ML030690391

Environmental Scoping Report - R. E. Ginna Nuclear Power Plant, Wayne County, New York, March 2003

ML030690391
Person / Time
Site:	Ginna
Issue date:	03/01/2003
From:	Robert Schaaf NRC/NRR/DRIP/RLEP
To:
schaaf R, NRR/DRIP/RLEP, 301-415-1312
References
-nr
Download: ML030690391 (26)

Text

Environmental Scoping Summary Report R.E. Ginna Nuclear Power Plant Wayne County, New York March 2003 Docket No. 50-244 U.S. Nuclear Regulatory Commission Rockville, Maryland

1 March 2003 R. E. Ginna Introduction 1

On August 1, 2002, the Nuclear Regulatory Commission (NRC) received, by letter dated 2

July 30, 2002, an application from the Rochester Gas and Electric Corporation (RG&E), filed 3

pursuant to Section 104b of the Atomic Energy Act of 1954, as amended, and 10 CFR part 54, 4

which would authorize the applicant to operate the R. E. Ginna Nuclear Power Plant (Ginna) for 5

an additional 20-year period. The current operating license for Ginna expires on September 18, 6

2009. Ginna is a pressurized water reactor designed by Westinghouse Electric Company and 7

is located in Wayne County, New York. As part of the application, RG&E submitted an 8

environmental report (ER) prepared in accordance with the requirements of 10 CFR Part 51.

9 10 CFR Part 51 contains the NRC requirements for implementing the National Environmental 10 Policy Act (NEPA) of 1969. Section 51.53 outlines requirements for preparation and submittal 11 of environmental reports to the NRC.

12 13 Section 51.53(c)(3) was based upon the findings documented in NUREG-1437, Generic 14 Environmental Impact Statement for License Renewal of Nuclear Power Plants, (GEIS). The 15 GEIS, in which the staff identified and evaluated the environmental impacts associated with 16 license renewal, was issued for public comment. The staff received input from Federal and 17 State agencies, public organizations, and private citizens. As a result of the assessments in the 18 GEIS, a number of impacts were determined to be generic to all nuclear power plants. These 19 were designated as Category 1 impacts. An applicant for license renewal may adopt the 20 conclusions contained in the GEIS for Category 1 impacts in the absence of new and significant 21 information that may cause the conclusions to fall outside those of the GEIS. Category 2 22 impacts are those impacts that have been determined to be plant-specific and are required to 23 be addressed in the applicants ER.

24 25 The Commission determined that the NRC does not have a role in energy planning decision-26 making for existing plants, which should be left to State regulators and utility officials.

27 Therefore, an applicant for license renewal need not provide an analysis of the need for power, 28 or the economic costs and economic benefits of the proposed action. Additionally, the 29 Commission determined that the ER should not include a discussion of any aspect of storage of 30 spent fuel for the facility. This determination was based on the Nuclear Waste Policy Act of 31 1982 and the Commissions Waste Confidence Rule, 10 CFR 51.23.

32 33 On October 10, 2002, the NRC published a Notice of Intent in the Federal Register (67 FR 34 63171), to notify the public of the NRCs intent to prepare a plant-specific supplement to the 35 GEIS to support the review of the license renewal application for the Ginna operating license.

36 The plant-specific supplement to the GEIS will be prepared in accordance with NEPA and 10 37 CFR Part 51. The NRC initiated the scoping process with the issuance of a Federal Register 38 Notice. The NRC invited the applicant; Federal, Tribal, State, and local government agencies; 39 local organizations; and individuals to participate in the scoping process by providing oral 40 comments at the scheduled public meetings and/or submitting written suggestions and 41 comments no later than December 11, 2002. The scoping process included two public scoping 42

Scoping Comment Report 2

R. E. Ginna March 2003 meetings, which were held at the Webster Public Library in Webster, New York on November 6, 1

2002. The NRC announced the meetings in local newspapers (Rochester Democrat and 2

Chronicle, Courier Gazette, Times of Wayne County, Wayne County Star, and Finger Lake 3

Times), issued press releases, and distributed flyers locally. Approximately 120 people attended 4

the meetings, including the NRC environmental review team, members of the public, 5

representatives from RG&E, State and local governments, and the press. Both sessions began 6

with NRC staff members providing a brief overview of the license renewal process and the 7

NEPA process. Following the NRCs prepared statements, the meetings were open for public 8

comments. Fifteen (15) commenters (two of whom spoke at both meetings) provided either 9

oral comments or written statements that were recorded and transcribed by a certified court 10 reporter. In addition to the comments provided during the public meetings, the NRC received 11 four comment letters. The afternoon and evening meeting transcripts (accession numbers 12 ML023530107 and ML023530120) and comment letters are available electronically for public 13 inspection in the NRC Public Document Room or from the Publicly Available Records (PARS) 14 component of NRCs document system (ADAMS). ADAMS is accessible from the NRC Web 15 site at http://www.nrc.gov/reading-rm.htm (the Public Electronic Reading Room).

16 17 The scoping process provides an opportunity for public participation to identify issues to be 18 addressed in the plant-specific supplement to the GEIS and highlight public concerns and 19 issues. The Notice of Intent to prepare an EIS identified the following objectives of the scoping 20 process:

21 22

Define the proposed action 23 24 Determine the scope of the supplement to the GEIS and identify significant issues to be 25 analyzed in depth 26 27 Identify and eliminate peripheral issues 28 29 Identify any environmental assessments and other environmental impact statements 30 being prepared that are related to the supplement to the GEIS 31 32 Identify other environmental review and consultation requirements 33 34 Indicate the schedule for preparation of the supplement to the GEIS 35 36 Identify any cooperating agencies 37 38 Describe how the supplement to the GEIS will be prepared 39 40 At the conclusion of the scoping period, the NRC staff and its contractor reviewed the 41

3 March 2003 R. E. Ginna transcripts and all written material received, and identified individual comments. All comments 1

and suggestions received orally during the scoping meetings or in writing were considered.

2 Each set of comments from a given commenter was given a unique alpha identifier 3

(Commenter ID letter), allowing each set of comments from a commenter to be traced back to 4

the transcript, letter, or email in which the comments were submitted. Several commenters 5

submitted comments through multiple sources (e.g., afternoon and evening scoping meetings).

6 Table 1 identifies the individuals providing comments and the Commenter ID letter associated 7

with each persons set(s) of comments. The individuals are listed in the order in which they 8

spoke at the public meeting, and random order for the comments received by letter or email.

9 10 Comments were consolidated and categorized according to the topic within the proposed 11 supplement to the GEIS or according to the general topic if outside the scope of the GEIS.

12 Comments with similar specific objectives were combined to capture the common essential 13 issues that had been raised in the source comments. Once comments were grouped according 14 to subject area, the staff and contractor determined the appropriate action for the comment.

15 The staff made a determination on each comment that it was one of the following:

16 17

a comment that was either related to support or opposition of license renewal in general 18 (or specifically to Ginna) or that makes a general statement about the licensing renewal 19 process. It may make only a general statement regarding Category 1 and/or Category 2 20 issues. In addition, it provides no new information and does not pertain to 10 CFR Part 21 54.

22 23 A comment about a Category 1 issue that 24 Provided new information that required evaluation during the review, or 25 Provided no new information 26 27 A comment about a Category 2 issue that 28 Provided information that required evaluation during the review, or 29 Provided no such information 30 31 A comment that raised an environmental issue that was not addressed in the GEIS, or 32 33 A comment regarding Alternatives to the proposed action 34 35 A comment regarding safety issues within the scope of 10 CFR Part 54, but out of the 36 scope of 10 CFR Part 51 37 38 39

Scoping Comment Report 4

R. E. Ginna March 2003 A comment outside the scope of license renewal (not related to 10 CFR Parts 51 or 54),

1 which include 2

A comment regarding emergency response and planning 3

A comment regarding the need for power 4

A comment regarding operational safety issues 5

A comment regarding safeguards and security 6

7 A comment that was actually a question and introduces no new information.

8 9

Each comment is summarized in the following pages. For reference, the unique identifier for 10 each comment (Commenter ID letter listed in Table 1 plus the comment number) is provided.

11 In those cases where no new information was provided by the commenter, no further evaluation 12 will be performed.

13 14 TABLE 1. Individuals Providing Comments During Scoping Comment Period 15 16 17 Commenter ID 18 Commenter Affiliation (If Stated)

Comment Source and ADAMS Accession Number A

19 Bernadette Anderson Afternoon Scoping Meeting(a)

B 20 Tim Judson Citizens Awareness Network Afternoon Scoping Meeting C

21 John Greenbaum Metro Justice Afternoon Scoping Meeting D

22 Andy Gutacker Afternoon Scoping Meeting E

23 Roland Micklem Lakeshore Environmental Action Afternoon Scoping Meeting F

24 Michael Havens Wayne Central School District Afternoon Scoping Meeting G

25 Bob Mecredy RG&E Afternoon Scoping Meeting H

26 Susan Gateley Lakeshore Environmental Action Afternoon Scoping Meeting I

27 Cathryn Thomas Town of Webster Afternoon Scoping Meeting J

28 Ron Fellows American Nuclear Society -

Ginna Plant Branch Afternoon Scoping Meeting K

29 Joel Van Schaffel Millwrights Local 1163 Afternoon Scoping Meeting L

30 Ron Behan Rochester Building and Construction Trades Council Afternoon Scoping Meeting M

31 Doctor Loomis Afternoon Scoping Meeting N

32 Charles Arnold Evening Scoping Meeting(b)

O 33 Dick Clark Town of Ontario Evening Scoping Meeting P

34 Bob Mecredy RG&E Evening Scoping Meeting Q

35 Ron Fellows American Nuclear Society-Ginna Plant Branch Evening Scoping Meeting R

36 Kimberly Merchant New York State Department of Environmental Conservation Comment Letter S

37 Kathy Mitchell Seneca Nation Comment Letter T

38 Tom Peaslee Comment Letter U

39 Frank Guelli Town of Walworth Comment Letter (a) The afternoon transcript can be found under accession number ML023530107.

40 (b) The evening transcript can be found under accession number ML023530120.

41 42

5 March 2003 R. E. Ginna The preparation of the plant-specific supplement to the GEIS (which is the SEIS) will take into 1

account all the relevant issues raised during the scoping process. The SEIS will address both 2

Category 1 and 2 issues, along with any new information identified as a result of scoping. The 3

SEIS will rely on conclusions supported by information in the GEIS for Category 1 issues, and 4

will include the analysis of Category 2 issues and any new and significant information. The 5

draft plant-specific supplement to the GEIS will be available for public comment. The comment 6

period will offer the next opportunity for the applicant, interested Federal, Tribal, State, and local 7

government agencies; local organizations; and members of the public to provide input to the 8

NRCs environmental review process. The comments received on the draft SEIS will be 9

considered in the preparation of the final SEIS. The final SEIS, along with the staffs Safety 10 Evaluation Report (SER), will provide much of the basis for the NRCs decision on the Ginna 11 license renewal.

12 13 The following pages summarize the comments and suggestions received as part of the scoping 14 process, and discuss their disposition. Parenthetical numbers after each comment refer to the 15 Commenter ID letter and the comment number. Comments can be tracked to the commenter 16 and the source document through the ID letter and comment number listed in Table 1.

17 Comments are grouped by category. The categories are as follows:

18 19

1. Comments Regarding License Renewal and its Processes 20

2. Comments in Support of License Renewal at R.E. Ginna Nuclear Power Plant 21

3. Comments in Opposition to License Renewal at R.E. Ginna Nuclear Power Plant 22

4. Comments Concerning Aquatic Ecology Issues 23

5. Comments Concerning Human Health 24

6. Comments Concerning Socioeconomic Issues 25

7. Comments Concerning Land Use Issues 26

8. Comments Concerning Uranium Fuel Cycle and Waste Management Issues 27

9. Comments Concerning Alternative Energy Sources 28

10. Comments Concerning Safety Issues Within the Scope of License Renewal 29

11. Comments Concerning Issues Outside the Scope of License Renewal: Emergency 30 Response and Preparedness, Need for Power, Operational Safety, and Safeguards and 31 Security 32

12. Request for Information 33 34 35 1.

Comments Regarding License Renewal and its Processes 36 37 Comment: But my other question is more in terms of the relicensing issue, and whether in 38 your understanding, or any of the NRC representatives understanding, if Ginna is relicensed, 39 whether that creates a larger window of opportunity for RG&E, or some other owner of Ginna, 40 to build a new reactor, without having to go through a site permitting process? Sure, it is just a 41 follow-up to my previous question. Because, you know, this is sort of a convoluted process that 42 I feel that we are going through with the relicensing, as well as other regulatory issues. But I 43

Scoping Comment Report 6

R. E. Ginna March 2003 guess one of the things Im wondering is, if Ginna were not to receive a license extension, then 1

it would have to shut down in 2009. And prior to that, you know, initiate a decommissioning and 2

site cleanup process, you know, through preparing plans for how they were going to do that, 3

that they would have to submit to NRC and begin preparing, you know, the reactor complex and 4

the site for that. And would that complicate, in any way, the submission of an early site permit 5

application to build a new reactor on site, or to begin that kind of preparation, has that ever 6

happened before, and what is the anticipation? (B-3) 7 8

Response: The comment is in regard to license renewal and its processes in general. The 9

Commission has established a process, by rule, for the environmental and safety reviews to be 10 conducted to review a license renewal application. Any attempt to locate a new reactor on the 11 existing site would require a new site permit as well as a new operating license completely 12 separate from license renewal. The comment did not provide significant, new information; 13 therefore, it will not be evaluated further.

14 15 Comment: And my question is, there are a number of nuclear power facilities on the New York 16 side of Lake Ontario. Canada has 12. When you do the environmental impact statements do 17 you then also take into consideration what is the impact of this conglomerate of plants that exist 18 in this area? (A-4) 19 20 Comment: And if Ginna were being considered, today, in this place, it might not be built under 21 that legislation. Lake Ontario is now home to 16 nuclear plants, a tritium recovery facility, a 22 uranium refinery, and at least two low-level radioactive waste dumps at Lewiston and Port 23 Hope. Most of these plants were built after Ginna. Ginna is one of the oldest plants on the 24 lake. That is a big cumulative impact on the lake. (H-3) 25 26 Comment: Also an environmental impact statement does, or should, consider what they call 27 secondary impacts. Which are something like you build a shopping mall, and then you attract 28 other businesses to set up alongside it, so that the initial traffic load from the mall becomes 29 greater 20 years down the road because of other things. And that may be some of what Tim is 30 driving at. By relicensing the plant you might encourage a future usage of that site, not 31 necessarily another nuclear plant, but some other industrial usage of this slightly contaminated 32 site that might not be compatible with the environment, or with the residential area. So Im 33 concerned about thinking about those secondary impacts, what this woman referred to, those 34 20 year out impacts. (H-12) 35 36 Response: The comments are in regard to license renewal and its processes in general. The 37 Commission has established a process, by rule, for the environmental and safety reviews to be 38 conducted to review a license renewal application. This process includes a review of 39 cumulative impacts. The comments did not provide significant, new information; therefore, they 40 will not be evaluated further.

41

7 March 2003 R. E. Ginna Comment: Another very big change since Ginna was built is deregulation. This is changing 1

the way these plants are operated. Ginna is coming up on 40 years now. So it does need 2

more care and monitoring. However, both the NRC and industry are trying to streamline 3

regulation and reduce costs. Pressures to reduce costs to industry, along with possibly a little 4

complacency, are what led to that hole in the reactor head at Davis-Besse. That could have 5

been a very serious accident on Lake Erie. One more change since the good old days of the 6

AEC, the regulatory Atomic Energy Commission of the 1960s. Today the NRC must function in 7

a political environment that stresses deregulation and less government spending. The NRC 8

has been like other agencies; it has been pressured to become more efficient. And for several 9

years it has endured reduced funding, and a shortage of skilled technical workers. In a speech 10 two years ago, I dont know what the situation is now, but two years ago the NRC chairman 11 said, despite efforts to hire new engineers, we have experienced a net loss of engineers over 12 the past five years, about 8 percent of their workforce, engineering workforce. We are losing 13 expertise, and along with it, valuable institutional knowledge. That is a direct quote from his 14 speech. The net effect of this, and failures to catch things like that Davis Besse hole in the 15 head, is that there is less trust of institutions like the NRC, than there was of the AEC, 40 years 16 ago. And I think we see a little bit of that in this room today, less trusting public. (H-8) 17 18 Response: The comment is in regard to license renewal and its processes in general. The 19 Commission has established a process, by rule, for the environmental and safety reviews to be 20 conducted to review a license renewal application. This includes an appropriate number of 21 NRC and contractor staff to sufficiently review the plant and prepare a supplemental 22 environmental impact statement specific to the plant. The comment did not provide significant, 23 new information; therefore, it will not be evaluated further.

24 25 Comment: The THPO (Tribal Historic Preservation Office) would indeed be a consulting party 26 to the renewal Ginna operating license. Under Section 106 of the NHPA (National Historic 27 Preservation Act), the THPO has 30 days to respond to a notification of an undertaking.

28 Unfortunately, your November 1 letter to us informed us of a public scoping meeting on 29 November 6 - i.e., 5 days notice. Future consultation with us should occur on a government-to-30 government basis. The Seneca Nation, being a sovereign entity, will not be classified as the 31 general public (see page 63172, bottom of left column of the Federal Register Notice of Intent).

32 (S-1) 33 34 Response: The NRC recognizes the Seneca Nation as a sovereign entity and will conduct 35 future consultation on a government-to-government basis. The comment did not provide 36 significant, new information; therefore, it will not be evaluated further.

37 38 2.

Comments in Support of License Renewal at R.E. Ginna Nuclear Power Plant 39 40 Comment: And let me say, with that, that provided that Energy East maintains the level of 41 support for the Ginna Nuclear Power Plant, that has been demonstrated by RG&E, I am in 42 support of relicensing the nuclear power plant. And I say that for three primary reasons. First of 43

Scoping Comment Report 8

R. E. Ginna March 2003 all, it has been an excellent corporate neighbor. Secondly it provides a substantial tax base for 1

the school district. And, thirdly, it provides a good standard of living for our families, and to my 2

students. (F-1) 3 4

Comment: The power plant has provided approximately 15.8 million dollars in revenue over 5

the last five years. It provided 3,182,172 dollars to the tax base just last year; 29.9 percent of 6

the local taxes that we collect come from Ginna. Consequently the loss of Ginna would be an 7

economic disaster for the school district, and taxpayers. (F-2) 8 9

Comment: Secondly, it has been a good corporate neighbor for us who live here in the Wayne 10 Central School District. And I live approximately eight miles from the nuclear power plant. (F-3) 11 12 Comment: I would also say that the plant has been a good neighbor. Mr. Biendenbach and 13 his people have allowed us to use their manor house for training; to house some of the 14 programs for our special needs children. When we have a need RG&E has always been there.

15 After 9/11 when all of us were very concerned about the safety of the plant, Rick Wyatts, Joe 16 Widay, others volunteered to come to the school and run programs for us. They have been a 17 good corporate neighbor to us. (F-5) 18 19 Comment: So, in conclusion, Ginna has been good for the Wayne Central School District, its 20 community, and its children. And as long as Energy East maintains the existing level of care, 21 we are supportive of its relicensing. (F-7) 22 23 Comment: We believe it is important to retain the option to operate the plant in the extended 24 period, thereby contributing to the overall power supply in the state and, importantly, to the 25 energy mix in the state. (G-5) (P-5) 26 27 Comment: Long-term is it a good idea to make the licensing, but if they are making their 28 decision, or a part of their decision is based on historically how has the facility run, and what is 29 the impression of people about it, my impression is that the facility is run in a very excellent 30 manner, and the people that we deal with to run it are very good, and caring, and professional 31 people. (I-4) 32 33 Comment: And, in closing, the American Nuclear Societys Ginna Plant Branch is obviously in 34 favor, and fully supportive of extending Ginnas license for 20 years. Thank you. (J-1) (Q-2) 35 36 Comment: theyve done a very good job protecting the workers there, along with the 37 surrounding areas. The people always seem to come home in good shape, they have learned 38 a lot; theyve been well educated while they were there. (K-1) 39 40

9 March 2003 R. E. Ginna Comment: Im here today to speak in favor for the renewal of the operating license for the 1

Ginna Nuclear Power Plant. And I can only say that I hope that the NRC goes through with the 2

licensing, it would mean a lot to this community. Thank you. (L-1) 3 4

Comment: And I think we all should realize, and appreciate what a well-rounded efficient plant 5

that RG&E has at Ginna. (L-3) 6 7

Comment: One of the concerns we talked about alternative sources of power. One of our 8

major concerns, after RG&E bought it, was not the nuclear side of things, but were they going 9

to put gigantic piles of coal about 600 or 800 feet behind our house. And then I found out, in 10 some of the early stuff, that it generated more radiation than did the plant. So we were 11 supporters at the start. And I did, for the town, a great deal of work regarding the safety of all 12 this. (M-1) 13 14 Comment: We believe the license should be renewed because the positive factors outweigh 15 the negative. (M-3) 16 17 Comment: In closing, Im 41 years old; I live 11 miles south of the plant. Im proud to be in 18 close proximity to such facility as Ginna. (Q-1) 19 20 Comment: I am writing you in support of RG&Es application for an operating license 21 extension. I believe its operating record is worthy of relicensing. (U-1) 22 23 Response: The comments were supportive of license renewal at Ginna and are general in 24 nature. The comments did not provide significant, new information; therefore, they will not be 25 evaluated further.

26 27 3.

Comments in Opposition to License Renewal at R.E. Ginna Nuclear Power Plant 28 29 Comment: And what actually, you know, what is afforded to us at this point is the fact that 30 Ginna, you know, if it doesnt get relicensed has seven years to plan for a shutdown. And while 31 as an anti-nuclear person it is hard for me to say, you know, keep it running for another seven 32 years. It affords us an opportunity to plan for the phase-out, and to plan for what is going to 33 happen in terms of jobs, and in terms of property taxes, and in terms of the economy. We 34 would all be a lot safer; there is no doubt about that. So why not take the chance that we have 35 now, rather than let R. E. Ginna go forward, and charge the repairs for the process of 36 relicensing this reactor, for any retrofits that it goes through, and deal honestly with the question 37 of whether RG&E is going to sell this plant. (B-6) 38 39 Comment: Ginna should not be relicensed. (H-11) 40 41 Comment: Nuclear power is one of the more regulated industries around. The solution is not 42 to deregulate it, or to extend it, or relicense it, but to eliminate it, to phase it out, like they are 43

Scoping Comment Report 10 R. E. Ginna March 2003 doing in Sweden and Germany. We could do it right here, we could start right here in Wayne 1

County. (H-14) 2 3

Comment: But with all due respect, to the NRC representatives here, I believe, and CAN 4

believes, that the NRCs review of this question of extending Ginnas operating life for another 5

20 years is really inadequate to protect the public health and safety. And that is because of 6

some of the questions that weve asked today, such as, you know, whether -- it is important 7

what the material condition of the reactor is at this point. You know, it sounds really scientific, 8

we got a lot of really scientific answers to that, how it is going to be dealt with? But, essentially, 9

the NRC supports relicensing of reactors as a policy. And the NRC, the Nuclear Regulatory 10 Commission appointed by the President, has given directives to the NRC staff to facilitate the 11 relicensing, and the construction of new reactors, and revised the rules on the relicensing 12 process to make that more possible, to make it easier. And so what we are stuck with is this 13 process in which it is really difficult for the public even to challenge the relicensing of a reactor 14 at this point. It is really difficult for the public to even intervene in this process, with all the 15 issues that are really relevant, like the questions that people have been raising today. So in that 16 sense, you know, it doesnt seem like this is the place to have our concerns addressed. And 17 there is a number of groups here who are going to be appealing to the Public Service 18 Commission in New York State to be involved in this process, and to oppose the relicensing.

19 And I know that when we are opposing the relicensing, essentially what we are saying is that 20 the reactor should shut down. And, you know, I live in Syracuse, I work in Oswego County, I 21 understand the terrible impact that people can conceive of when we talk about shutting down 22 plants in this region. (B-4) 23 24 Response: The comments are noted. The comments are opposed to license renewal at 25 Ginna and are general in nature. The comments did not provide significant, new information; 26 therefore, they will not be evaluated further.

27 28 4.

Comments Concerning Aquatic Ecology Issues 29 30 As stated in 10 CFR Part 51, Table B-1, Category 1 and 2 aquatic ecology issues include:

31 32 Category 1 33 34 Accumulation of contaminants in sediments or biota 35 Entrainment of phytoplankton and zooplankton 36 Cold shock 37 Thermal plume barrier to migrating fish 38 Distribution of aquatic organisms 39 Premature emergence of aquatic insects 40 Gas supersaturation (gas bubble disease) 41

11 March 2003 R. E. Ginna Low dissolved oxygen in the discharge 1

Losses from predation, parasitism, and disease among organisms exposed to sublethal stresses 2

Stimulation of nuisance organisms 3

4 Category 2 5

6 Entrainment of fish and shellfish in early life stages 7

Impingement of fish and shellfish 8

Heat shock 9

10 Comment: Now, how do you determine whether or not the amount of radiation that you 11 release into the lake, you obviously know what it is, how can you determine exactly what impact 12 it is going to have on the ecology of the lake, given the subtleties of the changes, and is it ever 13 considered that probably a lot of the deterioration of the lake environment -- Im talking about 14 now only of the internal motors, Im not talking about the air, or anything of that. The 15 deterioration of the lake environment may be due, partially of course, to nuclear plants, but also 16 to all the other discharges. And I dont see how you can make that kind of adequate evaluation.

17 Okay, so we have nuclear plants, and we have a lot of other things. I dont quite see how you 18 can get an adequate environmental impact statement on -- without really taking the whole 19 framework of the ecology there. (E-1) 20 21 Comment: I will just say one more thing, and then I will shut up. There used to be a species of 22 snail that was very prominent on the shores of Lake Ontario. And in my more studious days I 23 remembered the scientific name. I dont any more. All I know is that once it did exist, and now it 24 doesnt. (E-2) 25 26 Comment: Staff have determined that the existing entrainment study (conducted in 1977) is 27 out of date and should be updated as part of the application for NRC license extension of the 28 Ginna facility. The initial study was conducted to meet the requirements of the 401 Water 29 Quality Certification issued by the Department in 1974. The existing data is more than twenty 30 years old and Lake Ontario conditions have changed considerably in this time period - including 31 changes in populations of zebra and quagga mussels (Dreissena spp.), alewives, gobies, 32 smallmouth bass, climate, etc. In addition, the 1977 study was for a very limited period of the 33 year. More recent entrainment studies required by the Department have included studies over 34 longer periods of time, some of which have demonstrated entrainment impacts at Lake Ontario 35 cooling water intakes. Therefore, an updated study is recommended in order for the 36 Department to evaluate the impacts of the facility due to entrainment. Subsequently, the 37 Department has incorporated an entrainment study into the Draft State Pollutant Discharge 38 Elimination System (SPDES) Permit. RG&E has commented on the draft SPDES and the 39 Department has incorporated their comments. The draft SPDES permit is attached. The 40 requirement to conduct an updated entrainment study will also be included as a condition of the 41 new 401 Water Quality Certification. We recommend that the SEIS include a brief summary on 42

Scoping Comment Report 12 R. E. Ginna March 2003 the 1977 entrainment study results and the proposal to conduct an updated study of in-plant 1

entrainment. (R-1) 2 3

Comment: We recommend that the SEIS include a brief summary on impingement report 4

results and the commitment of RG&E to continue to replace older screens. (R-2) 5 6

Comment: Department staff identified the potential for increased fish mortality due to the 7

return of the impinged fish to the discharge canal, which contains elevated temperatures from 8

the cooling water effluent. RG&E included a brief discussion on this issue in the Environmental 9

Report. Staff did not have enough information from this discussion to determine whether the 10 elevated temperatures in the discharge canal result in additional fish mortality. On Monday, 11 December 9, 2002, RG&E provided staff with a copy of the 316(a) Demonstration and 12 Supplement (March 1977) to see if the report addresses the Departments concerns. Staff 13 have not had the opportunity to review the report, however, they will be reviewing it over the 14 next few weeks. We will continue to discuss the issue with RG&E and NRC on this issue.

15 Depending on the information provided in the 316(a) report, we may either recommend further 16 study, recommend an extension of the impinged fish return, or conclude that the concerns have 17 been addressed. In the interim, we recommend that the SEIS include a discussion regarding 18 Heat Shock. (R-3) 19 20 Response: The comments refer to the aquatic ecology near Ginna. These specific comments 21 as well as other aquatic ecology issues will be discussed in Chapter 2 and Chapter 4 of the 22 DSEIS.

23 24 5.

Comments Concerning Human Health 25 26 As stated in 10 CFR Part 51, Table B-1, Category 1 and 2 human health issues include:

27 28 Category 1 29 30 Microbiological organisms (occupational health) 31 Noise 32 Radiation exposures to public (license renewal) 33 Occupational radiation exposures (license renewal) 34 35 Category 2 36 37 Microbiological organisms (public health)(plants using lakes or canals, or cooling towers or 38 cooling ponds that discharge to a small river) 39 Electromagnetic fields, acute effects (electric shock) 40 41

13 March 2003 R. E. Ginna Comment: All of these plants, when they are operating, all of these facilities, release some 1

radioactivity. Some of it has a very short half-life of days or weeks, some of it, like tritium, has a 2

longer half-life of 12 years, some is very long-lived. That brings me to point number two. When 3

the plant was new, we did not have 40 years of radiation being released. Radiation exposure 4

has cumulative health effects. That is why most skin cancers show up later in life. As power 5

plants operate they expose the population, and the environment, to an ongoing burden of 6

exposure. And just as an aside to this, outside of scoping, many scientists do not accept 7

threshold dose and hormesis as valid, no matter what the HPs (health physicist) say. So the 8

longer these plants operate basically the more dose, cumulative, the population receives.

9 Population around Ginna, number three, is much higher than it was when the plant was built.

10 This is no longer a rural area; it is now a suburban area. (H-5) 11 12 Response: The comment is noted. Radiation exposure to the public and workers was 13 evaluated in the GEIS and determined to be a Category 1 issue. The NRCs regulatory limits 14 for radiological protection are set to protect workers and the public from the harmful health 15 effects of radiation on humans. The limits were based on the recommendations of standards-16 setting organizations. Radiation standards reflect extensive scientific study by national and 17 international organizations (International Commission on Radiological Protection [ICRP],

18 National Council on Radiation Protection and Measurements, and National Academy of 19 Sciences) and are conservative to ensure that the public and workers at nuclear power plants 20 are protected. The radiation exposure standards are presented in 10 CFR Part 20, Standards 21 for Protection Against Radiation, and are based on the recommendations in ICRP 26 and 30.

22 23 Numerous scientifically designed, peer-reviewed studies of personnel exposed to occupational 24 levels of radiation (versus life-threatening accident doses or medical therapeutic levels) have 25 shown minimal effect on human health, and any effect was from exposures well above the 26 exposure levels of the typical member of the public from normal operation of a nuclear power 27 plant.

28 29 The comment provides no new information, and does not pertain to the scope of license 30 renewal as set forth in 10 CFR Parts 51 and 54. Therefore, it will not be evaluated further.

31 32 6.

Comments Concerning Socioeconomic Issues 33 34 As stated in 10 CFR Part 51, Table B-1, Category 1 and 2 socioeconomic issues include:

35 36 Category 1 37 38 Public services: public safety, social services, and tourism and recreation 39 Public services, education (license renewal term) 40 Aesthetics impacts (refurbishment) 41 Aesthetics impacts (license renewal) 42 Aesthetics impacts of transmission lines (license renewal term) 43

Scoping Comment Report 14 R. E. Ginna March 2003 1

Category 2 2

3 Housing Impacts 4

Public services: public utilities 5

Public services, education (refurbishment) 6 Offsite land use (refurbishment) 7 Offsite land use (license renewal term) 8 Public services, transportation 9

Historic and archaeological resources 10 11 Comment: Thirdly, it has to do with the standard of living for my children. Ginna provides 12 approximately 500 RG&E jobs at its plant. In addition there are about 300 related jobs through 13 private contractors. Now, most of those people live in my school district, and they are parents of 14 my schoolchildren. My children live in decent homes, and have middle class values, and middle 15 class opportunities because of Ginna. Because of this we believe we can offer the best of both 16 worlds. We live in a pleasant rural community, but we have the benefits of a suburban type 17 school district. (F-6) 18 19 Comment: But beyond that our employees give back to the community in a variety of ways.

20 They serve on school boards, and town boards, as Scout leaders and sports coaches, they 21 support day care centers, and senior centers. They serve on ski patrols, and they train guide 22 dogs. Our employees raised money to donate a defibrillator to the Ontario Volunteer 23 Ambulance Service. We partner with the Wayne Central School District by providing them with 24 the space for their Eagles Ventures program, a program for those students who can benefit 25 from an alternative educational program, and setting. We continue to participate, on an annual 26 basis, in the science and exploration days of the St. John Fisher College, contributing to interest 27 in science on the part of the young people in the community, and we participate in the Annual 28 Day of Caring, among others. (G-8) (P-7) 29 30 Comment: It is used by more people every year, as a water source. I understand Newark may 31 be expanding the water district that will now tap into Lake Ontario water. I could be wrong, but I 32 do know that more and more municipalities are depending on Lake Ontario water. (H-4) 33 34 Comment: But a lot of things, talking about the jobs, and talking about the economic impact. I 35 just cant imagine taking a facility with the assessed value that that plant has out of a town just 36 like Webster, and what the impact would be. I mean, we could probably sit down and even 37 crunch numbers, but it would be significant. And it would be even more significant, would be 38 my guess, from my -- what I see as a relative relationship between what the town of Ontario is 39 like, and what the town of Webster is like. So certainly you are going to have an impact there 40 with that reduced assessed value should that not have a plant, or some facility there. And, of 41

15 March 2003 R. E. Ginna course, the job impact too. And I dont think we can really minimize it, in the economy these 1

days. The jobs, I know a lot of people right here in Webster, and in the surrounding area, do 2

work, rely on their jobs at the plant. So there certainly are the economic factors that are a 3

certainty would be negative. (I-1) 4 5

Comment: The reason is very simple for us; it is jobs for our members who live in this 6

community. Since the plant was built the Rochester Building Trades have been involved with 7

the building of the plant, and supplementing the RG&E personnel when it comes to maintaining 8

this plant. During shutdowns at the plant RG&E has always made sure that subcontractors have 9

hired local craftsmen to do their work. This has provided good paying, safe jobs for the people 10 that live in this community. (L-2) 11 12 Comment: Ginna provides jobs for our local residents. RG&E, now Energy East, is a 13 significant contributor to the tax base in the town of Ontario. This has enabled Ontario to 14 maintain a reasonable tax rate, and we hope this continues. RG&E has been a good neighbor.

15 They have been sensitive to the immediate neighborhood by keeping the rural setting of 16 orchards and acres of green space. (M-5) 17 18 Comment: In the past there has been a problem in establishing an assessed value of Ginna 19 for local property tax purposes. Although this is a local and state issue, the relationship 20 between Energy East and the town of Ontario is a key factor in establishing a fair assessed 21 value. Although the ultimate assessed value of the property lies with the local assessor, it is 22 hoped that the good relationship with the town established by RG&E will continue. Energy East, 23 albeit a new arrival, has yet to establish its credentials as a good neighbor, with commitment to 24 the health and welfare of Ontario, and the surrounding area. (M-8) 25 26 Comment: This past year the plant actually paid 30 percent of the tax bill. This revenue has 27 been very useful to the town in terms of developing the town, and also holding down the tax 28 rate. The 15 towns in Wayne County, Ontario has the lowest tax rate. I hope that with the 29 continued presence of the plant, it will continue to support a significant portion of our tax levy.

30 Or in lieu of that, the negotiations, some kind of a pilot agreement between the town and 31 RG&E, and/or the county and the school district, and RG&E. (O-6) 32 33 Comment: It is a responsive neighbor to my town and county. The plant is a substantial 34 taxpayer in my county and provides several hundred jobs. (U-3) 35 36 Response: The comments are noted. Socioeconomic issues specific to the plant are 37 Category 2 issues and will be addressed in Chapter 4 of the DSEIS. The comments did not 38 provide significant, new information; therefore, they will not be evaluated further.

39 40 Comment: My major beef was what I call light pollution. And on cloudy nights, particularly in 41 the winter, the snow is orange, but it hardly has to do with the safety. (M-9) 42 43

Scoping Comment Report 16 R. E. Ginna March 2003 Response: The comment is noted. Socioeconomic issues related to aesthetic impacts of the 1

plant during the license renewal term are Category 1 issues and were addressed in the GEIS.

2 The comments did not provide significant, new information; therefore, they will not be evaluated 3

further.

4 5

Comment: Although the State Historic Preservation Office has deemed no effect for the 6

undertaking, the Seneca Nation THPO has concerns with the uncertainty of ground disturbing 7

activities related to the project. The location and the history of the area surrounding Ginna are 8

highly sensitive. The Seneca Nation THPO would like to be consulted, in the earliest planning 9

stages, on any ground disturbing activities that may occur. (S-4) 10 11 Response: The comment refers to Historic and Archaeological resources near Ginna. This 12 comment will be addressed in Chapter 4 of the DSEIS.

13 14 Comment: The following text is suggested as a replacement to the first sentence of the 15 second paragraph of 2.12.1 on page 2-41: "The Monroe County Water Authority (MCWA),

16 which can produce 145 million gallons of treated water per day (mgd), was created by an act of 17 the New York State Legislature in 1950 and its legislation has been amended several times to 18 allow it to serve areas beyond Monroe County. Today the MCWA is a metropolitan regional 19 water purveyor, providing retail water service to most of Monroe County, several communities in 20 Genesee County and some small portions of Livingston and Ontario Counties. It exchanges 21 water with the Town of Ontario, Wayne County, provides wholesale water service to the Wayne 22 County Water and Sewer Authority (WCW&SA), the Town and Village of Victor, Ontario 23 County, three communities in Genesee County, and four adjoining communities in Orleans 24 County."(T-1) 25 26 Response: The comment refers to the water use near Ginna. Water use will be discussed in 27 Chapter 4 of the DSEIS. The comment is editorial in nature and will be considered in writing 28 this section of the DSEIS. Although the comment will be considered editorially, it provides no 29 significant, new information to the environmental review of Ginna; therefore, the comment will 30 not be evaluated further in that context.

31 32 7.

Comments Concerning Land Use Issues 33 34 As stated in 10 CFR Part 51, Table B-1, Category 1 land use issues include:

35 36 Onsite land use 37 Power line right of way 38 39 Comment: Department staff requested that RG&E provide an evaluation of the on-going 40 coastal erosion on-site and at neighboring properties to the Environmental Report. A brief 41

17 March 2003 R. E. Ginna discussion was provided. Department staff have concerns about the ongoing coastal erosion 1

on both sides of the shoreline protection. Subsequently, we have added a condition to the 2

recent Article 34 Coastal Erosion Control Permit to RG&E, to require a survey of the existing 3

shoreline.

4 5

We recommend that the ongoing coastal erosion issues be addressed in the SEIS. The survey 6

should be prepared in time for inclusion into the SEIS. We recommend that the federal NEPA 7

process identify whether any additional shoreline protection is required to protect the facility 8

over the renewal permit term. (R-5) 9 10 Response: The comment refers to land use issues near Ginna. This issue will be addressed 11 in Chapter 2 and Chapter 4 of the SEIS.

12 13 8.

Comments Concerning Uranium Fuel Cycle and Waste Management Issues 14 15 As stated in 10 CFR Part 51, Table B-1, Category 1 uranium fuel cycle and waste management 16 issues include:

17 18 Offsite radiological impacts (individual effects from other than the disposal of spent fuel and 19 high level waste) 20 Offsite radiological impacts (collective effects) 21 Offsite radiological impacts (spent fuel and high level waste disposal) 22 Nonradiological impacts of the uranium fuel cycle 23 Low level waste storage and disposal 24 Mixed waste storage and disposal 25 On-site spent fuel 26 Nonradiological waste 27 Transportation 28 29 Comment: If plans go as scheduled Yucca Mountain will then open up, as a storage facility, 30 and the waste will be trucked down 590, which is within two miles of my house, which is why I 31 have my potassium iodide. (C-1) 32 33 Comment: We touched on transporting nuclear waste, and also the containment chamber 34 safety requirements. What Im trying to say here is that back in the 80s we had a way of 35 looking, had development money to work for isotope separation. Which says we can take these 36 rods and like a battery, make them over, and over again, maybe nine times on the contract, but 37 actually figure we could probably get about 20 uses out of them. Which means the storage 38 goes down, and you have to have them on site. You can keep reusing them, and recharging 39 them. Did that whole science fall apart, or what? It was funded by -- I was working on that in 40 Los Alamos, and also Lawrence Livermore had contracts for that. And it looked like it had great 41 hope. Did that ever turn out to be viable? (D-1) 42 43

Scoping Comment Report 18 R. E. Ginna March 2003 Comment: And I dont know a lot of statistics, I cant quote a lot of this, but my big concern is 1

what happens to the waste from all of the thousands of nuclear power plants around the 2

country, that we keep accumulating the waste, and keep piling it up, and keep stockpiling it with 3

half-life of thousands of years, without any concern for what is going to happen to the people in 4

the future that will have to deal with it. (E-3) 5 6

Comment: When the plant was built there was no spent fuel on the site. It was supposed to 7

be removed. Politics and logistics are leading other nukes to use dry cask storage on-site. Will 8

this plant, how long will it be there, what about security for it? (H-7) 9 10 Comment: Secondary is what happens to the waste products. We were assured, by the 11 Federal government, I dont recall it was -- I believe it was the AEC at the time that this material 12 would be trucked away. And indeed, for a while, I believe it did go to West Valley, until its 13 closure. (M-2) 14 15 Comment: When Ginna started this operation, in 1970, the spent nuclear waste was trucked 16 out of this area to West Valley. This was changed several years ago and the waste is now 17 stored on-site. We believe that the local citizens should know when this spent fuel will be 18 removed from the present site. The answer to this issue should be part of the permitting 19 process. The Federal government has the responsibility for this, and has committed billions of 20 dollars to the proper storage of spent nuclear fuel. When will this happen? (M-7) 21 22 Comment: Also Im very interested in whether or not the environment has been taken into 23 account in terms of what happens to exhausted fuel. (N-1) 24 25 Comment: Although the Department does not have concerns regarding state regulated 26 hazardous waste storage, staff recommend that the future handling of the spent fuel inventory 27 and containment be addressed in the SEIS. (R-4) 28 29 Comment: The Environmental Impact Statement should analyze the ability of the plant to store 30 its spent nuclear fuel on plant property. The Environmental Impact Statement should analyze 31 the risks of transporting the spent nuclear fuel to the federal repository. This analysis should 32 include potential truck routes and rail routes, and depending on the routes, should be 33 coordinated with the Seneca Nation regarding the impacts to cultural resources along potential 34 transportation corridors. (S-3) 35 36 Response: Onsite storage and offsite disposal of spent nuclear fuel are Category 1 issues.

37 The safety and environmental effects of long-term storage of spent fuel onsite has been 38 evaluated by the NRC and, as set forth in the Waste Confidence Rule, the NRC generically 39 determined that such storage could be accomplished without significant environmental impact.

40 In the Waste Confidence Rule, the Commission determined that spent fuel can be stored onsite 41

19 March 2003 R. E. Ginna for at least 30 years beyond the licensed operating life, which may include the term of a 1

renewed license. At or before the end of that period, the fuel would be moved to a permanent 2

repository. The GEIS is based upon the assumption that storage of the spent fuel onsite is not 3

permanent. The plant-specific supplement to the GEIS regarding license renewal for Ginna will 4

be prepared based on the same assumption. The comments did not provide significant, new 5

information; therefore, they will not be evaluated further.

6 7

9.

Comments Concerning Alternative Energy Sources 8

9 Comment: And I dont understand why we are taking this risk. I dont understand why we are 10 not talking about wind generation on Lake Ontario. I just -- I think we need to look at the 11 alternatives. We are subsidizing the nuclear industry. Bushs energy plan calls for a 2.9 billion 12 dollar subsidy to nuclear industry, and the solar industrys subsidy would be enough to build 13 about two miles of federal interstate. So it seems like we need to look at the alternatives. And 14 Im not, myself, and the hundreds of members of Metro Justice, are not willing to take the risk 15 involved. (C-3) 16 17 Comment: Virtually every new power plant in New York depends on natural gas as the fuel of 18 choice. And as we have learned, in the past several years, the price of natural gas can 19 fluctuate greatly. This means that the price of electricity from gas fired power plants, would also 20 correspondingly fluctuate. To further complicate matters, even for those new plants receiving 21 siting approval, plant developers are finding it difficult, to impossible, to obtain financing. The 22 New York state power plant siting law is scheduled to expire at the end of this year. And a 23 number of older plants may need substantial new investment, if it is available, to meet new 24 environmental standards. (G-7) 25 26 Comment: And today there are more efficient, cleaner, and safer ways to make electricity.

27 (H-2) 28 29 Comment: Finally, the world of energy production has changed since 1960. We really dont 30 need nuclear plants any more. There are cleaner, safer ways to produce power. Denmark now 31 gets about ten percent of its power from wind. Their goal is half by 2030.California just passed 32 a renewable energy requirement of 20 percent in 20 years. We could do this in New York.

33 There have also been huge improvements in cogeneration technology, which is very much 34 more efficient than the large centralized plants. I would just add, I scribbled this down during the 35 meeting, and then it was brought up by someone else, that a good environmental impact 36 statement does consider alternatives. Im glad to hear that they will be considering alternative 37 ways of producing electricity. (H-10) 38 39 Comment: And as far as that tax base concern there could be other things, perhaps even 40 another generating facility, that would be safer and cleaner, that could pick up some of that 41 economic and tax concern, and it could even enhance the areas economic activity. (H-15) 42 43

Scoping Comment Report 20 R. E. Ginna March 2003 Comment: And you heard about, a couple of years ago, how terrible it was to live out in 1

California, and be a resident, and try to run a business out there with the rolling blackouts, or 2

brownouts, or whatever they were having, and we have not had any of those types of 3

experiences, at least in this part of New York state, and not that Im very widely aware of, 4

throughout our state. And to think that we would have to find something to replace that. And if 5

we were not to relicense a lot of these facilities around the state, and the country, we would 6

have to find a whole lot of things to replace a lot of that energy that is being created, that is just 7

another side of what is to be looked at. (I-3) 8 9

Response: The comments are noted. The GEIS included an extensive discussion of 10 alternative energy sources. Environmental impacts associated with various reasonable 11 alternatives to renewal of the operating licenses for Ginna will be discussed in Chapter 8 of the 12 DSEIS. The comments did not provide significant, new information; therefore, they will not be 13 evaluated further.

14 15

10. Comments Concerning Safety Issues Within the Scope of License Renewal 16 17 Comment: And I wasnt quite clear on how you are going to evaluate, as part of the renewal 18 process, the long-term degradation issues that are very prominent in nuclear power plants 19 across the country, Ohio being one, Virginia another one. The cracks and the various issues 20 that have surfaced and have caused great concerns in a number of communities across the 21 country, how do you propose to make the public aware of the process that you are going to be 22 using in evaluating degradation? (A-1) 23 24 Comment: That is, obviously fine, because that is part of the day-to-day inspection. Im talking 25 about a 20 year out in the future evaluation by the NRC, how are you going to go about 26 evaluating long-term degradation on that basis? (A-2) 27 28 Comment: There has to be, in my view, if you are extending a plant that has an age of 30 plus 29 years, another 20 years, if you are giving approval for that, there has to be something concrete, 30 in my view, that has to be given to the public, that estimates the degradation factors that this 31 plant will experience, over time, and gives the public some comfort that these aging plants that 32 many, many people feel should be shut down yesterday, are actually able to stay online safely 33 for another 20 years. (A-3) 34 35 Comment: Im with the Citizens Awareness Network. And just for claritys sake, I wanted to 36 sort of test this. It seems like the answer to this womans question is that, no, the NRC isnt, as 37 part of the relicensing process, going to do a systemic review of the aging and degradation of 38 the reactor. (B-1) 39 40

21 March 2003 R. E. Ginna Comment: I understand that. I mean, what Im saying is, you know, it seemed like the 1

question was whether as part of reevaluating the relicensing application, whether NRC does, 2

you know, an actual material condition inspection review, to determine whether this reactor 3

could safely operate for another 20 years. And didnt this used to be included as part of the 4

relicensing process? And there were certain reactors that were preparing their applications that 5

determined that the reactor was already too degraded, like Yankee Rowe? (B-2) 6 7

Comment: And it is instructive to talk about the reactor vessel head, in terms of inspections 8

and replacements. In the early 1990s, based on French experience, we began to perform 9

additional inspections, visual inspections, on our reactor vessel head. In 1999 we took the 10 opportunity, with our extended ten-year end service inspection to do detailed, non-destructive 11 examinations, and visual inspections, of our vessel head. In each of those cases we saw no 12 degradation, no defects. We performed additional inspections, both non-destructive 13 examinations, and visual inspections, in our most recent refueling outage, in 2002. And, again, 14 saw no degradation, and no defects. Nevertheless, looking to the future, even just to 2009, we 15 reached the conclusion to replace that reactor vessel head to provide us an economic benefit, 16 and to give us additional margin and assurance. That vessel head will be replaced in the fall of 17 2003, our next refueling outage. (G-3) 18 19 Comment: Some of its components were designed to last its licensed life. There have been 20 many other age related failures besides this one. Nine Mile core shroud, that steam generator 21 rupture in 1982 at Ginna was not anticipated; embrittlement of the reactor vessel, these all 22 surprised the experts. There are probably going to be more surprises as these plants age.

23 (H-9) 24 25 Response: The comments are noted. The NRCs environmental review is confined to 26 environmental matters relevant to the extended period of operation requested by the applicant.

27 To the extent that the comments pertain to safety of equipment and aging within the scope of 28 license renewal, these issues will be addressed during the parallel safety analysis review 29 performed under 10 CFR Part 54. Operational safety issues are outside the scope of 10 CFR 30 Part 51 and will not be evaluated further in this SEIS. The comments provide no new 31 information and, therefore, will not be evaluated further in the context of the environmental 32 review. However, the comments will be forwarded to the project manager for the license 33 renewal safety review for consideration.

34 35

11. Comments Concerning Issues Outside the Scope of License Renewal: Emergency 36 Response and Preparedness, Need for Power, Operational Safety, and Safeguards 37 and Security 38 39 Emergency Response and Preparedness 40 41 Comment: And while I must admit that the thought of a emergency at the plant is frightening to 42 all of us, particularly to me who is responsible for the safety of those 2,900 children, I also 43

Scoping Comment Report 22 R. E. Ginna March 2003 realize that Ginna is recognized as one of the best-run power plants in the nation. I have 1

confidence in the plant manager, Joe Widay, and his people who run the site. We also are 2

comfortable that it is a secure site, especially with the addition of the National Guardsmen, 3

more recently. The Wayne Central School District practices annual emergency drills and we 4

feel confident we are prepared to deal with an emergency, should there be one. (F-4) 5 6

Comment: Our emergency response is conducted in accordance with a formal plan, and is 7

thoroughly tested by Federal agencies. We have drills several times each year to test 8

ourselves. The emergency preparedness plan has been continuously improved. But 9

emergency planning at Ginna is not done in a vacuum; it is very much a team effort. Our 10 partners include Wayne and Monroe Counties, and the state of New York, among others. All 11 total about 1,000 people are part of our emergency response team. When we drill the plan we 12 have to meet rigorous standards set by the NRC and FEMA, the Federal Emergency 13 Management Agency. And our record is good. We, and our partners, constantly demonstrate 14 our ability to protect the health and safety of the public. The emergency plan has only one 15 focus, and that is safety. (G-2) (P-3) 16 17 Comment: But to give us some additional level of assurances of the security factors in place, 18 really that had been in place for an extended period of time, for the history of the plant, up until 19 9/11, and additional measures that had been thought of since that event. (I-2) 20 21 Comment: At a professional level I participated in the development of emergency planning, 22 participated in drills, and had the opportunity to observe, first-hand, the management team, 23 some of whom are here today, and their attentiveness to safety and health physics 24 departments, and to their consultants. Energy East must be observed by regulatory agencies to 25 see that the advice of these valuable employees continues to be carefully considered. (M-6) 26 27 Comment: Earlier this year, I went on tour of the Ginna plant to hear about their increased 28 security in light of what happened in New York City on September 11th of last year. Im 29 convinced that they take security seriously, and are well prepared. (O-3) 30 31 Comment: Approximately three weeks ago there was a drill, and I participated in it. I was at 32 the center over in Lyons, when it was being conducted. And I was pretty impressed with the 33 degree of professionalism I saw of all the people involved in the drill. There were probably at 34 least 25 to 30 people in the center at the time. And we had direct communications with the 35 plant, and I thought it was well done. (O-5) 36 37 Response: Emergency preparedness is an ongoing process at all plants, including Ginna.

38 Each nuclear plant must have an approved emergency plan, as required by 10 CFR Part 50, 39 that is revised periodically and required to be up to date. Emergency planning is part of the 40 current operating license and is outside the scope of the environmental analysis for license 41

23 March 2003 R. E. Ginna renewal. The comments did not provide, significant, new information and they do not pertain to 1

the scope of license renewal as set in 10 CFR Part 51 and Part 54, therefore, they will not be 2

evaluated further.

3 4

Need for Power 5

6 Comment: As I mentioned at the beginning of the presentation, Ginna is one of the key 7

providers of energy for the consumers in the RG&E service territory. Its 490 megawatts are 8

important for moderating energy prices in this region and, indeed, in the state. If Ginnas 9

baseload output is removed from the inventory of available capacity and energy, the result 10 could be a significant upward pressure on electric prices. (G-6) (P-6) 11 12 Comment: On the plus side we need energy for our homes, and for our places of employment.

13 We do not want to have brownouts here. (M-4) 14 15 Response: The need for power is specifically directed to be outside the scope of license 16 renewal (10 CFR 51.95 (c)(2)). The purpose and need for the proposed action (renewal of an 17 operating license) is to provide an option that allows for power generation capability beyond the 18 term of a current nuclear power plant operating license to meet future system generating 19 needs, as such needs may be determined by State, utility, and where authorized, Federal (other 20 than NRC) decision makers. The comments did not provide significant, new information and 21 they do not pertain to the scope of license renewal as set in 10 CFR Part 51 and Part 54; 22 therefore, they will not be evaluated further.

23 24 Operational Safety 25 26 Comment: And we would all be a lot safer. Whether or not you think that, you know, Ginna 27 should be relicensed or not, nobody can deny that we would be a lot safer if, you know, the 28 nuclear power plants were shut down, and the nuclear waste that was on-site was secured.

29 (B-7) 30 31 Comment: The mission of everyone who works at, and who supports Ginna, is simple; safe, 32 reliable, and economical operation, with the safety of the public and our workers being our 33 number one priority. (G-1) (P-1) 34 35 Comment: During this period of time that the plant has been in operation I have had no 36 concerns for my safety, nor those of my family. RG&E has expressed their commitment to safe 37 operation of the plant, and I believe the company employees feel the same way. (O-1) 38 39 Comment: However, if the Ginna plant is sold to another entity, I would like to be assured that 40 the new owner is as committed to the safe operation of the plant as RG&E is. And, of course, 41 that is something we dont know at this point in time. (O-2) 42 43

Scoping Comment Report 24 R. E. Ginna March 2003 Comment: The plant has been operated safely and reliably for more than 30 years. (U-2) 1 2

Response: The comments are noted. Operational safety, including comments related to the 3

original design of the facility, are outside the scope of the review. An NRC safety review for the 4

license renewal period is conducted separately. Although a topic may not be within the scope 5

of review for license renewal, the NRC is always concerned with protecting health and safety.

6 Any matter potentially effecting safety can be addressed under processes currently available for 7

existing operating license absent a license renewal application. The comments did not provide 8

significant, new information and do not pertain to the scope of the license renewal as set in 10 9

CFR Part 51; therefore, they will not be evaluated further.

10 11 Safeguards and Security 12 13 Comment: We also realize that, you know; nuclear in many ways is a special case. And right 14 now what we have to deal with, inevitably, is the reality that nuclear power plants in this country 15 are potential targets for terrorist attacks on civilians in America. And that is an issue that I didnt 16 even want to really look at, until 9/11. My concerns about nuclear power were, after having 17 grown up in reactor communities, living in one, had to do with just the day to day consequences 18 of having a reactor in the community, and the way that it divides people, the way that people 19 suffer from illness around reactors, and the ways in which it corrupts the political system in the 20 community. With 9/11 it is sort of the trump card, and the threat of terrorism. People talk about 21 the increase in security at Ginna. It is true, you know, people are hiring a few more security 22 guards. In New York we have the National Guard providing some extra service, which is 23 another subsidy, to deal with the inadequacy of the industrys ability to deal with the security 24 problem. But the truth is that security isnt an adequate response to it. The reactor sites, 25 themselves, are structurally vulnerable. People, there is a lot of focus on whether the 26 containment at Ginna could withstand an airliner impact, you know, whether or not the plane 27 goes through the containment, there is a lot of collateral damage that could cause a severe 28 accident. But, you know, the high level waste, the irradiated fuel; the spent fuel on site is in an 29 unprotected building. It is not -- there is no containment around the spent fuel pool, and that 30 has more radioactive material in it than the reactor ever has. So when you conceive of the fact 31 that the NRCs estimates from 1982, just for a meltdown, were that 2,000 people in the 32 immediate vicinity could die, and that 28,000 people within 40 miles could be hospitalized, and 33 that there could be, you know, 63 billion dollars in property losses to the surrounding area, you 34 know, this is really incredible. (B-5) 35 36 Comment: And even with Yucca Mountain we will still be left with 100 metric tons of 37 radioactive waste. And I dont know if Al Qaeda is targeting Ginna, but I do know that in the 38 80s the containment structures were studied, and were shown to not be able to, several of 39 them, many of them, 40 percent were shown not to be able to withstand a plane crash. (C-2) 40 41

25 March 2003 R. E. Ginna Comment: Security at the plant has received additional scrutiny and attention since the tragic 1

events of September 11th, 2001. RG&E has over 30 years experience in nuclear plant security.

2 The approach has never been relaxed, nor has it been static. It has been continually improved, 3

continually advanced, and continually toughened, from the day the plant started into operation.

4 And since September 11th we have devoted several million dollars in additional resources and 5

equipment. Our security force is numerous, it is well armed, and it is supported by 6

sophisticated technical surveillance, and intrusion detection systems. Plant security is founded 7

on a sound, very conservative, plant design. The reactor containment is a steel reinforced 8

concrete structure that is three feet thick. And more recent testing, and analysis, seems to 9

indicate that these designs would, indeed, withstand aircraft impacts. We have multiple safety 10 systems that support the security and the safety of the plant. And just as with emergency 11 preparedness, plant security is conducted with a formal plan, which is thoroughly reviewed by 12 the Nuclear Regulatory Commission, supported by others. We communicate frequently, and 13 work closely with a wide range of law enforcement and governmental agencies, including 14 county law enforcement, state police, the FBI, the Coast Guard, the National Guard, and 15 others. And to ensure the reliability and trustworthiness of the workforce, everyone who works 16 at Ginna is subject to detailed background checks before they are granted plant access. We do 17 take security seriously. And security at Ginna, and all other nuclear plants is under constant 18 review and evaluation. We cooperate, fully, with these reviews, because we believe any 19 system can be improved. (G-4) (P-4) 20 21 Comment: Commercial nuclear power plants once seen as vital to our national security are 22 now seen as vulnerable to terrorist attacks. (H-1) 23 24 Comment: Even without increased population many people believe the present emergency 25 ten-mile evacuation zones should be expanded, because of other concerns, such as the 26 terrorism issue. Ginna should not be relicensed until this is done. Terrorist concerns, we hear 27 how safe and secure the nuclear plants are with their guards, and lights, and fences, and 28 bunkers. But there have been failures of plant security, and warning devices, at Ginna since 29 September 11th.Sirens failed tests. A contract worker apparently tested positive for drugs last 30 spring. Many experts feel that the danger of attack lies from within the plant. There have been 31 at least two cases that we know of, since September 11th, where employee background checks 32 failed to catch workers who falsified information and omitted felony information. Also the spent 33 fuel pool is not in a hardened containment structure, it is more in something like a pole barn. It 34 could be attacked and breached with a relatively small projectile, and there is plenty of radiation 35 in it. (H-6) 36 37 Comment: As the downside, the heightened security has ruined the great fishing that is in the 38 warm water plume that exits the plant. Small mouth bass fishing there is tremendous.

39 However, now that we are restricted to a half mile offshore, that good fishing spot is no longer 40 available, so I cant buzz down there in my boat and fish any more. (O-4) 41 42

Scoping Comment Report 26 R. E. Ginna March 2003 Comment: The Environmental Impact Statement should analyze the potential impacts to the 1

public and the environment from terrorist attacks on the plant, including the ability of the local, 2

state, and federal emergency management agencies to mitigate the effects of any attack. (S-2) 3 4

Response: NRC and other Federal agencies have heightened vigilance and implemented 5

initiatives to evaluate and respond to possible threats posed by terrorists, including the use of 6

aircraft against commercial nuclear power plants and independent spent fuel storage 7

installations (ISFSIs). Malevolent acts remain speculative and beyond the scope of a NEPA 8

review. NRC routinely assesses threats and other information provided to them by other 9

Federal agencies and sources. The NRC also ensures that licensees meet appropriate security 10 levels. The NRC will continue to focus on prevention of terrorist acts for all nuclear facilities.

11 These matters will continue to be addressed through the ongoing regulatory process as a 12 current and generic regulatory issue that affects all nuclear facilities and many activities 13 conducted at nuclear facilities. The NRC has taken a number of actions to respond to the 14 events of September 11, 2001, and plans to take additional measures. However, the issue of 15 security and risk from malevolent acts at nuclear power plants is not unique to facilities that 16 have requested a renewal to their license and, therefore, will not be addressed within the scope 17 of this Supplement. The comments did not provide significant, new information and they do not 18 pertain to the scope of license renewals set forth in 10 CFR Part 51 and Part 54, therefore they 19 will not be evaluated further.

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12. Request for Information 22 23 Comment: We should also, as a condition; I would like to see this done. We should have 24 easier access to the radiation release data for the entire lake, not just Ginna, all the other 25 facilities. Winds of radiation do not respect boundary lines. I would like to see a database, a 26 good compilation of this information, that would be in an easy to access format, and it should be 27 sent to each town hall, and to each library within 25 miles of each of these power plants, not 28 just Ginna. The governments of the U.S. and Canada do not make it easy to get this data now.

29 I think somebody asked a question about that, and I think the fellow said it could be compiled.

30 But has it been compiled, or do we have to do this as citizens? That is not an easy process to 31 do. (H-13) 32 33 Response: This information has not been compiled; however the individual yearly data sets are 34 contained in Ginna annual environmental reports which can be found in the reading room on 35 the NRC website. This request for information did not provide significant, new information; 36 therefore, it will not be evaluated further.

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