ML21096A295

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

ML21096A295
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Issue date:	04/30/2021
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Malone, Tina
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NUREG/BR-0058, Rev. 5
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1 2

3 APPENDIX I NATIONAL ENVIRONMENTAL POLICY ACT COST-BENEFIT ANALYSIS GUIDANCE

I-iii NUREG/BR-0058, Rev. 5, App. I, Rev. 0 TABLE OF CONTENTS 1

2 ABBREVIATIONS AND ACRONYMS.......................................................................... I-v 3

I.1 PURPOSE........................................................................................................... I-1 4

I.2 COST-BENEFIT ANALYSIS FOR NATIONAL ENVIRONMENTAL POLICY 5

ACT REVIEWS.................................................................................................... I-2 6

I.2.1 Regulatory Requirements....................................................................................... I-2 7

I.2.1.1 Environmental Reports Prepared by License Applicants............................ I-2 8

I.2.1.2 National Environmental Policy Act Documents Prepared by the NRC 9

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

NUREG/BR-0058, Rev. 5, App. I, Rev. 0 I-iv I.4.2.3 Construction Permits and Operating Licenses......................................... I-15 1

I.4.3 Nuclear Material Licenses.................................................................................... I-15 2

I.5 REFERENCES.................................................................................................. I-17 3

4

I-v NUREG/BR-0058, Rev. 5, App. I, Rev. 0 ABBREVIATIONS AND ACRONYMS 1

2 ADAMS Agencywide Documents Access and Management System 3

CEQ Council on Environmental Quality 4

CFR Code of Federal Regulations 5

COL combined license 6

CP construction permit 7

EA environmental assessment 8

EIS environmental impact statement 9

EO Executive order 10 EPRI Electric Power Research Institute 11 ER environmental report 12 ESRP environmental standard review plan 13 FONSI finding of no significant impact 14 FR Federal Register 15 FSAR final safety analysis report 16 IPE individual plant examination 17 LWR light water reactor 18 NEI Nuclear Energy Institute 19 NEPA National Environmental Policy Act of 1969 20 NMSS Office of Nuclear Material Safety and Safeguards 21 NRC U.S. Nuclear Regulatory Commission 22 NRR Office of Nuclear Reactor Regulation 23 NUREG NRC technical report designation 24 NUREG/BR NUREG brochure 25 OL operating license 26 PRA probabilistic risk assessment 27 RG regulatory guide 28 SAMA severe accident mitigation alternative 29 SAMDA severe accident mitigation design alternative 30 SECY Office of the Secretary of the Commission, NRC Commission paper 31 SER safety evaluation report 32 SOARCA State-of-the-Art Reactor Consequence Analyses 33 U.S.C.

United States Code 34

I-1 NUREG/BR-0058, Rev. 5, App. I, Rev. 0 NATIONAL ENVIRONMENTAL POLICY ACT 1

COST-BENEFIT ANALYSIS GUIDANCE 2

3 I.1 PURPOSE 4

5 This appendix describes the methods used by the U.S. Nuclear Regulatory Commission (NRC) 6 when conducting cost-benefit analyses to satisfy the requirements of the National 7

Environmental Policy Act of 1969, as amended (NEPA) (42 U.S.C. 4332 et seq.) during 8

rulemaking or licensing reviews. The purpose of NEPA is to ensure that each Federal agency 9

considers, along with other factors, the impacts of its actions on the environment and the health 10 and welfare of the public. In implementing NEPA, Federal agencies must evaluate the 11 environmental effects of their actions before they make decisions and prepare a detailed 12 statement for major Federal actions that significantly affect the quality of the human 13 environment.

14 15 Title 10 of the Code of Federal Regulations (10 CFR) Part 51, Environmental Protection 16 Regulations for Domestic Licensing and Related Regulatory Functions, contains the NRCs 17 regulations for implementing NEPA. NEPA requires Federal agencies to conduct a detailed 18 assessment of the environmental effects of a proposed action, alternatives to the action, and 19 irreversible commitments of resources involved with the action. A comparative evaluation of the 20 proposed action and alternatives includes the identification, characterization, and analysis of 21 both monetized (i.e., those measured in dollars) and qualitative (i.e., descriptive or 22 nonmonetized) costs and benefits of environmental effects.

23 24 A cost-benefit analysis is one component of the NRCs analytical requirements under NEPA.

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

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

33 34 At the license renewal stage for a nuclear power plant under 10 CFR 51.95(c), a discussion of 35 the economic or technical costs and benefits of either the proposed action or alternatives is not 36 required unless costs and benefits are either (1) essential for determining whether to include an 37 alternative in the range of alternatives considered or (2) relevant to mitigation of severe 38 accidents.1 39 1

According to Table B-1, Summary of Findings on NEPA Issues for License Renewal of Nuclear Power Plants, in Appendix B to Subpart A, Environmental Effect of Renewing the Operating License of a Nuclear Power Plant, of 10 CFR Part 51, severe accident mitigation alternatives (SAMAs) must be considered for all plants that have not considered such alternatives.

NUREG/BR-0058, Rev. 5, App. I, Rev. 0 I-2 I.2 COST-BENEFIT ANALYSIS FOR NATIONAL ENVIRONMENTAL 1

POLICY ACT REVIEWS 2

3 This section describes the process for conducting cost-benefit analyses in support of NEPA 4

reviews for NRC licensing actions.Section I.4 presents the methods used for conducting 5

cost-benefit analyses in evaluations of SAMAs and severe accident mitigation design 6

alternatives (SAMDA).

7 8

I.2.1 Regulatory Requirements 9

10 The regulations at 10 CFR Part 51 provide the NRCs requirements for implementing NEPA.

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

20 21 I.2.1.1 Environmental Reports Prepared by License Applicants 22 23 By regulation, the NRC requires applicants that request NRC licensing actions to consider 24 economic, technical, and other costs and benefits of the proposed action and its alternatives in 25 environmental reports (ER). The regulations at 10 CFR 51.45(c) state:

26 27 Except for an environmental report prepared at the early site permit stage, or an 28 environmental report prepared at the license renewal stage under 51.53(c), the analysis 29 in the environmental report should also include consideration of the economic, technical, 30 and other benefits and costs of the proposed action and its alternatives. Environmental 31 reports prepared at the license renewal stage under 51.53(c) need not discuss the 32 economic or technical benefits and costs of either the proposed action or alternatives, 33 except if these benefits and costs are either essential for a determination regarding the 34 inclusion of an alternative in the range of alternatives considered or relevant to 35 mitigation.

36 37 The NRC is responsible for the independent evaluation of all information used in a NEPA review 38 (see 10 CFR 51.41, Requirement to submit environmental information).

39 40 For reactor license renewal, 10 CFR 51.53(c)(3)(ii)(L) requires the applicant to consider the 41 costs and benefits of SAMAs in its ER if SAMAs were not previously considered in an EIS, a 42 related supplement, or an EA. Conversely, a license renewal applicant for a nuclear power 43 plant that has already conducted a SAMA analysis as part of an EIS, a supplement to an EIS, or 44 an EA, does not need to provide another SAMA analysis in the subsequent or second license 45 renewal (SLR) ER. Nevertheless, 10 CFR 51.53(c)(3)(iv) requires the applicants ER to include 46 any new and significant cost-benefit information of which the applicant is aware that may affect 47 a prior SAMA analysis. Guidance is provided in Nuclear Energy Institute (NEI) 17-04, Revision 48 1, Model SLR New and Significant Assessment Approach for SAMA, dated August 2019.

49 Under 10 CFR 51.45, Environmental report, 10 CFR 51.54, Environmental report 50

I-3 NUREG/BR-0058, Rev. 5, App. I, Rev. 0 manufacturing license; and 10 CFR 51.55, Environmental reportstandard design 1

certification, the NRC requires new reactor applicants to address the costs and benefits of 2

SAMDAs and the bases for not incorporating SAMDAs in the design.

3 4

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

6 The regulations at 10 CFR 51.71 require an EIS to include the consideration of the economic, 7

technical, and other benefits and costs of the proposed action and alternatives. The EIS 8

includes recommendations regarding the proposed action based on the information collected 9

and the independent analyses conducted. These recommendations are generally based on the 10 environmental effects of the proposed action, the consideration of reasonable alternatives, and 11 an assessment of the costs and benefits of the proposed action.

12 13 Some differences in requirements exist depending on application type. Under 10 CFR 51.75(b),

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

26 27 I.2.2 NRC Guidance 28 29 Regulatory Guide 4.2, Preparation of Environmental Reports for Nuclear Power Stations, and 30 NUREG-1555, Standard Review Plans for Environmental Reviews for Nuclear Power Plants:

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

36 37

NUREG/BR-0058, Rev. 5, App. I, Rev. 0 I-4 I.2.2.1 Regulatory Guide 4.2 - Preparation of Environmental Reports for Nuclear Power 1

Stations 2

3 In Regulatory Guide (RG) 4.2, the NRC provides general procedures to applicants for preparing 4

cost-benefit analyses for ERs for the construction or operation of new nuclear power plants in 5

accordance with 10 CFR Part 52. The environmental impacts of constructing and operating the 6

new nuclear power plant, including the costs and benefits of the proposed action, must be 7

assessed before the NRC can issue a combined license (COL), construction permit (CP), or 8

operating license (OL). Therefore, the NRC requires applicants to include cost-benefit 9

information in ERs to assist the agency in analyzing the costs and benefits of the proposed 10 action. Analysts should verify that the applicants are applying the guidance from the latest 11 version of RG 4.2, or that an acceptable alternative approach is justified.

12 13 The companion document to RG 4.2 is NUREG-1555, which describes the types of information 14 and the level of detail needed by the NRC to support the development of cost-benefit analyses 15 in EISs for COL, CP, and OL applications. Applicants are encouraged to confer with the NRC 16 as early as possible to avoid issues related to cost-benefit information in the ERs (see 17 10 CFR 51.40, Consultation with NRC staff).

18 19 I.2.2.2 NUREG-1555 - Standard Review Plans for Environmental Reviews for Nuclear 20 Power Plants: Environmental Standard Review Plan 21 22 The environmental standard review plans (ESRP) in NUREG-1555 consist of a series of 23 instructions for conducting environmental reviews and preparing EISs and EAs for new reactor 24 licensing actions. The use of these ESRPs provides for completeness and consistency of the 25 environmental review, including the cost-benefit analyses prepared for EISs and EAs. The 26 analyst should apply the guidance from the latest version of NUREG-1555.

27 28 After receiving a new reactor licensing application, the NRC performs an acceptance review to 29 determine whether the information (including cost-benefit information) in the ER is sufficient to 30 complete the NEPA review. Based on the NEPA review, the EIS and the cost-benefit analysis 31 present the NRC staffs recommendations on the proposed licensing action.

32 33 The following sections summarize the applicable ESRPs in NUREG-1555 that direct the 34 analysis, evaluation, and balancing of costs and benefits.

35 36 ESRP 10.4 Benefit-Cost Balance 37 38 In ESRP 10.4, the NRC provides guidance for identifying, characterizing, and gathering the 39 expected costs and benefits associated with the proposed project from other parts of the EIS.

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

44 45 ESRP 10.4.1 Benefits 46 47 In ESRP 10.4.1, the NRC describes the identification, evaluation, and tabulation of the benefits 48 resulting from the construction and operation of the proposed project. The analyst may rely on 49 an independent analysis of benefits by State or regional authorities, may review the applicants 50 analysis, or may prepare an independent assessment. If a review of the applicants analysis is 51

I-5 NUREG/BR-0058, Rev. 5, App. I, Rev. 0 conducted, the analyst must ensure that the applicants assumptions, data, and methods are 1

acceptable. The scope should include the nuclear power plants average annual 2

electrical-energy generation in kilowatt-hours, enhanced reliability of the electrical distribution 3

system, technical benefits such as development of technology, the quantities of other products 4

produced (e.g., steam used for commercial processes), and other benefits that have been 5

identified (e.g., increased regional productivity, tax revenues, or new or improved recreational 6

facilities). Benefits should be identified for the applicants proposed project and for any of the 7

NRC staffs identified alternatives to mitigate adverse impacts.

8 9

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

12 13 The benefits of plant construction and operation should be summarized in tabular form similar to 14 that shown in the benefits summary table in Chapter 10 of the EIS. Each benefit identified by 15 the analyst should be discussed in the text and presented in the table.

16 17 ESRP 10.4.2 Costs 18 19 In ESRP 10.4.2, the NRC describes the identification and evaluation of the internal and external 20 costs of construction and operation of the proposed project. The analyst may rely on any 21 reasonable independent analysis of costs by State or regional authorities or on the applicants 22 analysis. The analyst may also prepare an independent assessment. The analyst must ensure 23 that the applicants assumption, data, and methods are acceptable. The scope should include 24 (1) capital costs, fuel costs, operating and maintenance costs, decommissioning costs, and any 25 other identified internal costs; (2) the external costs of impacts (e.g., loss of cropland 26 productivity or loss of wildlife habitat) identified in previous environmental reviews; and (3) other 27 external costs that are not associated with an identified environmental impact (e.g., effects of 28 increased traffic, medical costs). Costs should be identified for the applicants proposed project 29 and for any of the NRC staffs identified alternatives to mitigate adverse impacts. The analysis 30 should rely primarily on quantitative estimates where possible.

31 32 At the early site permit stage, 10 CFR 51.75(b) states that the draft EIS must not include an 33 assessment of the economic, technical, or other benefits... unless these matters are 34 addressed in the early site permit environmental report.

35 36 The costs of plant construction and operation should be summarized in tabular form similar to 37 that shown in the costs summary table in Chapter 10 of the EIS. Each cost identified by the 38 analyst should be discussed in the text and presented in the table.

39 40 ESRP 8.4 Assessment of Need for Power 41 42 The need for power is a critical component of an EIS because it establishes a framework for the 43 evaluation of project benefits and for the geographic boundaries of the relevant electricity 44 market over which costs and benefits are distributed. The ESRP sections that assess the need 45 for power discuss the proposed project in the context of the larger network of transmission and 46 generation and the loads the system serves. This includes discussions on the electrical 47 demand and demand growth in the region and electrical power supply options.

48 49 The Commission reaffirmed the importance of the NRCs need for power analyses in its 50 response to a petition for rulemaking (NRC, 2002) and stated that the principal benefit of 51

NUREG/BR-0058, Rev. 5, App. I, Rev. 0 I-6 constructing and operating a power reactor is the generation of electric power. Consequently, 1

the need for a power analysis in the EIS serves to establish the benefits of the project under 2

NEPA. The analyst should note that the analysis does not need to demonstrate a service-area-3 wide capacity deficit that is equal to or greater than the capacity of the proposed project to 4

conclude that there is some need for power.

5 6

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

power.

8 9

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

14 15 I.2.2.3 NUREG-1748 - Environmental Review Guidance for Licensing Actions Associated 16 with Office of Nuclear Material Safety and Safeguards Programs 17 18 In NUREG-1748, the NRC provides general procedures for the environmental reviews of 19 nuclear materials uses conducted by the Office of Nuclear Material Safety and Safeguards 20 (NMSS). The costs and benefits with respect to nuclear materials licenses should not be limited 21 to a simple financial accounting of project costs for the proposed action and each alternative.

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

29

I-7 NUREG/BR-0058, Rev. 5, App. I, Rev. 0 I.3 ENVIRONMENTAL JUSTICE 1

2 Executive Order (EO) 12898, Federal Actions to Address Environmental Justice in Minority 3

Populations and Low-Income Populations, mandates that Federal agencies make 4

environmental justice part of their respective missions by addressing disproportionately high and 5

adverse human health or environmental effects of Federal programs, policies, and activities on 6

minority populations and low-income populations. In December 1997, the Presidents Council 7

on Environmental Quality issued guidelines, titled Environmental Justice Guidance under the 8

National Environmental Policy Act, on how to integrate environmental justice into the NEPA 9

process. Independent agencies, such as the NRC, are not bound by the terms of EO 12898 but 10 are, as stated in paragraph 6-604 of the order, requested to comply with the provisions of [the]

11 order.

12 13 I.3.1 The Commissions Policy Statement 14 15 On August 24, 2004, the Commission issued a Policy Statement on the Treatment of 16 Environmental Justice Matters in NRC Regulatory and Licensing Actions (69 FR 52040) which 17 states, The Commission is committed to the general goals set forth in EO 12898, and strives to 18 meet those goals as part of its NEPA review process. The Commissions policy statement 19 confirms that NEPA is the legal basis for analyzing environmental justice matters, including the 20 human health and environmental effects of NRC licensing and other regulatory actions on 21 minority or low-income communities. Both the Office of Nuclear Reactor Regulation (NRR) and 22 NMSS have established procedures that incorporate the Commissions policy statement on 23 environmental justice into the NEPA review process.

24 25 I.3.2 NRC Guidance 26 27 Staff in NRR and the Office of New Reactors use Office Instruction LIC-203, Procedural 28 Guidance for Preparing Categorical Exclusions, Environmental Assessments, and Considering 29 Environmental Issues, as guidance on how to incorporate environmental justice in the NEPA 30 review process. The office instruction is the basis for the environmental justice process used for 31 new reactor licensing as provided in NUREG-1555 and in NUREG-1555, Supplement 1, 32 Standard Review Plans for Environmental Reviews for Nuclear Power Plants, Supplement 1:

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

35 36 I.3.2.1 Guidance for Preparing Environmental Assessments for Reactors 37 38 Specifically, LIC-203 provides the basic framework for meeting the NRCs responsibility to 39 comply with 10 CFR Part 51. This document provides guidance for conducting environmental 40 justice reviews for all actions that require the preparation of an EIS (or a supplement thereto).

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

NUREG/BR-0058, Rev. 5, App. I, Rev. 0 I-8 impacts are identified, a FONSI may not be possible, and an EIS should be considered. The 1

LIC-203, Appendix D, Environmental Justice in NRR NEPA Documents, gives a more detailed 2

explanation of environmental justice and a flow chart characterizing the steps in an 3

environmental justice review.

4 5

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

7 In NUREG-1748, the NRC provides general procedures for the environmental justice review of 8

licensing actions regulated by the NRC. Specifically, the EIS should follow environmental 9

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

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

23 24 I.3.2.3 Procedures for Rulemaking Activities 25 26 The staff should address environmental justice in the preamble to each proposed and final rule 27 that requires an EIS, a supplement to an EIS, or a generic EIS or, if warranted by a special case 28 or circumstance, an EA and FONSI.

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

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

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

46

I-9 NUREG/BR-0058, Rev. 5, App. I, Rev. 0 When a rule that is under modification or development contains siting evaluation factors or 1

criteria for siting a new facility, the staff should consider including specific language in the rule or 2

supporting regulatory guidance to state that an environmental justice review will be performed 3

as part of the licensing process.

4 5

NUREG/BR-0058, Rev. 5, App. I, Rev. 0 I-10 I.4 SEVERE ACCIDENT MITIGATION ALTERNATIVES 1

2 The implementation of the NEPA requirements for certain nuclear reactor licensing reviews 3

involves an evaluation of the costs and benefits of SAMA and SAMDA, including offsite property 4

damage. Comparable analyses do not exist for the treatment of accidents and offsite 5

consequences for materials, waste, and fuel cycle facility licensing.

6 7

The SAMA analyses are a systematic search for potentially cost-beneficial enhancements to 8

further reduce nuclear power plant risk. A SAMA analysis evaluates additional features or 9

actions that would prevent or mitigate the consequences of severe accidents. The SAMA 10 analysis considers: (1) hardware modifications, procedure changes, and training program 11 improvements; (2) both prevention of core damage and mitigation of severe accident 12 consequences; and (3) the full scope of potential accidents (i.e., accidents initiated by internal or 13 external events). The scope of the analyses is the same for SAMAs and SAMDAs. The 14 SAMDAs generally focus on hardware modifications because new reactor licensing is based on 15 future reactor designs that might not have established procedures and training programs.

16 17 Current NRC policy and guidance developed after the 1989 Limerick Generating Station 18 (Limerick) court decision (Limerick Ecology Action v. NRC, 869 F.2d 719 (3rd Cir. 1989)) require 19 that EISs prepared at the OL stage and at the COL stage consider SAMAs that mitigate the 20 consequences of severe accidents. Consideration of SAMAs is required at the license renewal 21 stage for plants for which a site-specific SAMA has not been included in an EIS or supplemental 22 EIS. In addition, the NRC expects that a CP review would need to consider SAMAs; however, 23 special factors discussed below should be taken into account.

24 25 Commission paper SECY-91-229, Severe Accident Mitigation Design Alternatives for Certified 26 Standard Designs, dated July 31, 1991, identifies the design-related SAMAs or SAMDAs 27 required by 10 CFR 52.47(b)(2). The EA for each design certification rule issued under 28 10 CFR Part 52 considers SAMDAs. If a COL application references a certified design, the 29 design-related SAMDA review should focus on whether the site characteristics are within the 30 site parameters specified in the SAMDA evaluation. However, if a COL application references a 31 reactor design that is still undergoing certification review, the NRC expects the applicant to 32 provide a site-specific SAMDA analysis based on the known information of the selected design.

33 34 In NUREG-1555 for new reactor applications and NUREG-1555, Supplement 1 for license 35 renewal applications, the NRC provides guidance to the staff on how to review SAMA and 36 SAMDA analyses. NEI 05-01A, Severe Accident Mitigation Alternatives (SAMA) Analysis:

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

43 44 The nuclear industry is developing advanced nuclear reactors with reduced risk profiles that are 45 not based on the current light water reactor (LWR) technology and could operate at power 46 levels as low as a couple of megawatt electric to power levels equivalent to the current LWRs.

47 Given that the staff may have to assess SAMAs for reactor designs with much lower risk profiles 48 than current LWRs, the staff is evaluating the need for a different SAMA methodology. If a 49

I-11 NUREG/BR-0058, Rev. 5, App. I, Rev. 0 different SAMA methodology can be performed for advanced nuclear reactor designs, the staff 1

expects to develop separate supplementary SAMA guidance to address the expected unique 2

advanced nuclear reactor risk profiles.

3 4

I.4.1 Analysis Methodology 5

6 Both SAMA and SAMDA analyses follow the same methodology. The steps outlined below that 7

refer to SAMAs also apply to SAMDAs.

8 9

I.4.1.1 Identification and Characterization of Leading Contributors to Risk 10 11 The SAMA analysis begins with an offsite consequence analysis based on a plant-specific risk 12 model2 that provides accident frequency and source term information from the applicants final 13 safety analysis report (FSAR) Chapter 19, Probabilistic Risk Assessment. In practice, 14 maximum use is made of the plant-specific probabilistic risk assessment (PRA) models 15 (e.g., Level 1 and Level 2 PRAs) for characterizing the dominant contributors to risk and 16 identifying candidate SAMAs to address these contributors. The contribution of external events 17 is considered to the extent that it can be supported by available risk methods because external 18 events can affect whether a SAMA is cost beneficial (i.e., greater reduction of risk).

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

21 22 I.4.1.2 Identification of Candidate Severe Accident Mitigation Alternatives 23 24 The next step is to identify the potential SAMA candidates that prevent core damage and that 25 prevent significant releases from containment. Insights from the plant-specific risk model, 26 compilations of potentially cost-beneficial SAMAs from similar reactor designs, and 27 improvements to training and procedures can inform the selection of potential SAMA 28 candidates. For license renewal, NEI 05-01A, Section 5, SAMA Identification, provides 29 guidance for developing a list of SAMA candidates. Tables 13 and 14 of NEI 05-01A provide 30 standard lists of SAMA candidates for boiling-water reactors and pressurized-water reactors, 31 respectively.

32 33 In new reactor applications, Chapter 19, Probabilistic Risk Assessment, of the FSAR typically 34 discusses potential design improvements. These potential design improvements could be 35 derived based on PRA criteria through the relative risk ranking of systems, structures, and 36 components and human actions, including the Fussell-Vesely Importance (e.g., greater than 37 0.005), Risk Reduction Worth, or Risk Achievement Worth. Other PRA-identified SAMA 38 candidates could come from a review of dominant sequences or cutsets (e.g., the top 100 39 cutsets) for failures that an enhancement to the plant could address. Additionally, an expert 40 panel that is very familiar with the reactor design could serve as a source to identify SAMAs.

41 42 Other candidate SAMAs can be considered based on input from members of the public during 43 the scoping phase of the NEPA review, if appropriate for the licensing action (see 44 10 CFR 51.27(a)(4) for a description of the scoping process).

45 46 2

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

NUREG/BR-0058, Rev. 5, App. I, Rev. 0 I-12 I.4.1.3 Estimation of Risk Reduction and Implementation of Cost Estimates 1

2 With a listing of candidate SAMAs, an initial screening is performed to determine which SAMAs 3

are not cost beneficial and can be eliminated from further consideration. Section 6 of 4

NEI 05-01A, Phase I Analysis, lists screening criteria that may be applied: (1) not applicable 5

to the reactor design, (2) already implemented, (3) combined with another SAMA, (3) excessive 6

implementation cost (i.e., a dollar value of the SAMA should be given to justify elimination), and 7

(4) very low benefit. These screening criteria have been applied in most license renewal and 8

new reactor applications that require a SAMA.

9 10 For the SAMAs that remain, a rough implementation cost estimate (or cost of enhancement) is 11 developed for each SAMA (NEI, 2005). Cost estimates for hardware modifications can be 12 based on estimates from past studies performed for a similar plant or developed on a 13 plant-specific basis. These cost estimates do not include certain cost factors 14 (e.g., surveillance/maintenance, the cost of replacement power during implementation) and thus 15 tend to increase the number of potentially cost-beneficial SAMAs to provide for a full 16 consideration of alternatives. Typically, screening estimates are used for initial assessments 17 and are refined as appropriate if a SAMA is potentially cost beneficial. Hardware costs could 18 range from several hundred thousand to a few million dollars. Procedure changes could range 19 from several tens of thousands of dollars for simple changes to several hundred thousand 20 dollars for complex changes with analysis and operator training impacts.

21 22 I.4.1.4 Identification of Severe Accident Mitigation Alternatives That Are Potentially 23 Cost Beneficial 24 25 To identify SAMAs that may be cost beneficial, the estimate of the net value of each SAMA is 26 based on the maximum benefit that can be achieved by avoiding an accident using an 27 assumption that the SAMA could eliminate all risk of a severe accident. Namely, the net 28 present value of the SAMA is reached by comparing the maximum benefit to the cost of the 29 SAMA.

30 31 This portion of the SAMA methodology for the evaluation of the maximum benefit follows the 32 guidance of Section 4.6.1.2, Severe Accident Mitigation Design Alternatives, of NUREG/BR-33 0058. The analyst then assesses the appropriate attributes listed in Section 5.3, Quantification 34 of Attributes, of NUREG/BR-0058 as follows:

35 36 APE = present value of averted public exposure (dollars) (Section 5.3.2.1) 37 AOC = present value of averted offsite property damage costs (dollars) (Section 5.3.2.3) 38 AOE = present value of averted occupational exposure costs (dollars) (Section 5.3.2.5) 39 AOSC = present value of averted onsite costs (dollars), including cleanup, decontamination, 40 and long-term replacement power costs (Section 5.3.2.6) 41 42 The analyst then assesses the net present value of the SAMA by adding the four attributes 43 together and subtracting the cost of the enhancement (i.e., the implementation cost of the 44 SAMA) from this total.

45 46 Net Present Value = (APE + AOC + AOE + AOSC) - COE, 47

I-13 NUREG/BR-0058, Rev. 5, App. I, Rev. 0 1

where 2

3 COE = cost of enhancement (dollars) 4 5

If the net value is positive, the SAMA is potentially cost beneficial and may be considered for 6

additional screening. If the net value is negative, the SAMA is not cost beneficial and is 7

removed from further consideration.

8 9

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

12 13 I.4.1.5 Screening Analysis for Remaining Severe Accident Mitigation Alternatives 14 15 After identifying SAMAs that are potentially cost beneficial, the analyst should then perform a 16 more in-depth analysis of the SAMAs. This analysis may include a detailed (i.e., more realistic 17 and less bounding) evaluation of the potential benefits of the SAMA. Rather than assuming that 18 the SAMA eliminates all core damage frequency contributors, the analysis should include only 19 those sequences relevant to the SAMA, thus resulting in a maximum benefit according to the 20 fraction of risk that the SAMA actually can affect. It may also include a more detailed 21 development of the cost associated with the proposed modification, including engineering 22 support, training, hardware costs, and implementation costs.

23 24 Additionally, a sensitivity analysis is recommended to evaluate how changes in SAMA analysis 25 assumptions would affect the cost-benefit analysis. The NEI 05-01A, Section 8, Sensitivity 26 Analyses, provides several areas for this type of analysis, including plant modifications, 27 uncertainty, peer review findings or observations, evacuation speed, real discount rate, and 28 analysis period. However, additional sensitivity categories could be relevant depending on the 29 reactor design, bases for assumptions, the site being considered, and dollar per person-rem 30 conversion factor values.

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

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

37 38 For license renewals, the remaining SAMAs would be evaluated to determine whether any of 39 the potentially cost-beneficial SAMAs identified are subject to aging management such that they 40 would be within the scope of license renewal. This evaluation would consider whether any 41 structures, systems, and components associated with these SAMAs would perform their 42 intended functions without moving parts or without a change in configuration or properties and 43 would not be subject to replacement based on a qualified life or specified time period. If the 44 potentially cost-beneficial SAMAs do not relate to the adequate management of the effects of 45 aging during the period of extended operation, the licensee does not need to implement the 46 SAMAs as part of its license renewal in accordance with 10 CFR Part 54, Requirements for 47 Renewal of Operating Licenses for Nuclear Power Plants.

48 49

NUREG/BR-0058, Rev. 5, App. I, Rev. 0 I-14 For new reactor applications, PRAs have been an integral tool in the development of the reactor 1

design. Therefore, the overall severe accident risk may be significantly lower when compared 2

to the current operating reactors. As a result, generically identified SAMDAs (i.e., SAMDAs 3

previously identified for a class of reactors such as PWRs and BWRs) would likely not be 4

potentially cost beneficial at this point in the process.

5 6

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

8 Although the assessment process for SAMDAs is essentially the same as that for SAMAs, this 9

section provides guidance for the consideration of the unique aspects of new reactor SAMDA 10 reviews.

11 12 I.4.2.1 Adequacy of the Probabilistic Risk Assessment 13 14 The NRCs Policy Statement on the Use of Probabilistic Risk Assessment Methods in Nuclear 15 Regulatory Activities encourages greater use of this analysis technique to improve safety 16 decisionmaking and regulatory efficiency. The NRC expects new reactor applications under 17 10 CFR Part 52 to have a PRA with results and insights that address the full scope of 18 operations for internal events at full power, external events at full power, and events during 19 other operating modes (e.g., low power and shutdown). The relevant regulatory requirements 20 depend on the type of application (e.g., standard design certification or COL) and are discussed 21 in NUREG-0800, Standard Review Plan for the Review of Safety Analysis Reports for Nuclear 22 Power Plants: LWR Edition, Section 19.0, Probabilistic Risk Assessment and Severe Accident 23 Evaluation for New Reactors. In addition to this guidance, RG 1.200, An Approach for 24 Determining the Technical Adequacy of Probabilistic Risk Assessment Results for Risk-25 Informed Activities, describes acceptable methods that the new reactor applicant and the 26 analyst can apply to assess the technical information in, and adequacy of, the PRA. Although a 27 license renewal application may apply RG 1.174, An Approach for Using Probabilistic Risk 28 Assessment in Risk-Informed Decisions on Plant-Specific Changes to the Licensing Basis, the 29 analyst may determine that, for an existing operating reactors PRA, this less than full scope 30 PRA information is acceptable.

31 32 The results of this difference in the adequacy of the PRA presents a unique challenge to the 33 SAMDA review in that, with a more complete set of risk information, the scope of the offsite 34 consequence analysis may be greater for a new reactor SAMDA review than it would for a 35 license renewal SAMA review given comparable design specifications (i.e., reactor power) and 36 site conditions. The NRC expects new reactor applicants to develop a reasonable set of source 37 term releases that will be more expansive over a larger set of hazard groups, including internal 38 and external release categories for at-power and low-power shutdown modes of operation.

39 40 I.4.2.2 Considerations Regarding Sources of Site Information 41 42 A key difference between the SAMDA analyses provided in a standard design certification 43 review versus a COL application is the basis for the site information being applied to the offsite 44 consequence calculation that supports the SAMDA analysis. Because the standard design 45 certification review only assesses the design itself, the site information would likely be based on 46 a reference site. This could be accomplished either by applying information based on an 47 industry document such as the Electric Power Research Institutes (EPRI) Advanced Light 48 Water Reactor Utility Requirements Document, Volume III, Annex B, ALWR Reference Site, 49

I-15 NUREG/BR-0058, Rev. 5, App. I, Rev. 0 Revisions 5 and 6, or by obtaining the site information from a publicly available source.3 For all 1

other licensing actions that require a SAMA or SAMDA analysis, the site information applied is 2

specific to the location.

3 4

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

5 Therefore, to ensure that the submitted ER applied the best information, the staff should verify 6

that the applicant properly adjusted the relevant information to present values.

7 8

I.4.2.3 Construction Permits and Operating Licenses 9

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

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

24 25 For the subsequent OL, 10 CFR 51.53(b) states that, for the OL stage, each applicant for a 26 license to operate a production or utilization facility under 10 CFR 51.20 shall submit with its 27 application a Supplement to Applicants Environmental ReportOperating License Stage, 28 which will update the Applicants Environmental ReportConstruction Permit Stage. Unless 29 otherwise required by the Commission, the applicant for an OL for a nuclear power reactor 30 submits this report only in connection with the first licensing action authorizing full power 31 operation. In the report, the applicant discusses SAMAs or SAMDAs but only to the extent that 32 they differ from those discussed or reflect new information in addition to that discussed in the 33 final EIS prepared by the NRC in connection with the CP based on the completed nuclear power 34 plant.

35 36 I.4.3 Nuclear Material Licenses 37 38 The NUREG-1748 provides guidance on the review of a material licensing action to focus 39 environmental review documents (e.g., EAs and EISs) on the environmental impacts of the 40 proposed action and reasonable alternatives. Typically, the staff prepares a safety evaluation 41 report (SER) to evaluate and document the safety of the proposed action and compliance with 42 NRC regulations. The agency conducts the safety and environmental reviews in parallel.

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

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

NUREG/BR-0058, Rev. 5, App. I, Rev. 0 I-16 document has a different purpose. The NEPA document does not address accident scenarios; 1

instead, it addresses the environmental impacts that would result from an accident and, 2

therefore, depends on certain information from the SER. The SER addresses accident 3

scenarios (i.e., frequency, probability).

4 5

The applicants ER and the NRCs NEPA document (an EIS or EA) should list reasonably 6

foreseeable and credible accidents (e.g., design-basis events for licenses under 7

10 CFR Part 72, Licensing Requirements for the Independent Storage of Spent Nuclear Fuel, 8

High-Level Radioactive Waste, and Reactor-Related Greater Than Class C Waste, and 9

credible consequence events for licenses under 10 CFR Part 70, Domestic Licensing of 10 Special Nuclear Material) identified as having a potential for releases to the environment and 11 the analysis of offsite radiological doses from these accidents. However, the environmental 12 review document would not analyze beyond-design-basis events for 10 CFR Part 72 licenses 13 and their potential environmental impacts because these events are typically not considered 14 reasonably foreseeable. Thus, material applicants and licensees do not determine whether a 15 cost-beneficial design alternative could mitigate a severe accident.

16 17 The analyst should use existing guidance from the latest version of NUREG-1748 to address 18 the environmental effects of accidents.

19 20

I-17 NUREG/BR-0058, Rev. 5, App. I, Rev. 0 I.5 REFERENCES 1

2 42 U.S.C. 4332 et seq., National Environmental Policy Act of 1969, as amended. Available at 3

https://energy.gov/nepa/downloads/national-environmental-policy-act-1969.

4 5

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

Energy.

7 8

CFR, Environmental Protection Regulations for Domestic Licensing and Related Regulatory 9

Functions, Part 51, Chapter 1, Title 10, Energy.

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

13 14 CFR, Requirements for Renewal of Operating Licenses for Nuclear Power Plants, Part 54, 15 Chapter 1, Title 10, Energy.

16 17 CFR, Domestic Licensing of Special Nuclear Material, Part 70, Chapter 1, Title 10, Energy.

18 19 CFR, Licensing Requirements for the Independent Storage of Spent Nuclear Fuel, High-Level 20 Radioactive Waste, and Reactor-Related Greater Than Class C Waste, Part 72, Chapter 1, 21 Title 10, Energy.

22 23 Council on Environmental Quality (CEQ), Environmental Justice Guidance under the National 24 Environmental Policy Act, December 1997. Available at https://ceq.doe.gov/docs/ceq-25 regulations-and-guidance/regs/ej/justice.pdf.

26 27 EPRI, Advanced Light Water Reactor Utility Requirements Document, Volume III, Annex B, 28 ALWR Reference Site, Revisions 5 and 6, December 1993.

29 30 Limerick Ecology Action vs. NRC, 869 F.2d 719 (3rd Cir. 1989).

31 32 NEI, Severe Accident Mitigation Alternatives (SAMA) Analysis: Guidance Document, NEI 05-33 01A, November 2005. Agencywide Documents Access and Management System (ADAMS) 34 Accession No. ML060530203.

35 36 NEI, Model SLR New and Significant Assessment Approach for SAMA, NEI 17-04, Revision 1, 37 August 2019.

38 39 Office of the President, Executive Order 12898: Federal Actions to Address Environmental 40 Justice in Minority Populations and Low-Income Populations, 59 FR 7629, February 16, 1994.

41 42 NRC, Severe Accident Risks: An Assessment for Five U.S. Nuclear Power Plants, Final 43 Summary Report, NUREG-1150, December 1990. ADAMS Accession No. ML040140729.

44 45 NRC, Severe Accident Mitigation Design Alternatives for Certified Standard Designs, 46 SECY-91-229, July 31, 1991. ADAMS Accession No. ML003707922.

47 48 NRC, Policy Statement on the Use of Probabilistic Risk Assessment Methods in Nuclear 49 Regulatory Activities, 60 FR 42622, August 16, 1995.

50

NUREG/BR-0058, Rev. 5, App. I, Rev. 0 I-18 1

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

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

3 4

NRC, Denial of Petition for Rulemaking to Eliminate Review of Alternative Sites, Alternative 5

Energy Sources and Need for Power in Nuclear Power Reactor Siting and Licensing Reviews 6

(PRM-52-2), SECY-02-0175, September 27, 2002. ADAMS Accession No. ML022200469.

7 8

NRC, Environmental Review Guidance for Licensing Actions Associated with NMSS Programs, 9

Final Report NUREG-1748 (current version).

10 11 NRC, Policy Statement on the Treatment of Environmental Justice Matters in NRC Regulatory 12 and Licensing Actions, 69 FR 52040, August 24, 2004.

13 14 NRC, United States Nuclear Regulatory Commission Regulations Handbook, 15 NUREG/BR-0053 (current version).

16 17 NRC, Notice of Availability of the Final License Renewal Interim Staff Guidance 18 LR-ISG-2006-03: Staff Guidance for Preparing Severe Accident Mitigation Alternatives 19 Analyses, August 2, 2007. ADAMS Accession No. ML071640471.

20 21 NRC, An Approach for Determining the Technical Adequacy of Probabilistic Risk Assessment 22 Results for Risk-Informed Activities, RG 1.200 (current version).

23 24 NRC, An Approach for Using Probabilistic Risk Assessment in Risk-Informed Decisions on 25 Plant-Specific Changes to the Licensing Basis, RG 1.174 (current version).

26 27 NRC, State-of-the-Art Reactor Consequence Analyses (SOARCA) Report, NUREG-1935, 28 November 2012. ADAMS Accession Nos. ML12332A057 and ML12332A058.

29 30 NRC, Standard Review Plans for Environmental Reviews for Nuclear Power Plants, 31 Supplement 1: Operating License Renewal, Final Report, NUREG-1555, Supplement 1 32 (current version).

33 34 NRC, Procedural Guidance for Preparing Categorical Exclusions, Environmental Assessments, 35 and Considering Environmental Issues, Office of Nuclear Reactor Regulation Office Instruction 36 LIC-203 (current version).

37 38 NRC, Preparation of Environmental Reports for Nuclear Power Plant License Renewal 39 Applications, RG 4.2, Supplement 1 (current version).

40 41 NRC, Standard Review Plan for the Review of Safety Analysis Reports for Nuclear Power 42 Plants, Section 19.0, Probabilistic Risk Assessment and Severe Accident Evaluation for New 43 Reactors, NUREG-0800 (current version).

44 45 NRC, Proposed Updates of Licensing Policies, Rules, and Guidance for Future Reactor 46 Applications, SECY-15-0002, January 8, 2015 (ADAMS Accession No. ML13277A420 47 (package)).

48