S–
3 was not to evaluate or select the most
effective long-term waste disposal
technology or develop site selection
criteria.21 The Court noted that the
19 ‘‘Declaration of Dr. Arjun Makhijani Regarding
the Waste Confidence Proposed Rule and Draft
Generic Environmental Impact Statement,’’ attached
to PRM–51–30 (paragraph 2.8 on p. 6).
20 Baltimore Gas & Elec. Co. v. National
Resources Defense Council, 462 U.S. 87, 103 S.Ct.
2246 (1983).
21 Id., 462 U.S. at 102, 103 S.Ct. at 2254–55.
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NRC’s intent, as stated in the 1979 rule
revising Table S–3 (44 FR 45362; August
2, 1979), was to estimate the impact of
the long-term waste disposal method
conservatively.22
This conservative analysis included
the NRC’s use of the zero release
assumption.23 The Court also noted that
other aspects of Table S–3 were
premised upon the assumption that ‘‘all
volatile materials in the fuel would
escape to the environment’’ prior to the
sealing of the geologic repository; this
assumption balanced the zero-release
assumption, an approach that the Court
found acceptable.24 In addition to
concluding that it was ‘‘not
unreasonable’’ for the NRC to employ
the zero release assumption, the Court
stated that ‘‘the zero-release assumption
is but a single figure in an entire Table,
which the Commission expressly
designed as a risk-averse estimate of the
environmental impact of the fuel cycle
. . . [a] reviewing court should not
magnify a single line item beyond its
significance as only part of a larger
Table.’’ 25
Following the enactment of the
NWPA and the Baltimore Gas & Elec.
Co. v. NRDC decision, the NRC issued
a Waste Confidence decision in 1984 (49
FR 34658; August 31, 1984) and
subsequently updated this decision in
1990 (55 FR 38472; September 18, 1990)
and again in 2010 (75 FR 81032;
December 23, 2010). In its 1990
revision, the Commission discussed the
relationship of Table S–3 with its Waste
Confidence decision. Specifically, the
Commission noted that the
promulgation of Table S–3 was the
outgrowth of efforts to generically
evaluate the environmental impacts of
the operation of a light water reactor
and in so doing, that Table S–3 assigned
numerical values for environmental
costs resulting from uranium fuel cycle
activities to support 1 year of light water
reactor operation. The number of curies
indicated for spent fuel disposal in
Table S–3 reflects the total volume of
waste material, not the amount of
radioactivity projected to be released
from the repository—an issue that is to
be addressed in the safety and
environmental review for the actual
geologic repository itself.
Table S–3 lists environmental data to
be used by applicants and the NRC staff
for new reactor license applications
under 10 CFR parts 50 and 52.
22 Id.,
462 U.S. at 102, 103 S.Ct. at 2255.
(‘‘The zero-release assumption cannot be
evaluated in isolation. Rather, it must be assessed
in relation to the limited purpose for which the
Commission made the assumption.’’).
24 Id., 462 U.S. at 103, 103 S.Ct. at 2255.
25 Id., 462 U.S. at 102–03, 103 S.Ct. at 2255.
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Specifically, Table S–3 is the basis for
evaluating the environmental effects of
the portions of the uranium fuel cycle
for light water reactors that occur before
new fuel is delivered to the plant and
after spent fuel is removed from the
plant site. The NRC has made generic
determinations that the radiological
impacts of the uranium fuel cycle on
individuals off-site will remain at or
below the Commission’s regulatory
limits (e.g., the public dose limits set
forth in 10 CFR part 20). The NRC
described this generic determination
and conclusion in the License Renewal
GEIS.26 Additionally, as part of the new
reactor EISs under 10 CFR part 52 and
the License Renewal GEIS, the NRC
concluded that the assumptions and
methodology used in preparing Table S–
3 were conservative enough that the
impacts described by the use of Table
S–3 would still be bounding. In these
EISs, the staff discussed why the
contemporary fuel cycle impacts are
below those identified in Table S–3 and
as such, Table S–3 remains bounding.27
The NRC concludes that Table S–3 is
bounding because, as reflected in
Section 4.12.1.1 of the License Renewal
GEIS, industry practice has shown that
the current fleet of reactors uses nuclear
fuel more efficiently due to higher fuel
burnup. Therefore, less uranium fuel
per year of reactor operation is required
than in the past to generate the same
amount of electricity. Fewer spent fuel
assemblies per reactor-year are
generated, hence, the waste storage and
deep geologic repository impacts are
lessened. The petitioners have not
provided any new and significant
information that would cause the NRC
to revisit these conclusions regarding
Table S–3.
While the NRC and the U.S.
Department of Energy (DOE) have, in
the past, concentrated efforts regarding
geologic repository research and
licensing efforts on a non-bedded salt
repository, characterizing the resulting
analysis as confirming that there is a
risk of ‘‘significant’’ radiation releases
and radiation doses from deep geologic
disposal is not accurate. As stated in
Volume 1, Appendix B of the Continued
Storage GEIS, ‘‘the consensus within the
scientific and technical community
engaged in nuclear waste management
is that safe geologic disposal is
achievable with currently available
technology. After decades of research
into various geological media, no
23 Id.
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26 2013
GEIS section 4.12.1.1, p. 4–185.
example, see the Bell Bend Nuclear Power
Plant EIS, NUREG 2179, vol. 1, section 6.1 (April
2015), for a discussion of the NRC determination
that Table S–3 remains bounding.
27 For
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insurmountable technical or scientific
problem has emerged to challenge the
conclusion that safe disposal of spent
fuel and high-level radioactive waste
can be achieved in a mined geologic
repository.’’ 28
The issue of concern to the NRC in
considering the disposal of spent
nuclear fuel in a geologic repository has
not been whether a zero-release
assumption will be met or ultimately
the type of environmental media (e.g.,
bedded salt, basalt, granite, etc.)
selected for the repository but rather
that the appropriate standards are
established and met, thereby ensuring
that any releases of radioactive materials
to the environment would not be
inimical to public health and safety.
Radiation dose limits for disposal of
radioactive materials are typically no
greater than 100 mrem/yr (such as the
U.S. Environmental Protection Agency
(EPA) limits for the proposed Yucca
Mountain geologic repository).
Although a geologic repository meeting
such radiation dose limits is not a
‘‘zero’’ release facility, compliance with
these dose limits would provide
adequate protection of public health and
safety. Given the substantial effort
developing repositories, it is reasonable
to assume geologic disposal facilities
can be developed within a variety of
geologic formations and types that
would be protective of public health
and safety. For example, the NRCNational Academy of Sciences (NAS)
study, referred to by Dr. Makhijani,
concludes on the overall performance of
candidate repositories that ‘‘[a]ll
radionuclides in unreprocessed spent
fuel can be adequately contained.’’ 29 In
conclusion, the NRC has determined
that Table S–3 is still bounding and that
the petitioners have not provided new
and significant information that requires
the NRC to amend Table S–3.
The petitioners assert that Table S–3
and Table B–1 are inconsistent with
each other
The petitioners assert that Table S–3
and Table B–1 are inconsistent with
each other. The petitioners state in
PRM–51–30, ‘‘[t]he inconsistencies and
questions raised by comparing Table S–
3 and Table B–1 are unacceptable under
NEPA’s standard for clarity and rigor of
scientific analysis.’’ In his comments,
Dr. Makhijani stated,
Table S–3 summarizes the NRC’s
conclusion that the impacts of spent fuel
28 NUREG–2157,
pg. 2 of Appendix B, Section
B.2.1.
29 NRC–NAS Report, ‘‘A Study of the Isolation
System for Geologic Disposal of Radioactive
Wastes,’’ p. 8 and 11.
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disposal will be zero, based on the
assumption that spent fuel will be disposed
of in a bedded salt repository. Proposed
Table B–1 contradicts Table S–3 by
concluding that long-term doses could be as
high as 100 millirem per year. But the NRC
does not attempt to reconcile proposed Table
B–1 and Table S–3. . . .30
The environmental effects of
operating uranium fuel cycle facilities
including radioactive waste disposal at
a geologic repository were evaluated in
two NRC documents, WASH–1248 and
NUREG–0116. The results of these
evaluations were summarized in and
promulgated as Table S–3 in 10 CFR
51.51(b). Paragraph (a) in 10 CFR 51.51
states:
[E]very environmental report prepared for
the construction permit stage or early site
permit stage or combined license stage of a
light-water-cooled nuclear power reactor, and
submitted on or after September 4, 1979,
shall take Table S–3, Table of Uranium Fuel
Cycle Environmental Data, as the basis for
evaluating the contribution of the
environmental effects of uranium mining and
milling, the production of uranium
hexafluoride, isotopic enrichment, fuel
fabrication, reprocessing of irradiated fuel,
transportation of radioactive materials and
management of low-level wastes and highlevel wastes related to uranium fuel cycle
activities to the environmental costs of
licensing the nuclear power reactor. Table S–
3 shall be included in the environmental
report and may be supplemented by a
discussion of the environmental significance
of the data set forth in the table as weighed
in the analysis for the proposed facility.
The environmental effects or issues
summarized in Table S–3 include: Land
use; water consumption and thermal
effluents; radioactive releases; burial of
transuranic, high-level and low-level
radioactive wastes; and radiation doses
from transportation and occupational
exposures. The contributions in Table
S–3 for reprocessing, waste
management, and transportation of
wastes are maximized for either of the
two fuel cycles (i.e., a fuel cycle that
includes spent fuel reprocessing and
one that does not)—the cycle that
results in the greater environmental
impact, and thus the most conservative
analysis, is used. The environmental
impact values are expressed in terms
normalized to show the potential
impacts attributable to processing the
fuel required for the operation of a
1,000–MWe nuclear power plant for 1
year at an 80 percent availability factor
to produce about 800 MW-yr of
electricity. This normalization is
referred to as one reference reactor year.
For each environmental consideration,
Table S–3 presents a result that has been
30 Makhijani
Declaration attached to PRM–51–30,
p. 9.
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integrated over the entire uranium fuel
cycle except during reactor
operations.31 The environmental
impacts of reactor operations are
addressed in the EIS prepared for each
individual reactor licensing action (i.e.,
an EIS for a new reactor licensing
application or a SEIS for a license
renewal application). Although certain
fuel cycle operations and fuel
management practices have changed
over the years, the assumptions and
methodology used in preparing Table S–
3 were, and continue to be, conservative
enough that the impacts described in
Table S–3 are still bounding.
In similar fashion, the NRC assessed
the generic environmental impacts of
renewing the operating license for a
nuclear power plant in the License
Renewal GEIS. Table B–1 summarizes
the Commission’s findings on the scope
and magnitude of the environmental
effects of renewing the operating license
for a nuclear power plant, based on
technical bases documented in the 2013
update of the License Renewal GEIS.
Subject to an evaluation of those
Category 2 issues, which require further
site-specific analysis, and the
identification of possible new and
significant information for any Category
1 or Category 2 issue, Table B–1
represents the analysis of the
environmental impacts associated with
the renewal of any operating license and
is to be used in accordance with 10 CFR
51.95(c). On a 10-year cycle, the
Commission intends to review the
findings in Table B–1 and update the
table if necessary. The latest review and
update was completed in 2013.
Both the License Renewal GEIS and
Table B–1 incorporate Table S–3 by
reference.32 Tables S–3 and B–1 were
developed at separate times for different
purposes. However, the technical bases
for the consideration of spent fuel
storage and disposal impacts for both
tables are the same, and as such, the
tables are consistent with each other.
The impact of the spent nuclear fuel
disposal finding in Table B–1 (i.e.,
‘‘Offsite radiological impacts of spent
nuclear fuel and high-level waste
disposal’’) is consistent with the solid
waste disposal information presented in
Table S–3, as the findings in Table B–
1 could not have been reached without
the environmental effects evaluations
conducted in WASH–1248 and NUREG–
31 The only exception is that the waste quantities
listed under the entry called ‘‘solids (buried
onsite)’’ also include wastes generated at the
reactor.
32 Table B–1 references Table S–3 under the
‘‘Uranium Fuel Cycle’’ section of the table.
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0116, which are summarized in Table
S–3.
Moreover, even if there were
differences in the assumptions in Table
S–3 and Table B–1, those differences are
not significant from a NEPA
perspective. As noted above, the issue of
concern to the NRC in considering the
environmental impacts of the disposal
of spent nuclear fuel in a geologic
repository has not been whether a zerorelease assumption will be met or
ultimately the type of environmental
media (e.g., bedded salt, basalt, granite,
etc.) selected for the repository but
rather that the appropriate standards are
established and met, thereby ensuring
that any releases of radioactive materials
to the environment would not be
inimical to public health and safety. For
NEPA purposes, such releases within
regulatory limits are clearly not
significant radiation releases and
radiation doses. The NRC concludes
that Tables B–1 and S–3 are consistent
with each other and there is no
technical or regulatory reason to amend
either table.
No significance determination for ‘‘offsite spent fuel disposal’’ in Table B–1
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The petitioners assert that Table B–1,
which codifies the findings of the
License Renewal GEIS, does not include
a finding as to whether the impacts of
spent fuel disposal are significant or
not. The ‘‘significance determination’’
in NEPA is made by an agency in
determining whether it is necessary to
prepare an EIS for a given proposed
action.33 With respect to the
environmental review of reactor license
renewal applications, the NRC has
already prepared a GEIS, the License
Renewal GEIS. In addition, for each sitespecific license renewal action, the NRC
prepares a SEIS. Therefore, the lack of
a finding as to whether the impacts of
spent fuel disposal are ‘‘significant’’ or
‘‘not significant’’ is irrelevant, as the
NRC has already satisfied the
‘‘significance determination’’ by
preparing a generic EIS and by its
regulatory requirement to prepare a site33 Lower Alloways Creek Tp. v. Public Service
Elec. & Gas Co., 687 F.2d 732, 740 (3rd Cir. 1987)
(‘‘[A]n agency must undertake a comprehensive
assessment of the expected effects of a proposed
action before it can determine whether that action
is ‘significant’ for NEPA purposes . . . . [i]f,
however, it is clear that the human environment
will be ‘significantly’ affected, then a full-scale EIS
is mandatory.’’); Blue Mountains Biodiversity
Project v. Blackwood, 161 F.3d 1208, 1211–14, and
1216 (9th Cir. 1998) (Forest Service made clear error
of judgment in its decision to prepare an
environmental assessment, rather than an
environmental impact statement); see also
Mandelker, NEPA Law and Litigation, 2d, §§ 8.48–
8.58.
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specific EIS for each reactor license
renewal application it considers.
Moreover, the NRC has extensively
analyzed spent fuel storage and disposal
environmental impacts in Table S–3,
and in various EISs, namely, the License
Renewal GEIS, the Continued Storage
GEIS, and SEISs for individual license
renewal actions. The License Renewal
GEIS provides the regulatory and
technical basis for the Commission’s
findings and the associated impact
significance levels for each
environmental NEPA issue listed in
Table B–1. The NRC’s evaluation of the
environmental impacts of the issue,
‘‘Offsite radiological impacts of spent
nuclear fuel and high-level waste
disposal,’’ 34 was documented in the
1996 License Renewal GEIS, which
relied upon the findings of the NRC’s
1990 Waste Confidence Decision and
Rule. In addition, the NRC analyzed the
EPA’s generic repository standards and
dose limits in existence at the time and
concluded that offsite radiological
impacts warranted a Category 1
(generic) determination (61 FR 28467;
June 5, 1996). However, due to the
decision of the U.S. Court of Appeals for
the DC Circuit in New York v. NRC and
its remand of the 2010 Waste
Confidence Decision and Rule (75 FR
81032; December 23, 2010), the NRC
was not able to complete its review and
update of the impact finding for this
issue in the 2013 License Renewal GEIS
(NUREG–1437, Revision 1) and update
of Table B–1. As a result, the 2013
License Renewal GEIS and rule (78 FR
37282; June 20, 2013) reclassified the
issue from Category 1 with no impact
level assigned, to an uncategorized issue
with an uncertain impact level.
On August 26, 2014, the Commission
approved the Continued Storage Rule
and its associated GEIS (Continued
Storage GEIS) amending 10 CFR part 51
to revise the generic determination on
the environmental impacts of continued
storage of spent nuclear fuel beyond the
licensed life for operation of a reactor.
In making conforming changes to the
Table B–1 entry for the issue ‘‘Offsite
radiological impacts of spent nuclear
fuel and high-level waste disposal,’’ the
final rule restored the Category 1
designation and references the existing
radiation protection standards for Yucca
Mountain instead of making a single
impact finding.
The NRC’s practice, once it has
determined to prepare an EIS, has been
to assign a significance level to most
potential environmental impacts, by
resource area or environmental issue,
arising from the proposed action. These
levels are ‘‘Small, Moderate, and Large.’’
The assigning of these levels to any
given impact is not required by law; it
is solely a matter of NRC practice.
Neither the Council on Environmental
Quality’s nor the NRC’s regulations for
implementing NEPA under 10 CFR part
51 explicitly require an agency to assign
a single significance level to
environmental impact issues; CEQ
regulations state that ‘‘[i]mpacts shall be
discussed in proportion to their
significance’’ in the context of preparing
environmental impact statements for
agency actions.35 Further, NRC does not
assign such a level to every resource
area or environmental issue covered by
a given EIS. The NRC only assigns a
single significance level for a generic
issue where it is meaningful and
appropriate to do so when considering
both the context and intensity of a
potential environmental impact.36
In this regard, the NRC has never
assigned a single impact significance
level to the issue of ‘‘Offsite radiological
impacts of spent nuclear fuel and highlevel waste disposal.’’ Although the
status of a repository, including a
repository at Yucca Mountain, remains
uncertain and beyond the control of the
NRC, the NRC has adopted EPA’s
radiation protection standards (40 CFR
part 197) for Yucca Mountain because
they are the current standard for
ensuring that the ultimate disposal of
spent nuclear fuel will present no
undue risk to public health and safety.
As discussed in the Continued Storage
GEIS, it is reasonable to believe that
wherever a geologic repository is
ultimately sited, radiological protection
standards comparable to those
established for Yucca Mountain will be
issued if necessary. Given these
considerations, the Commission’s
narrative finding in Table B–1 with
respect to the issue of offsite disposal is
appropriate. That finding states ‘‘[t]he
Commission concludes that the impacts
would not be sufficiently large to
require the NEPA conclusion, for any
plant, that the option of extended
operation under 10 CFR part 54 should
be eliminated. Accordingly, while the
Commission has not assigned a single
level of significance for the impacts of
spent fuel and high level waste disposal,
this issue is considered Category 1.’’
Therefore, the Commission, by rule, has
determined that a single significance
determination is not necessary.
35 40
34 This
issue was named ‘‘Offsite radiological
impacts (spent fuel and high level waste disposal)’’
in the 1996 license renewal GEIS and rule.
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31537
CFR 1502.2(b).
CEQ regulation 40 CFR 1508.27, which
defines the term ‘‘significantly,’’ in relation to both
‘‘context’’ and ‘‘intensity.’’
36 See
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The NRC concludes that the
petitioners’ significance determination
argument does not provide a ‘‘seriously
different picture’’ of the environmental
consequences of spent fuel storage and
disposal. Instead, based on the above,
the NRC concludes that the petitioners’
assertion that NEPA requires an agency
to assign a single level of significance to
the issue in question is without merit
and that the petitioners’ proposed
amendment to the NRC’s finding for the
issue, ‘‘Offsite radiological impacts of
spent nuclear fuel and high-level waste
disposal,’’ in Table B–1 in appendix B
to subpart A of 10 CFR part 51 is not
necessary.
The petitioners assert that license
renewal applicants in 10 CFR 51.53(c)
and NRC staff in 10 CFR 51.71(d) are
excused from addressing spent fuel
storage impacts in license renewal
environmental reviews
The NRC disagrees with the
petitioners’ assertion that the NRC’s
regulations in 10 CFR 51.53(c) and
51.71(d) ‘‘excuse license renewal
applicants and the NRC from addressing
spent fuel storage impacts in license
renewal cases.’’ The NRC has
determined that the potential
environmental impacts of spent fuel
storage are of a generic nature and as
such, do not need to be re-analyzed for
every license renewal action. As
mentioned previously, for future reactor
license renewal applications that rely on
the Continued Storage and License
Renewal GEISs, the NRC will
incorporate the environmental impacts
analyzed in the Continued Storage GEIS
as well as in the License Renewal GEIS
into the overall NEPA analysis
supporting its licensing decision. The
U.S. Supreme Court has upheld the use
of generic environmental analyses by
the NRC.37 Moreover, as part of its
environmental review for each license
renewal application, the NRC reviews
both generic and site-specific issues for
new and significant information. In the
event that the NRC determines that
there is new and significant
information, the NRC will consider such
information when preparing the SEIS
for that particular licensing action and,
if necessary, will also determine
whether the License Renewal GEIS or
Continued Storage GEIS should be
revised accordingly.
Moreover, the quality of the NRC’s
environmental analysis of spent fuel
storage is not dependent on whether the
37 Baltimore Gas & Elec. Co. v. NRDC, 462 U.S.
at 101, 103 S.Ct. at 2254 (‘‘The generic method
chosen by the agency is clearly an appropriate
method of conducting the hard look required by
NEPA.’’).
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NRC prepares a site-specific or generic
analysis. In developing both the License
Renewal GEIS and the Continued
Storage GEIS, the NRC employed
assumptions, including those based
upon reactor licensee operating
experience, that are sufficiently
conservative to bound the predicted
impacts such that any variances that
may occur from site to site are unlikely
to result in environmental impact
determinations that are greater than
those presented in both GEISs.38 In
addition, recent spent fuel studies
(including the expedited spent fuel
transfer regulatory analysis included in
COMSECY–13–0030 and NUREG–2161)
continue to support the findings of the
License Renewal GEIS. Though the
studies may contain ‘‘new’’ information,
the information is not ‘‘significant’’ for
the purpose of the environmental
analysis. The NUREG–2161 compared
spent fuel pool accident consequences
from previous research studies and
determined that they were of the same
magnitude. Finally, the Continued
Storage GEIS reinforces the
Commission’s original determination
that supports use of a generic analysis.
The NRC concludes that the
petitioners’ arguments regarding 10 CFR
51.53(c) and 51.71(d) do not provide a
‘‘seriously different picture’’ of the
environmental consequences of spent
fuel storage and disposal. Instead, based
on the above, the NRC concludes that
spent fuel storage impacts are fully
evaluated as part of the NRC’s license
renewal actions and that the petitioners’
proposed amendments are not
necessary.
The petitioners assert that the need for
power and economic costs were
excluded in license renewal
environmental reviews
The petitioners assert that NRC
regulations in 10 CFR 51.53(c) and
51.71(d) excuse license renewal
applicants and the NRC staff from
addressing the need for power in license
renewal cases. The petitioners state,
‘‘[b]y excluding need for power from
consideration in re-licensing decisions,
the [Continued Storage] GEIS cripples
its ability to assess the environmental
impacts of storing spent fuel. This
results in an ‘unbounded’ analysis of
radiological risk.’’ The petitioners also
assert that ‘‘it is essential to incorporate
the economic costs of spent fuel storage
and disposal in reactor cost-benefit
analyses.’’ In conjunction with the
issuance of the License Renewal GEIS in
1996, the Commission amended its
regulations concerning environmental
reviews for nuclear power plant license
renewal actions.39 These amendments
defined the generic environmental
impacts addressed in the License
Renewal GEIS and the environmental
impacts for which nuclear plant sitespecific analyses were to be performed.
The Commission stated in the June 5,
1996, final rule for the ‘‘Environmental
Review for Renewal of Nuclear Power
Plant Operating Licenses,’’
[T]he NRC will neither perform analyses of
the need for power nor draw any conclusions
about the need for generating capacity in a
license renewal review. [The] definition of
purpose and need reflects the Commission’s
recognition that, absent findings in the safety
review required by the Atomic Energy Act of
1954, as amended, or in the NEPA
environmental analysis that would lead the
NRC to reject a license renewal application,
the NRC has no role in the energy planning
decisions of State regulators and utility
officials. From the perspective of the licensee
and the State regulatory authority, the
purpose of renewing an operating license is
to maintain the availability of the nuclear
plant to meet system energy requirements
beyond the term of the plant’s current
license.40
As stated in the 2013 License Renewal
GEIS,
The purpose and need for the proposed
action (issuance of a renewed license) is to
provide an option that allows for baseload
power generation capability beyond the term
of the current nuclear power plant operating
license to meet future system generating
needs. Such needs may be determined by
other energy-planning decision-makers, such
as State, utility, and, where authorized,
Federal agencies (other than the NRC).
Unless there are findings in the safety review
required by the Atomic Energy Act or the
NEPA environmental review that would lead
the NRC to reject a license renewal
application, the NRC does not have a role in
the energy-planning decisions of whether a
particular nuclear power plant should
continue to operate.41
As shown by these statements, it has
been the NRC’s longstanding position
not to consider the need for power or
economic costs in making its license
renewal decisions. Consideration of the
need for power or the economic cost of
renewing the operating license of a
nuclear reactor is beyond the NRC’s
statutory and regulatory purview; rather,
such consideration is the responsibility
of State and local authorities and, where
appropriate, Federal entities such as the
Federal Energy Regulatory Commission
or the Tennessee Valley Authority. The
39 61
38 Statements
of Consideration for 1996 (61 FR
28467, 28479–480) and 2013 (78 FR 37282, 37310)
License Renewal GEISs.
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FR 28467; June 5, 1996.
FR at 28472.
41 License Renewal GEIS, NUREG–1437, Revision
1 (2013), Section 1.3, p. 1-3–1-4.
40 61
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petitioners’ assertion that NRC’s
regulatory approach of excluding need
for power from consideration in license
renewal decisions ‘‘cripples’’ NRC’s
ability to assess the environmental
impacts of storing spent fuel is not new
and significant information and thus
does not provide a basis for amending
the regulations.
‘‘Reasonable assurance’’ findings not
included in proposed 10 CFR 51.23
In commenting upon the NRC’s
proposed Continued Storage rule (78 FR
56776; September 13, 2013), the
petitioners asserted that the NRC’s
proposal to remove the ‘‘reasonable
assurance’’ statement from 10 CFR
51.23(a) was improper. Prior to the
promulgation of the Continued Storage
final rule (79 FR 56238; September 19,
2014), 10 CFR 51.23(a) stated, in part,
that ‘‘the Commission believes there is
reasonable assurance that sufficient
mined geologic repository capacity will
be available to dispose of the
commercial high-level radioactive waste
and spent fuel generated in any reactor
when necessary.’’ 42 In the final
Continued Storage rule, the NRC
removed the ‘‘reasonable assurance’’
statement.43 The statements of
consideration of the final Continued
Storage rule explain that 10 CFR
51.23(a) sets forth the NRC’s generic
determination that the environmental
impacts of the continued storage of
spent nuclear fuel beyond the licensed
life for operation of a reactor are those
impacts identified in NUREG–2157 (the
Continued Storage GEIS). In particular,
the statements of consideration note
that,
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NEPA is a procedural statute directed at
Federal agencies, and 10 CFR 51.23
(including the additional clarifying
amendments) addresses the manner by which
the NRC complies with NEPA with respect to
the subject of continued storage. These
amendments do not require action by any
person or entity regulated by the NRC, nor do
these amendments modify the substantive
responsibilities of any person or entity
regulated by the NRC.44
Consequently, there was no need to
retain the ‘‘reasonable assurance’’
statement, which is a safety finding, as
10 CFR 51.23(a) stated only the generic
environmental determination and the
remainder of 10 CFR 51.23 concerns the
NRC’s NEPA compliance. In this regard,
the statements of consideration explain,
The [Continued Storage] GEIS fulfills the
NRC’s NEPA obligations and provides a
regulatory basis for the rule rather than
42 10
CFR 51.23(a) (2013).
FR at 56260.
44 79 FR at 56253.
addressing the agency’s responsibilities to
protect public health and safety under the
Atomic Energy Act (AEA), of 1954 as
amended. Further, Appendix B of the
[Continued Storage] GEIS discusses the
technical feasibility of continued safe storage.
It is important to note that, in adopting
revised 10 CFR 51.23 and publishing the
[Continued Storage] GEIS, the NRC is not
making a safety determination under the
AEA to allow for the continued storage of
spent fuel. AEA safety determinations
associated with licensing of these activities
are contained in the appropriate regulatory
provision addressing licensing requirements
and in the specific licenses for facilities.
Further, there is not any legal requirement for
the NRC to codify a generic safety conclusion
in the rule text. By not including a safety
policy statement in the rule text, the NRC
does not imply that spent fuel cannot be
stored safely. To the contrary, the analysis
documented in the [Continued Storage] GElS
is predicated on the ability to store spent fuel
safely over the short-term, long-term, and
indefinite timeframes. This understanding is
based upon the technical feasibility analysis
in Appendix B of the [Continued Storage]
GElS and the NRC’s decades-long experience
with spent fuel storage and development of
regulatory requirements for licensing of
storage facilities that are focused on safe
operation of such facilities, which have
provided substantial technical knowledge
about storage of spent fuel. Further, spent
fuel is currently being stored safely at reactor
and storage sites across the country, which
supports the NRC’s conclusion that it is
feasible for spent fuel to be stored safely for
the timeframes considered in the [Continued
Storage] GEIS.45
The petitions do not present any new
and significant information that would
form a basis to amend 10 CFR 51.23,
particularly in light of the September
19, 2014, Continued Storage
rulemaking.
The petitioners assert that expedited
spent fuel transfer analysis is ‘‘new and
significant information’’
The petitioners request that the NRC
‘‘consider, in all pending and future
reactor licensing and re-licensing
decisions, new and significant
information bearing on the
environmental impacts of high-density
pool storage in reactor pools and
alternatives for avoiding or mitigating
those impacts.’’ The petitioners assert
that the NRC generated new and
significant information during its postFukushima Expedited Spent Fuel
Transfer proceeding.
On October 9, 2013, the NRC released
NUREG–2161, ‘‘Consequence Study of a
Beyond-Design-Basis Earthquake
Affecting the Spent Fuel Pool for a U.S.
Mark I Boiling Water Reactor’’ and, on
November 12, 2013, the NRC delivered
a regulatory analysis in COMSECY–13–
0030, ‘‘Staff Evaluation and
Recommendation for Japan LessonsLearned Tier 3 Issue on Expedited
Transfer of Spent Fuel.’’ These
documents concluded that spent fuel
pools are very robust structures with
large safety margins, and that proposed
regulatory actions for spent fuel pool
safety improvements were not
warranted. This conclusion not only
covers spent fuel pools at operating
reactors applying for license renewal
but also spent fuel pools that would be
constructed at new reactor sites. Citing
the low risk to public health and safety
from spent fuel pool storage, the
Commission subsequently concluded
that regulatory action need not be
pursued in Staff Requirements
Memorandum (SRM), SRM–COMSECY–
13–0030, issued on May 23, 2014.
The petitioners contend that former
Chairman Allison Macfarlane’s
comments on COMSECY–13–0030, also
provide new and significant information
that requires the NRC to reconsider its
impact findings in the 2013 license
renewal GEIS. The former Chairman’s
comments were considered by the other
Commissioners in the development of
the SRM on this issue. However, the
Commission determined in SRM–
COMSECY–13–0030, that no further
generic assessments concerning the
expedited transfer of spent fuel to dry
cask storage should be pursued.
Notably, the SRM supported the staff’s
approach of using the NRC’s Safety Goal
Policy Statement of 1986 as a screening
metric. The SRM is the agency’s
determination on this issue.
Nonetheless, the petitioners contend
that NUREG–2161 and COMSECY–13–
0030 constitute new and significant
information based on those documents’
discussion of the severity of the impact
of a spent fuel pool accident, sensitivity
studies showing that some mitigation
measures could be cost beneficial, and
the possibility that a reactor accident
could impact the likelihood of a spent
fuel pool fire. However, none of these
sources of information provides ‘‘a
seriously different picture’’ of the
environmental consequences of spent
fuel storage. First, as noted above, the
NRC has frequently recognized that the
consequences of a spent fuel pool
accident could be large but has
determined that the overall risk of spent
fuel pool accidents is small in light of
the low probability of such an event.46
Therefore, the petitioners have not
shown that the magnitude of the
consequences of a spent fuel pool
accident constitute new and significant
information. Rather, NUREG–2161 and
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COMSECY–13–0030’s recognition that
the consequences of a spent fuel pool
accident could be large but that the
overall risk from such an event is small
in light of the very low probability of
such an event comports with the
agency’s previous considerations of this
issue. Second, while the sensitivity
studies may have shown that some
mitigation measures could be costbeneficial, they are based on alternate
assumptions that do not represent the
NRC’s analysis of the most likely
impacts of a spent fuel pool accident. In
any event, petitioners have not shown
with specificity that any information in
these sensitivity studies would
undermine the agency’s overall
conclusion that despite potentially large
consequences, the very low probability
renders the overall risk of a spent fuel
pool accident very low. Finally,
contrary to petitioners’ assertions, the
NRC has frequently responded to claims
that the probability of a reactor accident
could impact the probability of a spent
fuel pool accident and repeatedly found
that such a probability is very low.47
In conclusion, neither NUREG–2161,
COMSECY–13–0030, nor SRM–
COMSECY–13–0030 constitutes ‘‘new
and significant information’’ requiring
the NRC to supplement any of its prior
EISs, whether generic or specific— or
amend those ‘‘regulations that make or
rely on findings regarding the
environmental impacts of spent fuel
storage during reactor operation,
including Table B–1 and all regulations
approving standardized reactor
designs.’’
III. Determination of Petitions
For the reasons cited in Section II of
this document, the NRC has concluded
that the petitioners have not provided
new and significant information that
would form a basis to amend the NRC
regulations identified in the PRM–51–30
and PRM–51–31.
Earlier 10 CFR Part 51 PRMs
Several of the regulations identified
by the petitioners have been the subject
of prior rulemaking petitions (i.e., PRM–
51–1, PRM–51–10, PRM–51–12, and
PRMs-51–14 to 51–28) and issues
similar to those raised by the petitioners
were considered by the Commission in
these prior petitions, therefore, these
issues have been thoroughly evaluated
by the Commission. The PRM–51–1
petitioner asserted that Table S–3
‘‘seriously understate[d]’’ the impact on
human health and safety from the
uranium fuel cycle and that the Table
S–3 values should be revised
accordingly.48 The NRC denied PRM–
51–1 based upon the Commission’s
‘‘generic determination that the
radiological impacts of the uranium fuel
cycle on individuals off-site will remain
at or below the Commission’s regulatory
limits, and as such, are of small
significance.’’ 49 The NRC described this
generic determination in Chapter 6 of
the 1996 version of the License Renewal
GEIS; the generic determination was
based upon findings made in various
NRC and EPA rulemakings.50
The petitioners in PRM–51–10 and
PRM–51–12 challenged the generic
findings for spent fuel storage impacts
codified in Table B–1 and requested a
rulemaking to remove this finding.51
The petitioners raised the prospect of a
fire at a nuclear power reactor’s spent
fuel pool and the resulting release of
radioactive material to the environment.
According to the petitioners’ scenario,
the spent fuel pool fire would be
initiated by either an accident or a
successful terrorist strike that would
cause a partial or complete drain of the
cooling water in the spent fuel pool. The
petitioners requested the amendment of
several of the regulations that are the
subject of PRM–51–30 and PRM–51–31,
namely, Table B–1, 10 CFR 51.23,
51.53(c), and 51.95(c).52 The petitioners
requested that the impacts of spent fuel
storage be considered on a site-specific
basis in license renewal cases, rather
than generically, due to this potential
threat. The Commission denied PRM–
51–10 and PRM–51–12 and concluded
that the risk of such a spent fuel pool
fire was very low and that, given the
safety and security requirements that
applied to all plants, as well as the
physical robustness of spent fuel pools,
the environmental impacts of spent fuel
pool storage could be handled
generically.53 The NRC’s denial of
PRM–51–10 and PRM–51–12 was
upheld by the U.S. Court of Appeals for
the Second Circuit.54
Finally, in a series of virtually
identical petitions, docketed as PRM–
51–14 through PRM–51–28, petitioners
requested that the NRC rescind all
regulations that reach generic
environmental impact conclusions
regarding severe reactor accidents and
spent fuel pool accidents, which would
include various provisions of Table B–
1 and 10 CFR 51.53. The PRM–51–14
through PRM–51–28 petitions were filed
shortly after the NRC issued its NearTerm Task Force (NTTF) report,
‘‘Recommendations for Enhancing
Reactor Safety in the 21st Century, the
NTTF Review of Insights from the
Fukushima Dai-ichi Accident,’’ dated
July 12, 2011. The NTTF report
provided the NRC staff’s
recommendations to enhance U.S.
nuclear power plant safety following the
March 11, 2011, Fukushima accident in
Japan. After determining that the NTTF
report did not constitute new and
significant information and further, that
the petitioners had provided insufficient
technical or regulatory basis to amend
any of the NRC regulations in question,
the NRC denied the PRM–51–14
through PRM–51–28 petitions.55
IV. Availability of Documents
The documents identified in the
following table are available to
interested persons through one or more
of the following methods, as indicated.
For more information on accessing
ADAMS, see the ADDRESSES section of
this document.
Document
ADAMS Accession No./Web Link/Federal Register citation
CLI–99–22, Hydro Resources, Inc., July 23, 1999 ..................................
https://www.nrc.gov/reading-rm/doc-collections/commission/orders/1999/
1999-022cli.pdf
https://www.nrc.gov/reading-rm/doc-collections/commission/orders/2014/
2014-07cli.pdf
ML14029A124, ML14029A169, ML14029A154
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CLI–14–07, DTE Electric Co., et al., July 17, 2014 .................................
‘‘Comments by Environmental Organizations on Draft Waste Confidence Generic Environmental Impact Statement [GEIS] and Proposed Waste Confidence Rule and Petition to Revise and Integrate
All Safety and Environmental Regulations Related to Spent Fuel
Storage and Disposal,’’ January 7, 2014.
47 73 FR at 46210; 2013 GEIS at E–38; NUREG–
2157 at D–438 to D–440; COMSECY–13–0030,
Enclosure 1 at 138.
48 73 FR 14946; March 20, 2008.
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at 14948.
51 73 FR 46204; August 8, 2008.
52 Id. at 46205.
50 Id.
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53 Id.
at 46206–12.
York v. U.S. Nuclear Regulatory
Commission, 589 F.3d 551 (2nd Cir. 2009).
55 80 FR 48235 (August 12, 2015).
54 New
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Document
ADAMS Accession No./Web Link/Federal Register citation
COMSECY–13–0030, Staff Evaluation and Recommendation for Japan
Lessons-Learned Tier 3 Issue on Expedited Transfer of Spent Fuel,
November 12, 2013.
COMSECY–13–0030 Vote Sheet, Staff Evaluation and Recommendation for Japan Lessons-Learned Tier 3 Issue on Expedited Transfer
of Spent Fuel, April 8, 2014.
Federal Register notice—Waste Confidence—Continued Storage of
Spent Nuclear Fuel (proposed rule), September 13, 2013.
Federal Register notice—Environmental Effects of the Uranium Fuel
Cycle, April 22, 1974.
Federal Register notice—Licensing and Regulatory Policy and Procedures for Environmental Protection; Uranium Fuel Cycle Impacts
From Spent Fuel Reprocessing and Radioactive Waste Management,
August 2, 1979.
Federal Register notice—Waste Confidence Decision, August 31,
1984.
Federal Register notice—Consideration of Environmental Impacts of
Temporary Storage of Spent Fuel After Cessation of Reactor Operation, September 18, 1990.
Federal Register notice—Environmental Review for Renewal of Nuclear Power Plant Operating Licenses, June 5, 1996.
Federal Register notice—Waste Confidence Decision Update, December 23, 2010.
Federal Register notice—Continued Storage of Spent Nuclear Fuel
(final rule), September 19, 2014.
Federal Register notice—Revisions to Environmental Review for Renewal of Nuclear Power Plant Operating Licenses, June 20, 2013.
Federal Register notice—Revise and Integrate All Safety and Environmental Regulations Related to Spent Fuel Storage and Disposal,
April 21, 2014.
Federal Register notice—Environmental Impacts of Spent Fuel Storage During Reactor Operation, May 1, 2014.
Federal Register notice—Environmental Impacts of Spent Fuel Storage During Reactor Operation, July 24, 2014.
Federal Register notice—New England Coalition on Nuclear Pollution;
Denial of Petition for Rulemaking, March 20, 2008.
Federal Register notice—The Attorney General of Commonwealth of
Massachusetts, The Attorney General of California; Denial of Petitions for Rulemaking, August 8, 2008.
Federal Register notice—Environmental Impacts of Severe Reactor
and Spent Fuel Pool Accidents, August 12, 2015.
Makhijani, Arjun, Comments of the Institute for Energy and Environmental Research on the U.S. Nuclear Regulatory Commission’s Proposed Waste Confidence Rule Update and Proposed Rule Regarding
Environmental Impacts of Temporary Spent Fuel Storage.
NRC-National Academies of Science Report, ‘‘A Study of the Isolation
System for Geologic Disposal of Radioactive Wastes,’’ 1983.
NUREG–0116, ‘‘Environmental Survey of the Reprocessing and Waste
Management Portions of the LWR Fuel Cycle,’’ October 1976.
NUREG–1437, ‘‘Generic Environmental Impact Statement for License
Renewal of Nuclear Plants,’’ June 20, 2013.
NUREG–2161, ‘‘Consequence Study of a Beyond-Design-Basis Earthquake Affecting the Spent Fuel Pool for a U.S. Mark I Boiling Water
Reactor,’’ October 9, 2013.
NUREG–2157, ‘‘Generic Environmental Impact Statement for Continued Storage of Spent Nuclear Fuel,’’ September 2014.
NUREG–2179, ‘‘Environmental Impact Statement for the Combined License (COL) for the Bell Bend Nuclear Power Plant (Draft Report for
Comment),’’ April 2015.
PRM–51–30, ‘‘Petition to Revise and Integrate All Safety and Environmental Regulations Related to Spent Fuel Storage and Disposal,’’
submitted by Diane Curran on behalf of 34 environmental organizations, January 7, 2014.
PRM–51–31, ‘‘Environmental Organizations’ Petition to Consider New
and Significant Information Regarding Environmental Impacts of
High-Density Spent Fuel Storage and Mitigation Alternatives in Licensing Proceedings for New Reactors and License Renewal Proceedings for Existing Reactors and Duly Modify All NRC Regulations
Regarding Environmental Impacts of Spent Fuel Storage During Reactor Operation,’’ February 18, 2014.
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78 FR 56776
39 FR 14188
44 FR 45362
49 FR 34658
55 FR 38472
61 FR 28467
75 FR 81037
79 FR 56238
78 FR 37282
79 FR 22055
79 FR 24595
79 FR 42989
73 FR 14946
73 FR 46204
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Document
ADAMS Accession No./Web Link/Federal Register citation
PRM–51–31, ‘‘Environmental Organizations’ Amended Petition to Consider New and Significant Information Regarding Environmental Impacts of High-Density Spent Fuel Storage and Mitigation Alternatives
in Licensing Proceedings for New Reactors and License Renewal
Proceedings for Existing Reactors and Duly Modify All NRC Regulations Regarding Environmental Impacts of Spent Fuel Storage During
Reactor Operation,’’ June 26, 2014.
Safety Goals for the Operations of Nuclear Power Plants; Policy Statement; Republication, August 21, 1986.
SRM–SECY–13–0030, ‘‘Staff Evaluation and Recommendation for
Japan Lessons-Learned Tier 3 Issue on Expedited Transfer of Spent
Fuel,’’ May 23, 2014.
WASH–1248, ‘‘Environmental Survey of the Uranium Fuel Cycle,’’ April
1974.
Dated at Rockville, Maryland, this 13th day
of May, 2016.
For the Nuclear Regulatory Commission.
Annette L. Vietti-Cook,
Secretary of the Commission.
[FR Doc. 2016–11820 Filed 5–18–16; 8:45 am]
BILLING CODE 7590–01–P
DEPARTMENT OF ENERGY
10 CFR Parts 429 and 430
[Docket No. EERE–2016–BT–TP–0018]
RIN 1904–AD68
Energy Conservation Program: Test
Procedure for Uninterruptible Power
Supplies
Office of Energy Efficiency and
Renewable Energy, Department of
Energy.
ACTION: Notice of proposed rulemaking.
AGENCY:
The U.S. Department of
Energy (DOE) is proposing to revise its
battery charger test procedure
established under the Energy Policy and
Conservation Act of 1975, as amended.
These proposed revisions, if adopted,
will add a discrete test procedure for
uninterruptible power supplies (UPSs)
to the current battery charger test
procedure.
DATES: Meeting: DOE will hold a public
meeting on Thursday, June 9, 2016,
from 9:30 a.m. to 12:30 p.m., in
Washington, DC. The meeting will also
be broadcast as a webinar. See section
V, ‘‘Public Participation,’’ for webinar
registration information, participant
instructions, and information about the
capabilities available to webinar
participants.
Comments: DOE will accept
comments, data, and information
regarding this notice of proposed
rulemaking (NOPR) before and after the
public meeting, but no later than July
18, 2016. See section V, ‘‘Public
Participation,’’ for details.
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The public meeting will be
held at the U.S. Department of Energy,
Forrestal Building, Room 8E–089, 1000
Independence Avenue SW.,
Washington, DC 20585.
Any comments submitted must
identify the NOPR for Test Procedure
for Battery Chargers, and provide docket
number EE–2016–BT–TP–0018 and/or
regulatory information number (RIN)
number 1904–AD68. Comments may be
submitted using any of the following
methods:
1. Federal eRulemaking Portal:
www.regulations.gov. Follow the
instructions for submitting comments.
2. Email: UPS2016TP0018@
ee.doe.gov. Include the docket number
and/or RIN in the subject line of the
message.
3. Mail: Ms. Brenda Edwards, U.S.
Department of Energy, Building
Technologies Office, Mailstop EE–2J,
1000 Independence Avenue SW.,
Washington, DC 20585–0121. If
possible, please submit all items on a
CD, in which case it is not necessary to
include printed copies.
4. Hand Delivery/Courier: Ms. Brenda
Edwards, U.S. Department of Energy,
Building Technologies Office, 950
L’Enfant Plaza SW., Suite 600,
Washington, DC 20024. Telephone:
(202) 586–2945. If possible, please
submit all items on a CD, in which case
it is not necessary to include printed
copies.
For detailed instructions on
submitting comments and additional
information on the rulemaking process,
see section V of this document (Public
Participation).
Docket: The docket, which includes
Federal Register notices, public meeting
attendee lists and transcripts,
comments, and other supporting
documents/materials, is available for
review at https://www.regulations.gov/
#!docketDetail;D=EERE-2016-BT-TP0018. All documents in the docket are
listed in the www.regulations.gov index.
However, some documents listed in the
ADDRESSES:
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index, such as those containing
information that is exempt from public
disclosure, may not be publicly
available. The www.regulations.gov Web
page contains simple instructions on
how to access all documents, including
public comments, in the docket. See
section V for information on how to
submit comments through
www.regulations.gov.
FOR FURTHER INFORMATION CONTACT:
Jeremy Dommu, U.S. Department of
Energy, Office of Energy Efficiency and
Renewable Energy, Building
Technologies Office, EE–5B, 1000
Independence Avenue SW.,
Washington, DC 20585–0121.
Telephone: (202) 586–9870. Email:
battery_chargers_and_external_power_
supplies@ee.doe.gov.
In the Office of the General Counsel,
contact Mr. Pete Cochran, U.S.
Department of Energy, Office of the
General Counsel, GC–33, 1000
Independence Avenue SW.,
Washington, DC 20585–0121.
Telephone: (202) 586–9496. Email:
peter.cochran@hq.doe.gov.
For further information on how to
submit a comment, review other public
comments and the docket, or participate
in the public meeting, contact Ms.
Brenda Edwards at (202) 586–2945 or by
email: Brenda.Edwards@ee.doe.gov.
SUPPLEMENTARY INFORMATION: This
proposed rule would incorporate by
reference into 10 CFR part 430 the
testing methods contained in the
following commercial standard:
IEC 62040–3, ‘‘Uninterruptible power
systems (UPS)—Method of specifying
the performance and test requirements,’’
Edition 2.0, Section 6 ‘‘UPS tests,’’ and
Annex J ‘‘UPS efficiency—Methods of
measurement.’’
Copies of the IEC 62040–3 Ed. 2.0
standard are available from the
American National Standards Institute,
25 W. 43rd Street, 4th Floor, New York,
NY 10036 or at https://webstore.ansi
.org/.
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Agencies
[Federal Register Volume 81, Number 97 (Thursday, May 19, 2016)]
[Proposed Rules]
[Pages 31532-31542]
From the Federal Register Online via the Government Publishing Office [www.gpo.gov]
[FR Doc No: 2016-11820]
========================================================================
Proposed Rules
Federal Register
________________________________________________________________________
This section of the FEDERAL REGISTER contains notices to the public of
the proposed issuance of rules and regulations. The purpose of these
notices is to give interested persons an opportunity to participate in
the rule making prior to the adoption of the final rules.
========================================================================
Federal Register / Vol. 81, No. 97 / Thursday, May 19, 2016 /
Proposed Rules
[[Page 31532]]
NUCLEAR REGULATORY COMMISSION
10 CFR Part 51
[Docket Nos. PRM-51-30 and PRM-51-31; NRC-2014-0014 and NRC-2014-0055]
Generic Determinations Regarding the Environmental Impacts of
Spent Fuel Storage and Disposal When Considering Nuclear Power Reactor
License Applications
AGENCY: Nuclear Regulatory Commission.
ACTION: Petitions for rulemaking; denial.
-----------------------------------------------------------------------
SUMMARY: The U.S. Nuclear Regulatory Commission (NRC) is denying two
petitions for rulemaking (PRMs), PRM-51-30 and PRM-51-31, submitted by
Diane Curran on behalf of 34 environmental organizations (the
petitioners). The petitioners request that the NRC revise certain
regulations that concern the environmental impacts of spent fuel
storage and disposal for nuclear power plant license applications. The
NRC is denying the petitions because they provide an insufficient basis
to consider a rulemaking to revise such regulations.
DATES: The dockets for the petitions, PRM-51-30 and PRM-51-31, are
closed on May 19, 2016.
ADDRESSES: Please refer to Docket IDs NRC-2014-0014 and NRC-2014-0055,
as appropriate, when contacting the NRC about the availability of
information regarding these petitions. You can access publicly-
available documents related to the petitions using any of the following
methods:
Federal Rulemaking Web site: Go to https://www.regulations.gov and search for Docket IDs NRC-2014-0014 and NRC-
2014-0055. Address questions about NRC dockets to Carol Gallagher;
telephone: 301-415-3463; email: Carol.Gallagher@nrc.gov. For technical
questions, contact the individual listed in the FOR FURTHER INFORMATION
CONTACT section of this document.
NRC's Agencywide Documents Access and Management System
(ADAMS): You may obtain publicly-available documents online in the
ADAMS Public Documents collection at https://www.nrc.gov/reading-rm/adams.html. To begin the search, select ``ADAMS Public Documents'' and
then select ``Begin Web-based ADAMS Search.'' For problems with ADAMS,
please contact the NRC's Public Document Room (PDR) reference staff at
1-800-397-4209, 301-415-4737, or by email to pdr.resource@nrc.gov. The
ADAMS accession number for each document referenced (if it is available
in ADAMS) is provided the first time that it is mentioned in the
SUPPLEMENTARY INFORMATION section. For the convenience of the reader,
instructions about obtaining materials referenced in this document are
provided in the Section IV, Availability of Documents.
NRC's PDR: You may examine and purchase copies of public
documents at the NRC's PDR, Room O1-F21, One White Flint North, 11555
Rockville Pike, Rockville, Maryland 20852.
FOR FURTHER INFORMATION CONTACT: Jenny C. Tobin, Office of Nuclear
Reactor Regulation, telephone: 301-415-2328, email:
Jennifer.Tobin@nrc.gov; U.S. Nuclear Regulatory Commission, Washington,
DC 20555-0001.
SUPPLEMENTARY INFORMATION:
Table of Contents
I. The Petitions
II. Reasons for Denial
III. Determination of Petitions
IV. Availability of Documents
I. The Petitions
Section 2.802 of title 10 of the Code of Federal Regulations (10
CFR), ``Petition for rulemaking,'' provides an opportunity for any
interested person to petition the Commission to issue, amend, or
rescind any regulation. The NRC has consolidated its response to PRM-
51-30 and PRM-51-31 because both petitions make similar rulemaking
requests. The NRC did not request public comment on PRM-51-30 and PRM-
51-31 because there was sufficient information for review and these
issues have been well-vetted in past NRC proceedings.
PRM-51-30
The petitioners filed the first of their two petitions on December
20, 2013, as a part of their comments on the NRC's proposed Continued
Storage Rule (formerly known as the Waste Confidence Decision and Rule)
and that rule's associated generic environmental impact statement
(Continued Storage Generic Environmental Impact Statement (GEIS)).\1\
The petitioners filed a corrected version of the first petition on
January 7, 2014. The NRC published a notice of receipt of the first
petition in the Federal Register (FR) on April 21, 2014, and assigned
it Docket No. PRM-51-30 (79 FR 22055).
---------------------------------------------------------------------------
\1\ The NRC published the Continued Storage Rule as a proposed
rule on September 13, 2013 (78 FR 56776), and as a final rule on
September 19, 2014 (79 FR 56238). As part of the final rule, all of
the public comments on the proposed rule were addressed in NUREG-
2157, ``Generic Environmental Impact Statement for Continued Storage
of Spent Nuclear Fuel.''
---------------------------------------------------------------------------
The petition requests that the NRC revise certain regulations in 10
CFR part 51 that concern the environmental impacts of spent fuel
storage and disposal for nuclear power plants. The NRC implements its
responsibilities under the National Environmental Policy Act (NEPA)
through its 10 CFR part 51 regulations. The petitioners assert that the
NRC's 10 CFR part 51 regulations are ``balkanized'' and ``disparate and
inconsistent,'' and that these regulations should be made into a
``cohesive and consistent whole.'' The petitioners identified the
following NRC regulations as being within the scope of their request:
10 CFR 51.53(c),\2\ 10 CFR 51.51 (Table S-3),\3\ 10 CFR 51.71(d),\4\
and Table B-1, ``Summary of
[[Page 31533]]
Findings on NEPA Issues for License Renewal on Nuclear Power Plants,''
in appendix B to subpart A of 10 CFR part 51 (Table B-1), as well as
the NRC's proposed amendments to 10 CFR 51.23, as set forth in its
September 13, 2013, proposed rule (78 FR 56776).\5\
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\2\ Section 51.53 is entitled ``Post construction environmental
reports.'' Paragraph (c) describes the contents of the required
environmental report submitted by an applicant in support of its
application to renew a nuclear power plant's operating license.
\3\ Table S-3 is entitled ``Table of Uranium Fuel Cycle
Environmental Data'' and is set forth at 10 CFR 51.51. Table S-3
shows the maximum environmental effect per annual fuel requirement
for an operating reactor and is the basis for evaluating the
contribution of the environmental effects of uranium mining and
milling, the production of uranium hexafluoride, isotopic
enrichment, fuel fabrication, reprocessing of irradiated fuel,
transportation of radioactive materials and management of low-level
wastes and high-level wastes related to uranium fuel cycle
activities to the environmental costs of licensing a nuclear power
reactor.
\4\ Section 51.71 is entitled ``Draft environmental impact
statement--contents.'' Paragraph (d) describes the analysis required
to be included in draft EISs. For license renewal actions, the
supplemental draft EIS relies on the findings and other supporting
information in NUREG-1437, Revision 1, ``Generic Environmental
Impact Statement for License Renewal of Nuclear Plants--Final
Report'' (2013).
\5\ The proposed amendments to 10 CFR 51.23 were adopted in the
final rule (79 FR 56238; September 19, 2014). Section 51.23 is
entitled ``Environmental impacts of continued storage of spent
nuclear fuel beyond the licensed life for operation of a reactor''
and states that the Commission ``has generically determined that the
environmental impacts of continued storage of spent nuclear fuel
beyond the licensed life for operation of a reactor are those
impacts identified in NUREG-2157 [the Continued Storage GEIS]'' (10
CFR 51.23(a)).
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Section 51.53(c) and a portion of 10 CFR 51.71(d) are premised upon
NUREG-1437, ``Generic Environmental Impact Statement for License
Renewal of Nuclear Plants,'' an environmental impact statement (EIS)
initially published in May 1996 and then revised and updated in June
2013 (License Renewal GEIS).\6\ The License Renewal GEIS describes the
potential environmental impacts of renewing the operating license of a
nuclear power plant for an additional 20 years. The NRC classifies the
license renewal issues described in the License Renewal GEIS as either
generic or site-specific. Generic issues concern environmental impacts
that are common to all nuclear power plants. Site-specific issues are
addressed initially by the license renewal applicant (i.e., a nuclear
power plant licensee seeking a renewal of its operating license under
the NRC's license renewal regulations in 10 CFR part 54) in its
environmental report, which is required by 10 CFR 51.45, and then by
the NRC, in its supplemental environmental impact statement (SEIS) to
the License Renewal GEIS prepared for each license renewal
application.\7\ For any given license renewal action, the License
Renewal GEIS together with the site-specific SEIS (along with any other
applicable generic EISs) documents the NRC's NEPA analysis.
---------------------------------------------------------------------------
\6\ The current version of the License Renewal GEIS is NUREG-
1437, Revision 1.
\7\ 10 CFR 51.95(c).
---------------------------------------------------------------------------
In Table B-1, generic issues are designated as ``Category 1''
issues and site-specific issues are designated as ``Category 2''
issues. Absent new and significant information, Category 1 issues are
not required to be re-analyzed for an applicant's environmental report
or the staff's SEIS. Table B-1 codifies the findings of the License
Renewal GEIS and is wholly concerned with nuclear power plant license
renewal.\8\
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\8\ Table B-1 was amended to reflect the June 2013 License
Renewal GEIS update. The NRC rule amending Table B-1 and other 10
CFR part 51 regulations was published in the Federal Register on
June 20, 2013 (78 FR 37282).
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The purpose of Table S-3 is to support the environmental review for
new reactor license applications. In addition to considering the
environmental impacts of the construction and operation of a commercial
nuclear power reactor, the NRC considers the contributions from the
uranium fuel cycle activities.\9\ Table S-3 identifies the uranium fuel
cycle impacts, generically, for new reactor license applications.
---------------------------------------------------------------------------
\9\ Uranium fuel cycle activities include ``uranium mining and
milling, the production of uranium hexafluoride, isotopic
enrichment, fuel fabrication, spent fuel storage and disposal'' (44
FR 45362; August 2, 1979).
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The petitioners also assert that the NRC's proposed amendments to
10 CFR 51.23, as set forth in the NRC's proposed rule of September 13,
2013 (78 FR 56776), are ``confusing'' to the extent that the proposed
continued storage regulation included safety findings, which should be
placed in either 10 CFR parts 50 or 52, and because the proposed
regulation no longer includes the ``reasonable assurance'' finding. The
petitioners also assert that Table S-3 has been ``repudiated'' and that
it is inconsistent with the findings in Table B-1. In addition, the
petitioners assert that Table B-1 does not include a finding as to
whether offsite spent fuel disposal impacts are significant or not.
The petitioners further assert that 10 CFR 51.53(c) and 51.71(d)
``excuse'' license renewal applicants and the NRC, respectively, from
addressing spent fuel storage impacts in individual license renewal
cases. As both regulatory provisions are premised upon the findings in
the License Renewal GEIS, the petitioners, essentially, object to the
finding that impacts of spent fuel storage during the license renewal
period are a Category 1, or generic, issue and have a ``small'' impact.
Finally, the petitioners assert that the economic costs of spent fuel
storage and disposal should be incorporated into reactor cost-benefit
analyses and that the need for power should be considered in license
renewal decisions.
PRM-51-31
The petitioners filed their second petition on February 18, 2014.
The petitioners' second petition asserts that COMSECY-13-0030, ``Staff
Evaluation and Recommendation for Japan Lessons-Learned Tier 3 Issue on
Expedited Transfer of Spent Fuel'' \10\ (the expedited spent fuel
transfer analysis), and NUREG-2161, ``Consequence Study of a Beyond-
Design-Basis Earthquake Affecting the Spent Fuel Pool for a U.S. Mark I
Boiling Water Reactor,'' \11\ constitute new and significant
information. The petitioners request that the NRC ``duly modify NRC's
regulations that make or rely on findings regarding the environmental
impacts of spent fuel storage during reactor operation, including Table
B-1 and all regulations approving standardized reactor designs.''
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\10\ COMSECY-13-0030, ``Memorandum from Mark Satorius, Executive
Director for Operations, to NRC Commissioners Re: Staff Evaluation
and Recommendation for Japan Lessons-Learned Tier 3 Issue on
Expedited Transfer of Spent Fuel'' (November 12, 2013), and
documents cited therein.
\11\ NUREG-2161, ``Consequence Study of a Beyond-Design-Basis
Earthquake Affecting the Spent Fuel Pool for a U.S. Mark I Boiling
Water Reactor'' (September 2014).
---------------------------------------------------------------------------
The NRC published a notice of receipt of the second petition in the
Federal Register on May 1, 2014, and assigned it Docket No. PRM-51-31
(79 FR 24595). The petitioners subsequently submitted an ``amended
petition'' for rulemaking on June 26, 2014, seeking to add ``the
observations made by [former] Chairman Macfarlane in her dissenting
comments'' on the expedited spent fuel transfer analysis. The
petitioners assert that the former Chairman's dissenting vote on the
expedited spent fuel transfer analysis provides ``new and significant''
information that would affect the NRC's environmental reviews. The NRC
treated the ``amended petition'' as a supplement to the February 18,
2014, petition and re-noticed the petition, along with the supplement,
for informational purposes only (79 FR 42989; July 24, 2014).
II. Reasons for Denial
The NRC is denying the petitions because the petitioners have not
presented a sufficient basis to amend the regulations. The petitioners
largely contend that they present new and significant information that
requires the agency to revisit its previous NEPA analyses that form the
bases for the challenged regulations. Under Commission precedent,
information that provides a ``seriously different picture'' of the
environmental consequences than previously considered is new and
significant information.\12\ As explained below, the NRC finds that the
petitioners' information does not provide a ``seriously different
picture'' of the environmental consequences of spent fuel storage. As a
result, the NRC concludes that the current technical
[[Page 31534]]
bases for those regulations challenged by the petitioners remain sound.
---------------------------------------------------------------------------
\12\ Hydro Res. Inc., CLI-99-22, 50 NRC 3, 14 (1999) (quoting
Sierra Club v. Froehike, 816 F.2d 205, 210 (5th Cir. 1987)); see
generally Marsh v. Oregon Natural Resources Council, 490 U.S. 360
(1989).
---------------------------------------------------------------------------
The petitioners assert that the NRC's environmental review regulations
are ``balkanized''
The petitioners assert that ``[t]he NRC's piecemeal and disjointed
approach to the consideration of spent fuel storage and disposal
impacts violates the NEPA principle that an agency may not segment its
analysis in a manner that conceals the environmental significance of
its action.'' Segmentation refers to instances where a Federal agency
splits a project into smaller components to avoid preparing an EIS, or
where an agency does not consider related actions in a single EIS.\13\
The NRC does not agree that its approach to the consideration of spent
fuel storage and disposal impacts is piecemeal and disjointed or that
NRC's environmental review regulations in 10 CFR part 51 are
``balkanized'' or result in NEPA segmentation.
---------------------------------------------------------------------------
\13\ Delaware Riverkeeper Network v. FERC, 753 F.3d 1304, 1313
(D.C. Cir. 2014) (``An agency impermissibly `segments' NEPA review
when it divides connected, cumulative, or similar federal actions
into separate projects and thereby fails to address the true scope
and impact of the activities that should be under consideration.'');
see also Council on Environmental Quality (CEQ) regulation, 40 CFR
1508.25.
---------------------------------------------------------------------------
While the petitioners have pointed to some instances where the
agency relies on generic analyses as part of its overall NEPA review
for certain licensing actions, the petitioners have not shown any case
where the NRC artificially divided a licensing action into smaller
components. Rather, as discussed below, the NRC fully considers the
environmental impacts of each licensing action through a combination of
site-specific EISs and, where appropriate, GEISs. The use of generic
analyses by the NRC to support licensing decisions has been upheld by
the U.S. Supreme Court.\14\
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\14\ In a 1983 decision concerning a challenge to Table S-3, the
U.S. Supreme Court stated that ``[t]he generic method chosen by the
agency is clearly an appropriate method of conducting the hard look
required by NEPA.'' Baltimore Gas & Elec. Co. v. NRDC, 462 U.S. 87,
101, 103 S.Ct. 2246, 2254 (1983).
---------------------------------------------------------------------------
In addition to the License Renewal GEIS and the Continued Storage
GEIS, the NRC prepares EISs for all new reactor and license renewal
applications. Within the umbrella of both its generic and site-specific
EISs, the NRC adequately considers the spent fuel storage impacts of
its licensing decisions. The EISs for new nuclear power reactors
describe the environmental impacts from the onsite storage and
management of spent nuclear fuel and offsite disposal based on 40 years
of reactor operation, which is the maximum initial term of a reactor
license.\15\ The License Renewal GEIS describes the environmental
impacts from the onsite storage and offsite disposal of spent nuclear
fuel generated during an additional 20 years of reactor operation
(i.e., 20 years beyond the expiration of the initial license).\16\ The
Continued Storage GEIS describes the environmental impacts of the
continued storage of spent nuclear fuel beyond the licensed life for
operation of a reactor. Additionally, spent fuel storage and disposal
impacts are considered by the NRC staff during each new reactor license
and license renewal environmental review to determine if there is new
and significant information that could alter the generic conclusions.
---------------------------------------------------------------------------
\15\ 10 CFR 52.104.
\16\ 10 CFR 54.31.
---------------------------------------------------------------------------
Moreover, the underlying technical bases for the consideration of
spent fuel storage and disposal impacts in EISs for new power reactor
licenses and the License Renewal GEIS are the same. Combined with the
Continued Storage GEIS, these NEPA documents provide a complete
analysis of spent fuel storage and disposal environmental impacts. The
regulations in 10 CFR part 51 are premised upon, and support, this NEPA
framework of generic EISs supported by site-specific EISs.
The NRC's approach improves the effectiveness of environmental
reviews by generically resolving issues that are not substantially
different from one proposed action to another, while still ensuring
that those impacts are considered in subsequent licensing actions. The
NRC conducts environmental and safety reviews for the issuance of
licenses for the operation of nuclear power plants including the onsite
storage of spent nuclear fuel. The NRC has also conducted separate
environmental and safety reviews for the issuance of specific licenses
for the storage of spent nuclear fuel in independent spent fuel storage
installations (ISFSIs).\17\ With respect to spent fuel disposal, an EIS
would fully discuss the environmental impacts for any proposed action
to dispose of spent fuel in a geologic repository. In addition, the NRC
has previously determined the potential radiological effects of offsite
spent fuel disposal in a permanent repository or some other permanent
disposal scenario while evaluating the environmental effects of the
uranium fuel cycle.\18\
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\17\ NRC regulation, 10 CFR 72.3, defines an ISFSI as ``a
complex designed and constructed for the interim storage of spent
nuclear fuel.''
\18\ See WASH-1248, ``Environmental Survey of the Uranium Fuel
Cycle,'' April 1974, and NUREG-0116, ``Environmental Survey of the
Reprocessing and Waste Management Portions of the LWR Fuel Cycle,''
October 1976.
---------------------------------------------------------------------------
The consideration of spent fuel storage and disposal environmental
impacts builds upon the knowledge gained from previous environmental
reviews and associated rulemakings and is consistent throughout the
NRC's regulations in that the NRC relies on the same technical bases to
make impact determinations. The only differences are the timeframes in
which these impacts occur and whether the impacts occur during
continued onsite storage or offsite disposal. In each of these
regulatory situations, the technical bases remain the same.
Tables S-3 and B-1 in the NRC's regulations were developed at
separate times for different purposes but have common technical bases.
The 2014 continued storage rule, and its supporting Continued Storage
GEIS, updated the NRC's NEPA findings in Table B-1 for issues
pertaining to ``Onsite storage of spent nuclear fuel'' and ``Offsite
radiological impacts of spent nuclear fuel and high-level waste
disposal.'' In doing so, the NRC effectively incorporated the NEPA
analysis of continued spent fuel storage into license renewal. For new
reactors, 10 CFR 51.23(b) directs that the impact determinations in
NUREG-2157 shall be deemed incorporated into the associated EIS. And
for licensing actions for which an environmental assessment (EA) is
being prepared (such as an ISFSI built under a specific license at a
site occupied by a nuclear power reactor), 10 CFR 51.30(b) directs that
the impacts determinations in NUREG-2157 regarding the continued
storage of spent fuel shall be considered, if such impacts are relevant
to the proposed action.
For a given future reactor licensing action that relies on the
Continued Storage GEIS and rule, the NRC will incorporate the
environmental impacts analyzed in the Continued Storage GEIS into the
overall licensing decision. The NRC's NEPA review for each licensing
action that involves either a new reactor or a license renewal
application will fully account for the reasonably foreseeable impacts
of spent fuel storage and disposal, including, where applicable, the
impacts that have been analyzed generically in the Continued Storage
GEIS and License Renewal GEIS. The NRC concludes that its 10 CFR part
51 environmental review regulations are internally consistent and are
not inappropriately segmented, and
[[Page 31535]]
therefore, there is no reason to amend these regulations.
The petitioners assert that Table S-3 has been repudiated
The petitioners' expert, Dr. Arjun Makhijani, in a declaration
attached to the petitioners' January 2014 submission, states that the
Table S-3 finding regarding the impacts of spent fuel disposal is no
longer valid because the finding is based upon the disposal of spent
fuel in a bedded salt repository and that such disposal would result in
zero releases of radioactive effluents, and therefore, zero
radiological dose. Dr. Makhijani asserts that
[m]oreover, we note that Table S-3 at 10 CFR 51.51 is invalid for
estimating high-level waste disposal impacts. Among other things,
its underlying assumption of disposal in a bedded salt repository
for spent fuel disposal was repudiated by the NRC itself in
2008.\19\
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\19\ ``Declaration of Dr. Arjun Makhijani Regarding the Waste
Confidence Proposed Rule and Draft Generic Environmental Impact
Statement,'' attached to PRM-51-30 (paragraph 2.8 on p. 6).
The petitioners, through Dr. Makhijani's declaration, assert that the
NRC must prepare a new analysis concerning the impacts of spent fuel
disposal.
Contrary to Dr. Makhijani's assertion, the NRC has never repudiated
Table S-3; the original assumption of spent fuel disposal in a bedded
salt repository is not germane to the overall purpose of Table S-3 nor
does the change in media for storing spent fuel undermine the findings
of Table S-3. Dr. Makhijani's statement evaluates Table S-3 in
isolation and does not consider later developments in the NRC's
regulatory policy and U.S. Supreme Court precedent. The Atomic Energy
Commission, the predecessor agency of the NRC, promulgated the initial
version of Table S-3 on April 22, 1974 (39 FR 14188). Since the
promulgation of Table S-3, the Nuclear Waste Policy Act of 1982 (NWPA)
adopted deep geologic disposal as the nation's solution for spent fuel
disposal. Furthermore, in 1983 the U.S. Supreme Court, in its Baltimore
Gas & Elec. Co. v. National Resources Defense Council (NRDC)
decision,\20\ upheld both Table S-3 and the approach taken by the NRC
in using Table S-3 data in individual licensing proceedings. In
Baltimore Gas & Elec. Co. v. NRDC, the U.S. Supreme Court recognized
that the purpose of Table S-3 was not to evaluate or select the most
effective long-term waste disposal technology or develop site selection
criteria.\21\ The Court noted that the NRC's intent, as stated in the
1979 rule revising Table S-3 (44 FR 45362; August 2, 1979), was to
estimate the impact of the long-term waste disposal method
conservatively.\22\
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\20\ Baltimore Gas & Elec. Co. v. National Resources Defense
Council, 462 U.S. 87, 103 S.Ct. 2246 (1983).
\21\ Id., 462 U.S. at 102, 103 S.Ct. at 2254-55.
\22\ Id., 462 U.S. at 102, 103 S.Ct. at 2255.
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This conservative analysis included the NRC's use of the zero
release assumption.\23\ The Court also noted that other aspects of
Table S-3 were premised upon the assumption that ``all volatile
materials in the fuel would escape to the environment'' prior to the
sealing of the geologic repository; this assumption balanced the zero-
release assumption, an approach that the Court found acceptable.\24\ In
addition to concluding that it was ``not unreasonable'' for the NRC to
employ the zero release assumption, the Court stated that ``the zero-
release assumption is but a single figure in an entire Table, which the
Commission expressly designed as a risk-averse estimate of the
environmental impact of the fuel cycle . . . [a] reviewing court should
not magnify a single line item beyond its significance as only part of
a larger Table.'' \25\
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\23\ Id. (``The zero-release assumption cannot be evaluated in
isolation. Rather, it must be assessed in relation to the limited
purpose for which the Commission made the assumption.'').
\24\ Id., 462 U.S. at 103, 103 S.Ct. at 2255.
\25\ Id., 462 U.S. at 102-03, 103 S.Ct. at 2255.
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Following the enactment of the NWPA and the Baltimore Gas & Elec.
Co. v. NRDC decision, the NRC issued a Waste Confidence decision in
1984 (49 FR 34658; August 31, 1984) and subsequently updated this
decision in 1990 (55 FR 38472; September 18, 1990) and again in 2010
(75 FR 81032; December 23, 2010). In its 1990 revision, the Commission
discussed the relationship of Table S-3 with its Waste Confidence
decision. Specifically, the Commission noted that the promulgation of
Table S-3 was the outgrowth of efforts to generically evaluate the
environmental impacts of the operation of a light water reactor and in
so doing, that Table S-3 assigned numerical values for environmental
costs resulting from uranium fuel cycle activities to support 1 year of
light water reactor operation. The number of curies indicated for spent
fuel disposal in Table S-3 reflects the total volume of waste material,
not the amount of radioactivity projected to be released from the
repository--an issue that is to be addressed in the safety and
environmental review for the actual geologic repository itself.
Table S-3 lists environmental data to be used by applicants and the
NRC staff for new reactor license applications under 10 CFR parts 50
and 52. Specifically, Table S-3 is the basis for evaluating the
environmental effects of the portions of the uranium fuel cycle for
light water reactors that occur before new fuel is delivered to the
plant and after spent fuel is removed from the plant site. The NRC has
made generic determinations that the radiological impacts of the
uranium fuel cycle on individuals off-site will remain at or below the
Commission's regulatory limits (e.g., the public dose limits set forth
in 10 CFR part 20). The NRC described this generic determination and
conclusion in the License Renewal GEIS.\26\ Additionally, as part of
the new reactor EISs under 10 CFR part 52 and the License Renewal GEIS,
the NRC concluded that the assumptions and methodology used in
preparing Table S-3 were conservative enough that the impacts described
by the use of Table S-3 would still be bounding. In these EISs, the
staff discussed why the contemporary fuel cycle impacts are below those
identified in Table S-3 and as such, Table S-3 remains bounding.\27\
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\26\ 2013 GEIS section 4.12.1.1, p. 4-185.
\27\ For example, see the Bell Bend Nuclear Power Plant EIS,
NUREG 2179, vol. 1, section 6.1 (April 2015), for a discussion of
the NRC determination that Table S-3 remains bounding.
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The NRC concludes that Table S-3 is bounding because, as reflected
in Section 4.12.1.1 of the License Renewal GEIS, industry practice has
shown that the current fleet of reactors uses nuclear fuel more
efficiently due to higher fuel burnup. Therefore, less uranium fuel per
year of reactor operation is required than in the past to generate the
same amount of electricity. Fewer spent fuel assemblies per reactor-
year are generated, hence, the waste storage and deep geologic
repository impacts are lessened. The petitioners have not provided any
new and significant information that would cause the NRC to revisit
these conclusions regarding Table S-3.
While the NRC and the U.S. Department of Energy (DOE) have, in the
past, concentrated efforts regarding geologic repository research and
licensing efforts on a non-bedded salt repository, characterizing the
resulting analysis as confirming that there is a risk of
``significant'' radiation releases and radiation doses from deep
geologic disposal is not accurate. As stated in Volume 1, Appendix B of
the Continued Storage GEIS, ``the consensus within the scientific and
technical community engaged in nuclear waste management is that safe
geologic disposal is achievable with currently available technology.
After decades of research into various geological media, no
[[Page 31536]]
insurmountable technical or scientific problem has emerged to challenge
the conclusion that safe disposal of spent fuel and high-level
radioactive waste can be achieved in a mined geologic repository.''
\28\
---------------------------------------------------------------------------
\28\ NUREG-2157, pg. 2 of Appendix B, Section B.2.1.
---------------------------------------------------------------------------
The issue of concern to the NRC in considering the disposal of
spent nuclear fuel in a geologic repository has not been whether a
zero-release assumption will be met or ultimately the type of
environmental media (e.g., bedded salt, basalt, granite, etc.) selected
for the repository but rather that the appropriate standards are
established and met, thereby ensuring that any releases of radioactive
materials to the environment would not be inimical to public health and
safety. Radiation dose limits for disposal of radioactive materials are
typically no greater than 100 mrem/yr (such as the U.S. Environmental
Protection Agency (EPA) limits for the proposed Yucca Mountain geologic
repository). Although a geologic repository meeting such radiation dose
limits is not a ``zero'' release facility, compliance with these dose
limits would provide adequate protection of public health and safety.
Given the substantial effort developing repositories, it is reasonable
to assume geologic disposal facilities can be developed within a
variety of geologic formations and types that would be protective of
public health and safety. For example, the NRC-National Academy of
Sciences (NAS) study, referred to by Dr. Makhijani, concludes on the
overall performance of candidate repositories that ``[a]ll
radionuclides in unreprocessed spent fuel can be adequately
contained.'' \29\ In conclusion, the NRC has determined that Table S-3
is still bounding and that the petitioners have not provided new and
significant information that requires the NRC to amend Table S-3.
---------------------------------------------------------------------------
\29\ NRC-NAS Report, ``A Study of the Isolation System for
Geologic Disposal of Radioactive Wastes,'' p. 8 and 11.
---------------------------------------------------------------------------
The petitioners assert that Table S-3 and Table B-1 are inconsistent
with each other
The petitioners assert that Table S-3 and Table B-1 are
inconsistent with each other. The petitioners state in PRM-51-30,
``[t]he inconsistencies and questions raised by comparing Table S-3 and
Table B-1 are unacceptable under NEPA's standard for clarity and rigor
of scientific analysis.'' In his comments, Dr. Makhijani stated,
Table S-3 summarizes the NRC's conclusion that the impacts of
spent fuel disposal will be zero, based on the assumption that spent
fuel will be disposed of in a bedded salt repository. Proposed Table
B-1 contradicts Table S-3 by concluding that long-term doses could
be as high as 100 millirem per year. But the NRC does not attempt to
reconcile proposed Table B-1 and Table S-3. . . .\30\
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\30\ Makhijani Declaration attached to PRM-51-30, p. 9.
The environmental effects of operating uranium fuel cycle
facilities including radioactive waste disposal at a geologic
repository were evaluated in two NRC documents, WASH-1248 and NUREG-
0116. The results of these evaluations were summarized in and
promulgated as Table S-3 in 10 CFR 51.51(b). Paragraph (a) in 10 CFR
---------------------------------------------------------------------------
51.51 states:
[E]very environmental report prepared for the construction
permit stage or early site permit stage or combined license stage of
a light-water-cooled nuclear power reactor, and submitted on or
after September 4, 1979, shall take Table S-3, Table of Uranium Fuel
Cycle Environmental Data, as the basis for evaluating the
contribution of the environmental effects of uranium mining and
milling, the production of uranium hexafluoride, isotopic
enrichment, fuel fabrication, reprocessing of irradiated fuel,
transportation of radioactive materials and management of low-level
wastes and high-level wastes related to uranium fuel cycle
activities to the environmental costs of licensing the nuclear power
reactor. Table S-3 shall be included in the environmental report and
may be supplemented by a discussion of the environmental
significance of the data set forth in the table as weighed in the
analysis for the proposed facility.
The environmental effects or issues summarized in Table S-3
include: Land use; water consumption and thermal effluents; radioactive
releases; burial of transuranic, high-level and low-level radioactive
wastes; and radiation doses from transportation and occupational
exposures. The contributions in Table S-3 for reprocessing, waste
management, and transportation of wastes are maximized for either of
the two fuel cycles (i.e., a fuel cycle that includes spent fuel
reprocessing and one that does not)--the cycle that results in the
greater environmental impact, and thus the most conservative analysis,
is used. The environmental impact values are expressed in terms
normalized to show the potential impacts attributable to processing the
fuel required for the operation of a 1,000-MWe nuclear power plant for
1 year at an 80 percent availability factor to produce about 800 MW-yr
of electricity. This normalization is referred to as one reference
reactor year. For each environmental consideration, Table S-3 presents
a result that has been integrated over the entire uranium fuel cycle
except during reactor operations.\31\ The environmental impacts of
reactor operations are addressed in the EIS prepared for each
individual reactor licensing action (i.e., an EIS for a new reactor
licensing application or a SEIS for a license renewal application).
Although certain fuel cycle operations and fuel management practices
have changed over the years, the assumptions and methodology used in
preparing Table S-3 were, and continue to be, conservative enough that
the impacts described in Table S-3 are still bounding.
---------------------------------------------------------------------------
\31\ The only exception is that the waste quantities listed
under the entry called ``solids (buried onsite)'' also include
wastes generated at the reactor.
---------------------------------------------------------------------------
In similar fashion, the NRC assessed the generic environmental
impacts of renewing the operating license for a nuclear power plant in
the License Renewal GEIS. Table B-1 summarizes the Commission's
findings on the scope and magnitude of the environmental effects of
renewing the operating license for a nuclear power plant, based on
technical bases documented in the 2013 update of the License Renewal
GEIS. Subject to an evaluation of those Category 2 issues, which
require further site-specific analysis, and the identification of
possible new and significant information for any Category 1 or Category
2 issue, Table B-1 represents the analysis of the environmental impacts
associated with the renewal of any operating license and is to be used
in accordance with 10 CFR 51.95(c). On a 10-year cycle, the Commission
intends to review the findings in Table B-1 and update the table if
necessary. The latest review and update was completed in 2013.
Both the License Renewal GEIS and Table B-1 incorporate Table S-3
by reference.\32\ Tables S-3 and B-1 were developed at separate times
for different purposes. However, the technical bases for the
consideration of spent fuel storage and disposal impacts for both
tables are the same, and as such, the tables are consistent with each
other. The impact of the spent nuclear fuel disposal finding in Table
B-1 (i.e., ``Offsite radiological impacts of spent nuclear fuel and
high-level waste disposal'') is consistent with the solid waste
disposal information presented in Table S-3, as the findings in Table
B-1 could not have been reached without the environmental effects
evaluations conducted in WASH-1248 and NUREG-
[[Page 31537]]
0116, which are summarized in Table S-3.
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\32\ Table B-1 references Table S-3 under the ``Uranium Fuel
Cycle'' section of the table.
---------------------------------------------------------------------------
Moreover, even if there were differences in the assumptions in
Table S-3 and Table B-1, those differences are not significant from a
NEPA perspective. As noted above, the issue of concern to the NRC in
considering the environmental impacts of the disposal of spent nuclear
fuel in a geologic repository has not been whether a zero-release
assumption will be met or ultimately the type of environmental media
(e.g., bedded salt, basalt, granite, etc.) selected for the repository
but rather that the appropriate standards are established and met,
thereby ensuring that any releases of radioactive materials to the
environment would not be inimical to public health and safety. For NEPA
purposes, such releases within regulatory limits are clearly not
significant radiation releases and radiation doses. The NRC concludes
that Tables B-1 and S-3 are consistent with each other and there is no
technical or regulatory reason to amend either table.
No significance determination for ``off-site spent fuel disposal'' in
Table B-1
The petitioners assert that Table B-1, which codifies the findings
of the License Renewal GEIS, does not include a finding as to whether
the impacts of spent fuel disposal are significant or not. The
``significance determination'' in NEPA is made by an agency in
determining whether it is necessary to prepare an EIS for a given
proposed action.\33\ With respect to the environmental review of
reactor license renewal applications, the NRC has already prepared a
GEIS, the License Renewal GEIS. In addition, for each site-specific
license renewal action, the NRC prepares a SEIS. Therefore, the lack of
a finding as to whether the impacts of spent fuel disposal are
``significant'' or ``not significant'' is irrelevant, as the NRC has
already satisfied the ``significance determination'' by preparing a
generic EIS and by its regulatory requirement to prepare a site-
specific EIS for each reactor license renewal application it considers.
---------------------------------------------------------------------------
\33\ Lower Alloways Creek Tp. v. Public Service Elec. & Gas Co.,
687 F.2d 732, 740 (3rd Cir. 1987) (``[A]n agency must undertake a
comprehensive assessment of the expected effects of a proposed
action before it can determine whether that action is `significant'
for NEPA purposes . . . . [i]f, however, it is clear that the human
environment will be `significantly' affected, then a full-scale EIS
is mandatory.''); Blue Mountains Biodiversity Project v. Blackwood,
161 F.3d 1208, 1211-14, and 1216 (9th Cir. 1998) (Forest Service
made clear error of judgment in its decision to prepare an
environmental assessment, rather than an environmental impact
statement); see also Mandelker, NEPA Law and Litigation, 2d,
Sec. Sec. 8.48-8.58.
---------------------------------------------------------------------------
Moreover, the NRC has extensively analyzed spent fuel storage and
disposal environmental impacts in Table S-3, and in various EISs,
namely, the License Renewal GEIS, the Continued Storage GEIS, and SEISs
for individual license renewal actions. The License Renewal GEIS
provides the regulatory and technical basis for the Commission's
findings and the associated impact significance levels for each
environmental NEPA issue listed in Table B-1. The NRC's evaluation of
the environmental impacts of the issue, ``Offsite radiological impacts
of spent nuclear fuel and high-level waste disposal,'' \34\ was
documented in the 1996 License Renewal GEIS, which relied upon the
findings of the NRC's 1990 Waste Confidence Decision and Rule. In
addition, the NRC analyzed the EPA's generic repository standards and
dose limits in existence at the time and concluded that offsite
radiological impacts warranted a Category 1 (generic) determination (61
FR 28467; June 5, 1996). However, due to the decision of the U.S. Court
of Appeals for the DC Circuit in New York v. NRC and its remand of the
2010 Waste Confidence Decision and Rule (75 FR 81032; December 23,
2010), the NRC was not able to complete its review and update of the
impact finding for this issue in the 2013 License Renewal GEIS (NUREG-
1437, Revision 1) and update of Table B-1. As a result, the 2013
License Renewal GEIS and rule (78 FR 37282; June 20, 2013) reclassified
the issue from Category 1 with no impact level assigned, to an
uncategorized issue with an uncertain impact level.
---------------------------------------------------------------------------
\34\ This issue was named ``Offsite radiological impacts (spent
fuel and high level waste disposal)'' in the 1996 license renewal
GEIS and rule.
---------------------------------------------------------------------------
On August 26, 2014, the Commission approved the Continued Storage
Rule and its associated GEIS (Continued Storage GEIS) amending 10 CFR
part 51 to revise the generic determination on the environmental
impacts of continued storage of spent nuclear fuel beyond the licensed
life for operation of a reactor. In making conforming changes to the
Table B-1 entry for the issue ``Offsite radiological impacts of spent
nuclear fuel and high-level waste disposal,'' the final rule restored
the Category 1 designation and references the existing radiation
protection standards for Yucca Mountain instead of making a single
impact finding.
The NRC's practice, once it has determined to prepare an EIS, has
been to assign a significance level to most potential environmental
impacts, by resource area or environmental issue, arising from the
proposed action. These levels are ``Small, Moderate, and Large.'' The
assigning of these levels to any given impact is not required by law;
it is solely a matter of NRC practice. Neither the Council on
Environmental Quality's nor the NRC's regulations for implementing NEPA
under 10 CFR part 51 explicitly require an agency to assign a single
significance level to environmental impact issues; CEQ regulations
state that ``[i]mpacts shall be discussed in proportion to their
significance'' in the context of preparing environmental impact
statements for agency actions.\35\ Further, NRC does not assign such a
level to every resource area or environmental issue covered by a given
EIS. The NRC only assigns a single significance level for a generic
issue where it is meaningful and appropriate to do so when considering
both the context and intensity of a potential environmental impact.\36\
---------------------------------------------------------------------------
\35\ 40 CFR 1502.2(b).
\36\ See CEQ regulation 40 CFR 1508.27, which defines the term
``significantly,'' in relation to both ``context'' and
``intensity.''
---------------------------------------------------------------------------
In this regard, the NRC has never assigned a single impact
significance level to the issue of ``Offsite radiological impacts of
spent nuclear fuel and high-level waste disposal.'' Although the status
of a repository, including a repository at Yucca Mountain, remains
uncertain and beyond the control of the NRC, the NRC has adopted EPA's
radiation protection standards (40 CFR part 197) for Yucca Mountain
because they are the current standard for ensuring that the ultimate
disposal of spent nuclear fuel will present no undue risk to public
health and safety. As discussed in the Continued Storage GEIS, it is
reasonable to believe that wherever a geologic repository is ultimately
sited, radiological protection standards comparable to those
established for Yucca Mountain will be issued if necessary. Given these
considerations, the Commission's narrative finding in Table B-1 with
respect to the issue of offsite disposal is appropriate. That finding
states ``[t]he Commission concludes that the impacts would not be
sufficiently large to require the NEPA conclusion, for any plant, that
the option of extended operation under 10 CFR part 54 should be
eliminated. Accordingly, while the Commission has not assigned a single
level of significance for the impacts of spent fuel and high level
waste disposal, this issue is considered Category 1.'' Therefore, the
Commission, by rule, has determined that a single significance
determination is not necessary.
[[Page 31538]]
The NRC concludes that the petitioners' significance determination
argument does not provide a ``seriously different picture'' of the
environmental consequences of spent fuel storage and disposal. Instead,
based on the above, the NRC concludes that the petitioners' assertion
that NEPA requires an agency to assign a single level of significance
to the issue in question is without merit and that the petitioners'
proposed amendment to the NRC's finding for the issue, ``Offsite
radiological impacts of spent nuclear fuel and high-level waste
disposal,'' in Table B-1 in appendix B to subpart A of 10 CFR part 51
is not necessary.
The petitioners assert that license renewal applicants in 10 CFR
51.53(c) and NRC staff in 10 CFR 51.71(d) are excused from addressing
spent fuel storage impacts in license renewal environmental reviews
The NRC disagrees with the petitioners' assertion that the NRC's
regulations in 10 CFR 51.53(c) and 51.71(d) ``excuse license renewal
applicants and the NRC from addressing spent fuel storage impacts in
license renewal cases.'' The NRC has determined that the potential
environmental impacts of spent fuel storage are of a generic nature and
as such, do not need to be re-analyzed for every license renewal
action. As mentioned previously, for future reactor license renewal
applications that rely on the Continued Storage and License Renewal
GEISs, the NRC will incorporate the environmental impacts analyzed in
the Continued Storage GEIS as well as in the License Renewal GEIS into
the overall NEPA analysis supporting its licensing decision. The U.S.
Supreme Court has upheld the use of generic environmental analyses by
the NRC.\37\ Moreover, as part of its environmental review for each
license renewal application, the NRC reviews both generic and site-
specific issues for new and significant information. In the event that
the NRC determines that there is new and significant information, the
NRC will consider such information when preparing the SEIS for that
particular licensing action and, if necessary, will also determine
whether the License Renewal GEIS or Continued Storage GEIS should be
revised accordingly.
---------------------------------------------------------------------------
\37\ Baltimore Gas & Elec. Co. v. NRDC, 462 U.S. at 101, 103
S.Ct. at 2254 (``The generic method chosen by the agency is clearly
an appropriate method of conducting the hard look required by
NEPA.'').
---------------------------------------------------------------------------
Moreover, the quality of the NRC's environmental analysis of spent
fuel storage is not dependent on whether the NRC prepares a site-
specific or generic analysis. In developing both the License Renewal
GEIS and the Continued Storage GEIS, the NRC employed assumptions,
including those based upon reactor licensee operating experience, that
are sufficiently conservative to bound the predicted impacts such that
any variances that may occur from site to site are unlikely to result
in environmental impact determinations that are greater than those
presented in both GEISs.\38\ In addition, recent spent fuel studies
(including the expedited spent fuel transfer regulatory analysis
included in COMSECY-13-0030 and NUREG-2161) continue to support the
findings of the License Renewal GEIS. Though the studies may contain
``new'' information, the information is not ``significant'' for the
purpose of the environmental analysis. The NUREG-2161 compared spent
fuel pool accident consequences from previous research studies and
determined that they were of the same magnitude. Finally, the Continued
Storage GEIS reinforces the Commission's original determination that
supports use of a generic analysis.
---------------------------------------------------------------------------
\38\ Statements of Consideration for 1996 (61 FR 28467, 28479-
480) and 2013 (78 FR 37282, 37310) License Renewal GEISs.
---------------------------------------------------------------------------
The NRC concludes that the petitioners' arguments regarding 10 CFR
51.53(c) and 51.71(d) do not provide a ``seriously different picture''
of the environmental consequences of spent fuel storage and disposal.
Instead, based on the above, the NRC concludes that spent fuel storage
impacts are fully evaluated as part of the NRC's license renewal
actions and that the petitioners' proposed amendments are not
necessary.
The petitioners assert that the need for power and economic costs were
excluded in license renewal environmental reviews
The petitioners assert that NRC regulations in 10 CFR 51.53(c) and
51.71(d) excuse license renewal applicants and the NRC staff from
addressing the need for power in license renewal cases. The petitioners
state, ``[b]y excluding need for power from consideration in re-
licensing decisions, the [Continued Storage] GEIS cripples its ability
to assess the environmental impacts of storing spent fuel. This results
in an `unbounded' analysis of radiological risk.'' The petitioners also
assert that ``it is essential to incorporate the economic costs of
spent fuel storage and disposal in reactor cost-benefit analyses.'' In
conjunction with the issuance of the License Renewal GEIS in 1996, the
Commission amended its regulations concerning environmental reviews for
nuclear power plant license renewal actions.\39\ These amendments
defined the generic environmental impacts addressed in the License
Renewal GEIS and the environmental impacts for which nuclear plant
site-specific analyses were to be performed. The Commission stated in
the June 5, 1996, final rule for the ``Environmental Review for Renewal
of Nuclear Power Plant Operating Licenses,''
---------------------------------------------------------------------------
\39\ 61 FR 28467; June 5, 1996.
[T]he NRC will neither perform analyses of the need for power
nor draw any conclusions about the need for generating capacity in a
license renewal review. [The] definition of purpose and need
reflects the Commission's recognition that, absent findings in the
safety review required by the Atomic Energy Act of 1954, as amended,
or in the NEPA environmental analysis that would lead the NRC to
reject a license renewal application, the NRC has no role in the
energy planning decisions of State regulators and utility officials.
From the perspective of the licensee and the State regulatory
authority, the purpose of renewing an operating license is to
maintain the availability of the nuclear plant to meet system energy
requirements beyond the term of the plant's current license.\40\
---------------------------------------------------------------------------
\40\ 61 FR at 28472.
---------------------------------------------------------------------------
As stated in the 2013 License Renewal GEIS,
The purpose and need for the proposed action (issuance of a
renewed license) is to provide an option that allows for baseload
power generation capability beyond the term of the current nuclear
power plant operating license to meet future system generating
needs. Such needs may be determined by other energy-planning
decision-makers, such as State, utility, and, where authorized,
Federal agencies (other than the NRC). Unless there are findings in
the safety review required by the Atomic Energy Act or the NEPA
environmental review that would lead the NRC to reject a license
renewal application, the NRC does not have a role in the energy-
planning decisions of whether a particular nuclear power plant
should continue to operate.\41\
---------------------------------------------------------------------------
\41\ License Renewal GEIS, NUREG-1437, Revision 1 (2013),
Section 1.3, p. 1-3-1-4.
As shown by these statements, it has been the NRC's longstanding
position not to consider the need for power or economic costs in making
its license renewal decisions. Consideration of the need for power or
the economic cost of renewing the operating license of a nuclear
reactor is beyond the NRC's statutory and regulatory purview; rather,
such consideration is the responsibility of State and local authorities
and, where appropriate, Federal entities such as the Federal Energy
Regulatory Commission or the Tennessee Valley Authority. The
[[Page 31539]]
petitioners' assertion that NRC's regulatory approach of excluding need
for power from consideration in license renewal decisions ``cripples''
NRC's ability to assess the environmental impacts of storing spent fuel
is not new and significant information and thus does not provide a
basis for amending the regulations.
``Reasonable assurance'' findings not included in proposed 10 CFR 51.23
In commenting upon the NRC's proposed Continued Storage rule (78 FR
56776; September 13, 2013), the petitioners asserted that the NRC's
proposal to remove the ``reasonable assurance'' statement from 10 CFR
51.23(a) was improper. Prior to the promulgation of the Continued
Storage final rule (79 FR 56238; September 19, 2014), 10 CFR 51.23(a)
stated, in part, that ``the Commission believes there is reasonable
assurance that sufficient mined geologic repository capacity will be
available to dispose of the commercial high-level radioactive waste and
spent fuel generated in any reactor when necessary.'' \42\ In the final
Continued Storage rule, the NRC removed the ``reasonable assurance''
statement.\43\ The statements of consideration of the final Continued
Storage rule explain that 10 CFR 51.23(a) sets forth the NRC's generic
determination that the environmental impacts of the continued storage
of spent nuclear fuel beyond the licensed life for operation of a
reactor are those impacts identified in NUREG-2157 (the Continued
Storage GEIS). In particular, the statements of consideration note
that,
---------------------------------------------------------------------------
\42\ 10 CFR 51.23(a) (2013).
\43\ 79 FR at 56260.
NEPA is a procedural statute directed at Federal agencies, and
10 CFR 51.23 (including the additional clarifying amendments)
addresses the manner by which the NRC complies with NEPA with
respect to the subject of continued storage. These amendments do not
require action by any person or entity regulated by the NRC, nor do
these amendments modify the substantive responsibilities of any
person or entity regulated by the NRC.\44\
---------------------------------------------------------------------------
\44\ 79 FR at 56253.
Consequently, there was no need to retain the ``reasonable
assurance'' statement, which is a safety finding, as 10 CFR 51.23(a)
stated only the generic environmental determination and the remainder
of 10 CFR 51.23 concerns the NRC's NEPA compliance. In this regard, the
---------------------------------------------------------------------------
statements of consideration explain,
The [Continued Storage] GEIS fulfills the NRC's NEPA obligations
and provides a regulatory basis for the rule rather than addressing
the agency's responsibilities to protect public health and safety
under the Atomic Energy Act (AEA), of 1954 as amended. Further,
Appendix B of the [Continued Storage] GEIS discusses the technical
feasibility of continued safe storage. It is important to note that,
in adopting revised 10 CFR 51.23 and publishing the [Continued
Storage] GEIS, the NRC is not making a safety determination under
the AEA to allow for the continued storage of spent fuel. AEA safety
determinations associated with licensing of these activities are
contained in the appropriate regulatory provision addressing
licensing requirements and in the specific licenses for facilities.
Further, there is not any legal requirement for the NRC to codify a
generic safety conclusion in the rule text. By not including a
safety policy statement in the rule text, the NRC does not imply
that spent fuel cannot be stored safely. To the contrary, the
analysis documented in the [Continued Storage] GElS is predicated on
the ability to store spent fuel safely over the short-term, long-
term, and indefinite timeframes. This understanding is based upon
the technical feasibility analysis in Appendix B of the [Continued
Storage] GElS and the NRC's decades-long experience with spent fuel
storage and development of regulatory requirements for licensing of
storage facilities that are focused on safe operation of such
facilities, which have provided substantial technical knowledge
about storage of spent fuel. Further, spent fuel is currently being
stored safely at reactor and storage sites across the country, which
supports the NRC's conclusion that it is feasible for spent fuel to
be stored safely for the timeframes considered in the [Continued
Storage] GEIS.\45\
---------------------------------------------------------------------------
\45\ 79 FR at 56254-55.
The petitions do not present any new and significant information
that would form a basis to amend 10 CFR 51.23, particularly in light of
the September 19, 2014, Continued Storage rulemaking.
The petitioners assert that expedited spent fuel transfer analysis is
``new and significant information''
The petitioners request that the NRC ``consider, in all pending and
future reactor licensing and re-licensing decisions, new and
significant information bearing on the environmental impacts of high-
density pool storage in reactor pools and alternatives for avoiding or
mitigating those impacts.'' The petitioners assert that the NRC
generated new and significant information during its post-Fukushima
Expedited Spent Fuel Transfer proceeding.
On October 9, 2013, the NRC released NUREG-2161, ``Consequence
Study of a Beyond-Design-Basis Earthquake Affecting the Spent Fuel Pool
for a U.S. Mark I Boiling Water Reactor'' and, on November 12, 2013,
the NRC delivered a regulatory analysis in COMSECY-13-0030, ``Staff
Evaluation and Recommendation for Japan Lessons-Learned Tier 3 Issue on
Expedited Transfer of Spent Fuel.'' These documents concluded that
spent fuel pools are very robust structures with large safety margins,
and that proposed regulatory actions for spent fuel pool safety
improvements were not warranted. This conclusion not only covers spent
fuel pools at operating reactors applying for license renewal but also
spent fuel pools that would be constructed at new reactor sites. Citing
the low risk to public health and safety from spent fuel pool storage,
the Commission subsequently concluded that regulatory action need not
be pursued in Staff Requirements Memorandum (SRM), SRM-COMSECY-13-0030,
issued on May 23, 2014.
The petitioners contend that former Chairman Allison Macfarlane's
comments on COMSECY-13-0030, also provide new and significant
information that requires the NRC to reconsider its impact findings in
the 2013 license renewal GEIS. The former Chairman's comments were
considered by the other Commissioners in the development of the SRM on
this issue. However, the Commission determined in SRM-COMSECY-13-0030,
that no further generic assessments concerning the expedited transfer
of spent fuel to dry cask storage should be pursued. Notably, the SRM
supported the staff's approach of using the NRC's Safety Goal Policy
Statement of 1986 as a screening metric. The SRM is the agency's
determination on this issue.
Nonetheless, the petitioners contend that NUREG-2161 and COMSECY-
13-0030 constitute new and significant information based on those
documents' discussion of the severity of the impact of a spent fuel
pool accident, sensitivity studies showing that some mitigation
measures could be cost beneficial, and the possibility that a reactor
accident could impact the likelihood of a spent fuel pool fire.
However, none of these sources of information provides ``a seriously
different picture'' of the environmental consequences of spent fuel
storage. First, as noted above, the NRC has frequently recognized that
the consequences of a spent fuel pool accident could be large but has
determined that the overall risk of spent fuel pool accidents is small
in light of the low probability of such an event.\46\ Therefore, the
petitioners have not shown that the magnitude of the consequences of a
spent fuel pool accident constitute new and significant information.
Rather, NUREG-2161 and
[[Page 31540]]
COMSECY-13-0030's recognition that the consequences of a spent fuel
pool accident could be large but that the overall risk from such an
event is small in light of the very low probability of such an event
comports with the agency's previous considerations of this issue.
Second, while the sensitivity studies may have shown that some
mitigation measures could be cost-beneficial, they are based on
alternate assumptions that do not represent the NRC's analysis of the
most likely impacts of a spent fuel pool accident. In any event,
petitioners have not shown with specificity that any information in
these sensitivity studies would undermine the agency's overall
conclusion that despite potentially large consequences, the very low
probability renders the overall risk of a spent fuel pool accident very
low. Finally, contrary to petitioners' assertions, the NRC has
frequently responded to claims that the probability of a reactor
accident could impact the probability of a spent fuel pool accident and
repeatedly found that such a probability is very low.\47\
---------------------------------------------------------------------------
\46\ NUREG-1437, Rev.1, at E-34 to -339.
\47\ 73 FR at 46210; 2013 GEIS at E-38; NUREG-2157 at D-438 to
D-440; COMSECY-13-0030, Enclosure 1 at 138.
---------------------------------------------------------------------------
In conclusion, neither NUREG-2161, COMSECY-13-0030, nor SRM-
COMSECY-13-0030 constitutes ``new and significant information''
requiring the NRC to supplement any of its prior EISs, whether generic
or specific-- or amend those ``regulations that make or rely on
findings regarding the environmental impacts of spent fuel storage
during reactor operation, including Table B-1 and all regulations
approving standardized reactor designs.''
III. Determination of Petitions
For the reasons cited in Section II of this document, the NRC has
concluded that the petitioners have not provided new and significant
information that would form a basis to amend the NRC regulations
identified in the PRM-51-30 and PRM-51-31.
Earlier 10 CFR Part 51 PRMs
Several of the regulations identified by the petitioners have been
the subject of prior rulemaking petitions (i.e., PRM-51-1, PRM-51-10,
PRM-51-12, and PRMs-51-14 to 51-28) and issues similar to those raised
by the petitioners were considered by the Commission in these prior
petitions, therefore, these issues have been thoroughly evaluated by
the Commission. The PRM-51-1 petitioner asserted that Table S-3
``seriously understate[d]'' the impact on human health and safety from
the uranium fuel cycle and that the Table S-3 values should be revised
accordingly.\48\ The NRC denied PRM-51-1 based upon the Commission's
``generic determination that the radiological impacts of the uranium
fuel cycle on individuals off-site will remain at or below the
Commission's regulatory limits, and as such, are of small
significance.'' \49\ The NRC described this generic determination in
Chapter 6 of the 1996 version of the License Renewal GEIS; the generic
determination was based upon findings made in various NRC and EPA
rulemakings.\50\
---------------------------------------------------------------------------
\48\ 73 FR 14946; March 20, 2008.
\49\ 73 FR at 14947.
\50\ Id. at 14948.
---------------------------------------------------------------------------
The petitioners in PRM-51-10 and PRM-51-12 challenged the generic
findings for spent fuel storage impacts codified in Table B-1 and
requested a rulemaking to remove this finding.\51\ The petitioners
raised the prospect of a fire at a nuclear power reactor's spent fuel
pool and the resulting release of radioactive material to the
environment. According to the petitioners' scenario, the spent fuel
pool fire would be initiated by either an accident or a successful
terrorist strike that would cause a partial or complete drain of the
cooling water in the spent fuel pool. The petitioners requested the
amendment of several of the regulations that are the subject of PRM-51-
30 and PRM-51-31, namely, Table B-1, 10 CFR 51.23, 51.53(c), and
51.95(c).\52\ The petitioners requested that the impacts of spent fuel
storage be considered on a site-specific basis in license renewal
cases, rather than generically, due to this potential threat. The
Commission denied PRM-51-10 and PRM-51-12 and concluded that the risk
of such a spent fuel pool fire was very low and that, given the safety
and security requirements that applied to all plants, as well as the
physical robustness of spent fuel pools, the environmental impacts of
spent fuel pool storage could be handled generically.\53\ The NRC's
denial of PRM-51-10 and PRM-51-12 was upheld by the U.S. Court of
Appeals for the Second Circuit.\54\
---------------------------------------------------------------------------
\51\ 73 FR 46204; August 8, 2008.
\52\ Id. at 46205.
\53\ Id. at 46206-12.
\54\ New York v. U.S. Nuclear Regulatory Commission, 589 F.3d
551 (2nd Cir. 2009).
---------------------------------------------------------------------------
Finally, in a series of virtually identical petitions, docketed as
PRM-51-14 through PRM-51-28, petitioners requested that the NRC rescind
all regulations that reach generic environmental impact conclusions
regarding severe reactor accidents and spent fuel pool accidents, which
would include various provisions of Table B-1 and 10 CFR 51.53. The
PRM-51-14 through PRM-51-28 petitions were filed shortly after the NRC
issued its Near-Term Task Force (NTTF) report, ``Recommendations for
Enhancing Reactor Safety in the 21st Century, the NTTF Review of
Insights from the Fukushima Dai-ichi Accident,'' dated July 12, 2011.
The NTTF report provided the NRC staff's recommendations to enhance
U.S. nuclear power plant safety following the March 11, 2011, Fukushima
accident in Japan. After determining that the NTTF report did not
constitute new and significant information and further, that the
petitioners had provided insufficient technical or regulatory basis to
amend any of the NRC regulations in question, the NRC denied the PRM-
51-14 through PRM-51-28 petitions.\55\
---------------------------------------------------------------------------
\55\ 80 FR 48235 (August 12, 2015).
---------------------------------------------------------------------------
IV. Availability of Documents
The documents identified in the following table are available to
interested persons through one or more of the following methods, as
indicated. For more information on accessing ADAMS, see the ADDRESSES
section of this document.
------------------------------------------------------------------------
ADAMS Accession No./Web Link/
Document Federal Register citation
------------------------------------------------------------------------
CLI-99-22, Hydro Resources, Inc., https://www.nrc.gov/reading-rm/doc-
July 23, 1999. collections/commission/orders/1999/
1999-022cli.pdf
CLI-14-07, DTE Electric Co., et https://www.nrc.gov/reading-rm/doc-
al., July 17, 2014. collections/commission/orders/2014/
2014-07cli.pdf
``Comments by Environmental ML14029A124, ML14029A169,
Organizations on Draft Waste ML14029A154
Confidence Generic Environmental
Impact Statement [GEIS] and
Proposed Waste Confidence Rule and
Petition to Revise and Integrate
All Safety and Environmental
Regulations Related to Spent Fuel
Storage and Disposal,'' January 7,
2014.
[[Page 31541]]
COMSECY-13-0030, Staff Evaluation ML13273A601
and Recommendation for Japan
Lessons-Learned Tier 3 Issue on
Expedited Transfer of Spent Fuel,
November 12, 2013.
COMSECY-13-0030 Vote Sheet, Staff https://www.nrc.gov/reading-rm/doc-
Evaluation and Recommendation for collections/commission/comm-secy/
Japan Lessons-Learned Tier 3 Issue 2013/2013-0030comvtr.pdf
on Expedited Transfer of Spent
Fuel, April 8, 2014.
Federal Register notice--Waste 78 FR 56776
Confidence--Continued Storage of
Spent Nuclear Fuel (proposed
rule), September 13, 2013.
Federal Register notice-- 39 FR 14188
Environmental Effects of the
Uranium Fuel Cycle, April 22, 1974.
Federal Register notice--Licensing 44 FR 45362
and Regulatory Policy and
Procedures for Environmental
Protection; Uranium Fuel Cycle
Impacts From Spent Fuel
Reprocessing and Radioactive Waste
Management, August 2, 1979.
Federal Register notice--Waste 49 FR 34658
Confidence Decision, August 31,
1984.
Federal Register notice-- 55 FR 38472
Consideration of Environmental
Impacts of Temporary Storage of
Spent Fuel After Cessation of
Reactor Operation, September 18,
1990.
Federal Register notice-- 61 FR 28467
Environmental Review for Renewal
of Nuclear Power Plant Operating
Licenses, June 5, 1996.
Federal Register notice--Waste 75 FR 81037
Confidence Decision Update,
December 23, 2010.
Federal Register notice--Continued 79 FR 56238
Storage of Spent Nuclear Fuel
(final rule), September 19, 2014.
Federal Register notice--Revisions 78 FR 37282
to Environmental Review for
Renewal of Nuclear Power Plant
Operating Licenses, June 20, 2013.
Federal Register notice--Revise and 79 FR 22055
Integrate All Safety and
Environmental Regulations Related
to Spent Fuel Storage and
Disposal, April 21, 2014.
Federal Register notice-- 79 FR 24595
Environmental Impacts of Spent
Fuel Storage During Reactor
Operation, May 1, 2014.
Federal Register notice-- 79 FR 42989
Environmental Impacts of Spent
Fuel Storage During Reactor
Operation, July 24, 2014.
Federal Register notice--New 73 FR 14946
England Coalition on Nuclear
Pollution; Denial of Petition for
Rulemaking, March 20, 2008.
Federal Register notice--The 73 FR 46204
Attorney General of Commonwealth
of Massachusetts, The Attorney
General of California; Denial of
Petitions for Rulemaking, August
8, 2008.
Federal Register notice-- 80 FR 48235
Environmental Impacts of Severe
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Environmental Impacts of Spent
Fuel Storage During Reactor
Operation,'' February 18, 2014.
[[Page 31542]]
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------------------------------------------------------------------------
Dated at Rockville, Maryland, this 13th day of May, 2016.
For the Nuclear Regulatory Commission.
Annette L. Vietti-Cook,
Secretary of the Commission.
[FR Doc. 2016-11820 Filed 5-18-16; 8:45 am]
BILLING CODE 7590-01-P