ML041970736
| ML041970736 | |
| Person / Time | |
|---|---|
| Site: | Browns Ferry  |
| Issue date: | 07/01/2004 |
| From: | Office of Nuclear Reactor Regulation |
| To: | |
| Masnik MT, NRR/DRIP/RLEP, 415-1191 | |
| Shared Package | |
| ML041970731 | List: |
| References | |
| TAC MC1768, TAC MC1769, TAC MC1770 | |
| Download: ML041970736 (29) | |
Text
Environmental Scoping Summary Report Browns Ferry, Units 1, 2, and 3 Limestone County, Alabama June 2004 Docket Nos. 50-259, 50-260, and 50-296 U.S. Nuclear Regulatory Commission Rockville, Maryland
Scoping Comment Report June 2004 1
Browns Ferry, Units 1, 2, and 3 Introduction On January 6, 2004, the U.S. Nuclear Regulatory Commission (NRC) received, by letter, an 1
application from the Tennessee Valley Authority (TVA), filed pursuant to Section 104b of the 2
Atomic Energy Act of 1954, as amended, and 10 CFR part 54, which would authorize the 3
applicant to operate Browns Ferry Nuclear Plant Units 1, 2, and 3 for an additional 20-year 4
period. The current operating license for Browns Ferry Nuclear Plant Unit 1 expires on 5
December 20, 2013, the current operating license for Browns Ferry Nuclear Plant Unit 2 expires 6
on June 28, 2014, and the current operating license for Browns Ferry Nuclear Plant Unit 3 7
expires on July 2, 2016. Browns Ferry Units 1, 2, and 3 are boiling water reactors designed by 8
General Electric Company and are located in Limestone County, Alabama. As part of the 9
application, TVA submitted an environmental report (ER) prepared in accordance with the 10 requirements of 10 CFR Part 51. 10 CFR Part 51 contains the NRC requirements for 11 implementing the National Environmental Policy Act (NEPA) of 1969 and the implementing 12 regulations promulgated by the Council on Environmental Quality (CEQ). Section 51.53 13 outlines requirements for preparation and submittal of environmental reports to the NRC.
14 15 Section 51.53(c)(3) was based upon the findings documented in NUREG-1437, Generic 16 Environmental Impact Statement for License Renewal of Nuclear Power Plants, (GEIS). The 17 GEIS, in which the staff identified and evaluated the environmental impacts associated with 18 license renewal, was issued for public comment. The staff received input from Federal and 19 State agencies, public organizations, and private citizens. As a result of the assessments in the 20 GEIS, a number of impacts were determined to be generic to all nuclear power plants. These 21 were designated as Category 1 impacts. An applicant for license renewal may adopt the 22 conclusions contained in the GEIS for Category 1 impacts in the absence of new and significant 23 information that may cause the conclusions to fall outside those of the GEIS. Category 2 24 impacts are those impacts that have been determined to be plant-specific and are required to 25 be addressed in the applicants ER.
26 27 The Commission determined that the NRC does not have a role in energy planning decision-28 making for existing plants, which should be left to State regulators and utility officials.
29 Therefore, an applicant for license renewal need not provide an analysis of the need for power, 30 or the economic costs and economic benefits of the proposed action. Additionally, the 31 Commission determined that the ER should not include a discussion of any aspect of storage of 32 spent fuel for the facility. This determination was based on the Nuclear Waste Policy Act of 33 1982 and the Commissions Waste Confidence Rule, 10 CFR 51.23.
34 35 On March 10, 2004, the NRC published a Notice of Intent in the Federal Register (69 FR 36 11462), to notify the public of the NRCs intent to prepare a plant-specific supplement to the 37 GEIS to support the review of the license renewal application for the Browns Ferry, Units 1, 2, 38 and 3 operating licenses. The plant-specific supplement to the GEIS will be prepared in 39 accordance with NEPA, CEQ guidelines, and 10 CFR Part 51. As outlined by NEPA, the NRC 40 initiated the scoping process with the issuance of the Federal Register Notice. The NRC invited 41 the applicant; Federal, Tribal, State, and local government agencies; local organizations; and 42 individuals to participate in the scoping process by providing oral comments at the scheduled 43 public meetings and/or submitting written suggestions and comments no later than May 10, 44 2004. The deadline for filing comments was subsequently extended to June 4, 2004 (69 FR 45
Scoping Comment Report Browns Ferry, Unit 1, 2, and 3 2
June 2004 30338). The scoping process included two public scoping meetings, which were held at the 1
Athens State University, Student Center Cafeteria in Athens, Alabama on April 1, 2004. The 2
NRC announced the meetings in local newspapers (Huntsville Times, Decatur Daily, News 3
Courier, Florence Times Daily) and issued press releases. Approximately 40 people attended 4
each meeting, including the NRC environmental review team, members of the public, 5
representatives from TVA, 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. Seven (7) commenters provided either oral comments or written statements that 9
were recorded and transcribed by a certified court reporter. One commenter made comments 10 in both the afternoon and evening meetings. In addition to the comments provided during the 11 public meetings, the NRC received six comment letters. The afternoon and evening meeting 12 transcripts (accession numbers ML041350407 and ML041350459) and comment letters are 13 available electronically for public inspection in the NRC Public Document Room or from the 14 Publicly Available Records (PARS) component of NRCs Agency-wide Documents Access and 15 Management System (ADAMS). ADAMS is accessible from the NRC Web site at 16 http://www.nrc.gov/reading-rm.htm (the Public Electronic Reading Room).
17 18 The scoping process provides an opportunity for public participation to identify issues to be 19 addressed in the plant-specific supplement to the GEIS and highlight public concerns and 20 issues. The Notice of Intent identified the following objectives of the scoping 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 being 30 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 transcripts and all written material received, and identified individual comments. All comments 42 and suggestions received orally during the scoping meetings or in writing were considered.
43 Each set of comments from a given commenter was given a unique alpha identifier 44 (Commenter ID letter), allowing each set of comments from a commenter to be traced back to 45 the transcript, letter, or email in which the comments were submitted. Table 1 identifies the 46 individuals providing comments and the Commenter ID letter associated with each persons 47
Scoping Comment Report June 2004 3
Browns Ferry, Units 1, 2, and 3 set(s) of comments. The individuals are listed in the order in which they spoke at the public 1
meeting, and random order for the comments received by letter or email.
2 3
Comments were consolidated and categorized according to the topic within the proposed 4
supplement to the GEIS or according to the general topic if outside the scope of the GEIS.
5 Comments with similar specific objectives were combined to capture the common essential 6
issues that had been raised in the source comments. Once comments were grouped according 7
to subject area, the staff and contractor determined the appropriate action for the comment.
8 The staff made a determination on each comment that it was one of the following:
9 10
a comment that was either related to support or opposition of license renewal in general 11 (or specifically to Browns Ferry) or that makes a general statement about the licensing 12 renewal process. It may make only a general statement regarding Category 1 and/or 13 Category 2 issues. In addition, it provides no new information and does not pertain to 14 10 CFR Part 54.
15 16 A comment about a Category 1 issue that 17 Provided new information that required evaluation during the review, or 18 Provided no new information 19 20 A comment about a Category 2 issue that 21 Provided information that required evaluation during the review, or 22 Provided no such information 23 24 A comment that raised an environmental issue that was not addressed in the GEIS, or 25 26 A comment regarding Alternatives to the proposed action 27 28 A comment regarding safety issues within the scope of 10 CFR Part 54, but out of the 29 scope of 10 CFR Part 51 30 31 A comment outside the scope of license renewal (not related to 10 CFR Parts 51 or 54),
32 which include 33 A comment regarding emergency response and planning 34 A comment regarding the need for power 35 A comment regarding operational safety issues 36 A comment regarding safeguards and security 37 A comment regarding aging management 38 A comment regarding MOX fuel 39 A comment regarding decommissioning 40 A comment regarding restart of Browns Ferry Unit 1 41 A comment regarding cost-benefit analysis 42 43 A comment that was actually a question and introduces no new information.
44 45 Each comment is summarized in the following pages. For reference, the unique identifier for 46 each comment (Commenter ID letter listed in Table 1 plus the comment number) is provided.
47
Scoping Comment Report Browns Ferry, Unit 1, 2, and 3 4
June 2004 In those cases where no new information was provided by the commenter, no further evaluation 1
will be performed.
2 3
The preparation of the plant-specific supplement to the GEIS (which is the SEIS) will take into 4
account all the relevant issues raised during the scoping process. The SEIS will address both 5
Category 1 and 2 issues, along with any new information identified as a result of scoping. The 6
SEIS will rely on conclusions supported by information in the GEIS for Category 1 issues, and 7
will include the analysis of Category 2 issues and any new and significant information. The 8
draft plant-specific supplement to the GEIS will be available for public comment. The comment 9
period will offer the next opportunity for the applicant, interested Federal, Tribal, State, and local 10 government agencies; local organizations; and members of the public to provide input to the 11 NRCs environmental review process. The comments received on the draft SEIS will be 12 considered in the preparation of the final SEIS. The final SEIS, along with the staffs Safety 13 Evaluation Report (SER), will provide much of the basis for the NRCs decision on the Browns 14 Ferry license renewal.
15 16
Scoping Comment Report June 2004 5
Browns Ferry, Units 1, 2, and 3 TABLE 1 - Individuals Providing Comments During Scoping Comment Period 1
2 Commenter 3
ID 4
Commenter Affiliation (If Stated)
Comment Source and Accession Number:
BF-A 5
Stewart Horn Afternoon Scoping Meeting - ML041350407 BF-B 6
Dr. Lane Price Afternoon Scoping Meeting BF-C 7
Ann Harris We the People, Inc Afternoon Scoping Meeting BF-D 8
Stewart Ward Afternoon Scoping Meeting BF-E 9
Chuck Wilson Tennessee Valley Authority Afternoon Scoping Meeting BF-F 10 Nancy Muse Evening Scoping Meeting -
ML041350459 BF-G 11 Jeff North Evening Scoping Meeting BF-H 12 Chuck Wilson Tennessee Valley Authority Evening Scoping Meeting BF-I 13 Zola Comment Letter -
ML041250405 BF-J 14 Michael Bolt Eastern Band of Cherokee Indians Comment Letter BF-K 15 Michelle Hamilton Eastern Band of Cherokee Indians Comment Letter -
ML041490083 BF-L 16 Sara Barczak and David Ritter Southern Alliance for Clean Air and Public Citizens Critical Mass Energy and Environmental Program Comment Letter -
ML041340245 BF-M 17 Anoatubby Chickasaw Nation Comment Letter -
ML041410044 BF-N 18 Frances Lamberts Tennesee League of Women Voters Comment Letter -
19
Scoping Comment Report Browns Ferry, Unit 1, 2, and 3 6
June 2004 1
Scoping Comment Report June 2004 7
Browns Ferry, Units 1, 2, and 3 Browns Ferry Nuclear Power Plant, Units 1, 2, 3 1
Public Scoping Meeting and Written Input 2
Comments and Responses 3
4 5
6 The following pages summarize the comments and suggestions received as part of the scoping 7
process, and discuss their disposition. Parenthetical numbers after each comment refer to the 8
Commenter ID letter and the comment number. Comments can be tracked to the commenter 9
and the source document through the ID letter and comment number listed in Table 1.
10 Comments are grouped by category. The categories are as follows:
11 12 1.
Comments Regarding License Renewal and its Processes 13 2.
Comments in Support of License Renewal at Browns Ferry Nuclear Power Plant 14 3.
Comments in Opposition to License Renewal at Browns Ferry Nuclear Power 15 Plant 16 4.
Comments Concerning Aquatic Ecology Issues 17 5.
Comments Concerning Threatened and Endangered Species 18 6.
Comments Concerning Air Quality Issues 19 7.
Comments Concerning Human Health Issues 20 8.
Comments Concerning Cultural Resources Issues 21 9.
Comments Concerning Alternative Energy Sources 22 10.
Comments Concerning Surface Water Quality, Hydrology and Use 23 11.
Comments Concerning Postulated Accidents 24 12.
Comments Concerning Uranium Fuel Cycle 25 13.
Comments Concerning Issues Outside the Scope of License Renewal:
26 Emergency Response and Preparedness, Need for Power, Operational Safety, 27 and Safeguards and Security, Aging Management, Decommissioning, Restart of 28 Browns Ferry, Unit 1, Cost-Benefit Analysis 29 14.
Request for Information 30 31 32
- 1. Comments Regarding License Renewal and its Processes 33 34 Comment: We appreciate this opportunity to comment during this scoping process, and trust 35 that our comments will be taken seriously. (BF-L-31) 36 37 Comment: I appreciate the process that allows the public to comment. (BF-A-5) 38 39 40 41 Response: The comments are in regard to license renewal and its processes in general. The 42 Commission has established a process, by rule, for the environmental and safety reviews to be 43 conducted to review a license renewal application. This process includes a review of public 44 comments received during scoping. The comments did not provide significant, new information; 45 therefore, they will not be evaluated further.
46
Scoping Comment Report Browns Ferry, Unit 1, 2, and 3 8
June 2004 Comment: I was talking with the TVA gentleman before the formal meeting started. I asked 1
why a 20 year extension? And they said thats easy, thats what the law provides for us, not 10, 2
not 30. [MR. CAMERON: First question, why 20?] (BF-G-1) 3 4
Response: The license renewal period is for up to 20 years. In revising the regulations that 5
address license renewal in 10 CFR 54, NRC determined that 20 years is appropriate to 6
demonstrate an adequate licensing basis. This time period offers reasonable assurance of 7
adequate protection assuming the current licensing basis is modified to account for age-related 8
safety issues to manage to adverse effects on systems, structures and components. The 9
comment did not provide significant, new information; therefore, will not be evaluated further.
10 11 Comment: Somewhat related to the above, we urge a comprehensive Environmental Impact 12 Statement before Unit 1 re-start and license extension decisions for Units 2 and 3. (BF-N-20) -
13 14 Response: The comment is in regard to license renewal and its processes in general. The 15 Commission has established a process, by rule, for the environmental and safety reviews to be 16 conducted to review a license renewal application. This process includes preparation of a 17 comprehensive supplement to the GEIS for license renewal. The comment did not provide 18 significant, new information; therefore, they will not be evaluated further.
19 20
- 2. Comments in Support of License Renewal at Browns Ferry Nuclear Power Plant 21 22 Comment: For the Browns Ferry license renewal supplemental EIS, TVA concluded the 23 following: there were no significant environmental impacts, and restarting Unit 1, and continuing 24 operation of all three units allows power production without green house gases. Which is 25 consistent with TVAs clean air initiatives. (BF-E-1) (BF-H-1) 26 27 Comment: Plus, it maximizes use of existing assets and avoids the impacts of new site 28 construction, which is very important financially to the ratepayers and consumers of the valley.
29 (BF-E-2) (BF-H-2) 30 31 Response: The comments were supportive of license renewal at Browns Ferry and are general 32 in nature. The comments did not provide significant, new information; therefore, they will not be 33 evaluated further.
34 35
- 3. Comments in Opposition to License Renewal at Browns Ferry Nuclear Power Plant 36 37 Comment: Now that you are supporting TVA in this endeavor of licensing extension, I must 38 assume that you will provide them with the 20 years as requested. So much for public input, so 39 much for regulatory oversight. (BF-C-8) 40 41 Comment: I know that this meeting is being to held to check off the next box on your list of 42 happenings for TVA to receive this extension. I dont believe for a minute that you will hinder or 43 take this process seriously. (BF-C-14) 44 45
Scoping Comment Report June 2004 9
Browns Ferry, Units 1, 2, and 3 Response: The NRC makes the decision to grant or deny a license renewal, based on whether 1
the applicant has demonstrated that the environmental and safety requirements in the NRCs 2
regulations can be met during the renewal period. If the applicant meets the requirements given 3
in the regulations, then the NRC can be expected to approve renewal of the license. The NRC 4
can deny an applicants request to renew a license, however, the process to renew a license is a 5
reiterative process, such that if the licensee did not provide appropriate or adequate information 6
in their initial application, the NRC would identify the deficiencies and the licensee would be 7
allowed to resubmit the application. This process could, and has, continued until the NRC 8
concludes that the application is sufficient to complete the review. Furthermore, if it appeared to 9
the applicant that the NRC may deny the request for license renewal, the applicant would likely 10 withdraw the request in advance of the formal denial. The comments oppose license renewal at 11 Browns Ferry, and are general in nature. The comments do not provide new information; 12 therefore, they will not be evaluated further.
13 14 Comment: Why should I or other TVA ratepayers trust you NRC to stand up to bullies such as 15 these? NRC you have never said no to the industry, so I must admit that my statement is an act 16 of futility and is simply playing into your hands to show someone somewhere that you have met 17 the requirements of public input. (BF-C-17) 18 19 Comment: And you boys are supporting this plant to go forth and spread its venom on helpless 20 communities, simply because you do not have the nerve to say no to TVA. (BF-C-9) 21 22 Response: To date, at the conclusion of the review, the NRC has approved all of the 23 applications for license renewal. The NRC can deny an applicants request to renew a license, 24 however, the process to renew a license is a reiterative process, such that if the licensee did not 25 provide appropriate or adequate information in their initial application, the NRC would identify the 26 deficiencies and the licensee would be allowed to resubmit the application. This process could, 27 and has, continued until the NRC concludes that the application is sufficient to complete the 28 review. Furthermore, if it appeared to the applicant that the NRC may deny the request for 29 license renewal, the applicant would likely withdraw the request in advance of the formal denial.
30 31 The NRC has clearly defined the requirements for license renewal and the nuclear industry has 32 the experience of over a dozen successful license renewal requests. Because of the cost and 33 the commitment associated with an application it is unlikely that an applicant would intentionally 34 submit an application for license renewal that was so flawed that the NRC staff would issue a 35 denial. Finally, if problems with systems, structures or components of the facility were identified 36 during the review, the applicant would likely be able to make the required modifications or put in 37 place a mitigation plan that would be acceptable to the NRC. Identified problems with active 38 structures, systems, or components would be addressed immediately, and any necessary 39 changes made under the current operating license rather than waiting for the period of extended 40 operation. The comments oppose license renewal at Browns Ferry, and are general in nature.
41 The comments do not provide new information; therefore, they will not be evaluated further.
42 43 Comment: With absence of substantive efforts toward this end by the TVA, the granting of 44 licenses to simply extend (or even expand) this providers nuclear energy capacity for almost a 45 generations lifetime seems to us inappropriate. (BF-N-4) 46
Scoping Comment Report Browns Ferry, Unit 1, 2, and 3 10 June 2004 Comment: In this context, we object to the proposed twenty-year license extension for 1
reactor Unit 1, whose current operating license will expire on December 20, 2013 2
but which has been on (legally undefined administrative hold) in-operational 3
status since more than a decade and a-half ago. (BF-N-8) 4 5
Comment: We so urge the Nuclear Regulatory Commission, i.e. against expansion and 6
long-term license renewal, at this time. (BF-N-29) 7 8
Response: The comments oppose license renewal at Browns Ferry, and are general in nature.
9 The comments do not provide new information; therefore, they will not be evaluated further.
10 11
- 4. Comments Concerning Aquatic Ecology Issues 12 13 As stated in 10 CFR Part 51, Table B-1, Category 1 and 2 aquatic ecology issues include:
14 15 Category 1 16 17 Accumulation of contaminants in sediments or biota 18 Entrainment of phytoplankton and zooplankton 19 Cold shock 20 Thermal plume barrier to migrating fish 21 Distribution of aquatic organisms 22 Premature emergence of aquatic insects 23 Gas supersaturation (gas bubble disease) 24 Low dissolved oxygen in the discharge 25 Losses from predation, parasitism, and disease among organisms exposed to sublethal 26 stresses 27 Stimulation of nuisance organisms 28 29 Category 2 30 31 Entrainment of fish and shellfish in early life stages 32 Impingement of fish and shellfish 33 Heat shock 34 35 Comment: I don't understand the terminology impingement and entrainment. I don't know how 36 to comment on that without understanding what it is. (BF-F-6) 37 38 Comment: Through impingement and entrainment, and through thermal alteration of returned 39 water they cause damage to aquatic life, including great fishery and related recreational losses 40 along river systems on which they are located. (BF-N-15) 41 42 Response: Impingement occurs when a fish or shellfish are pulled onto the intake screens that 43 are part of the cooling water systems associated with nuclear power plants. Entrainment occurs 44 when fish, shellfish, or larva that are too small to be impinged on the screen are entrained in the 45
Scoping Comment Report June 2004 11 Browns Ferry, Units 1, 2, and 3 flow through the plant, traversing the plant cooling system. Impingement and entrainment as 1
well as other aquatic ecology issues will be discussed in Chapter 2 and Chapter 4 of the SEIS.
2 3
Comment: The EIS should include (3) analysis of aquatic wildlife and terrestrial species 4
impacts, with extensive involvement of the federal and state agencies charged 5
with natural resource protection. (BF-N-23) 6 7
Response: Impacts to aquatic and terrestrial species will be discussed in Chapter 4 of the SEIS.
8 9
- 5. Comments Concerning Threatened and Endangered Species 10 11 Comment: New data on the status of federally and state-listed endangered or threatened 12 terrestrial animal, aquatic, and plant species should be required and studied as to the impacts of 13 an additional 20 years of operations per reactor. (BF-L-13) 14 15 Comment: Proper notification to, along with creation of working relationships with, state 16 agencies, Fish and Wildlife Service, and National Marine Fisheries Service should occur.
17 (BF-L-14) 18 19 Response: During the analysis and preparation of the draft SEIS for license renewal, the NRC 20 staff consults with appropriate Federal agencies. The NRC usually contacts directly the U.S.
21 Fish and Wildlife Service (Department of the Interior) and the National Marine Fisheries Service 22 (Department of Commerce) for environmental issues related to the impact on any threatened or 23 endangered species that may be in the vicinity of the plant or to any critical habitat. If other 24 agencies have actions or jurisdiction over areas directly related to the review, they would also be 25 contacted directly by the NRC.
26 27 In addition to NRC coordinated consultation, after a draft EIS is published, it is also reviewed by 28 various Federal agencies at their discretion. For example, at the Federal level, the draft SEISs 29 for license renewal are most commonly reviewed by the Environmental Protection Agency and 30 the Department of the Interior. The comments from these agencies are considered and included 31 in the Final SEIS as appropriate.
32 33 Potential impacts of renewing the operating licenses for Browns Ferry Units 1, 2, and 3 on 34 threatened or endangered species will be evaluated in Chapter 2 and Chapter 4 of the SEIS.
35 36
- 6. Comments Concerning Air Quality Issues 37 38 Comment: We note that Limestone County is not evaluated as having bad air quality and that 39 the annual quantity of emissions released into the atmosphere is normal for a nuclear plant. In 40 an ideal situation it would not be necessary for us to make comment on air quality, however the 41 air quality situation is far from ideal in the Great Smoky Mountains. Because air flows from 42 Alabama frequently move towards our mountains we would like to encourage the exploration of 43 reducing emissions at Browns Ferry. (BF-J-1) 44 45
Scoping Comment Report Browns Ferry, Unit 1, 2, and 3 12 June 2004 Response: Air quality impacts from plant operations were evaluated in the GEIS and found to 1
be minimal. Air emissions are regulated through the U.S. Environmental Protection Agency and 2
the State of Alabama. Air quality will be discussed in Chapter 2 of the SEIS for Browns Ferry 3
4 5
6
- 7. Comments Concerning Human Health Issues 7
8 As stated in 10 CFR Part 51, Table B-1, Category 1 and 2 human health issues include:
9 10 Category 1 11 12 Microbiological organisms (occupational health) 13 Noise 14 Radiation exposures to public (license renewal) 15 Occupational radiation exposures (license renewal) 16 17 Category 2 18 19 Microbiological organisms (public health)(plants using lakes or canals, or cooling towers or 20 cooling ponds that discharge to a small river) 21 Electromagnetic fields, acute effects (electric shock) 22 23 Comment: I'm also concerned about the level of radioactive substances that are effluent. If 24 and what they are, and where can we get that information? Is that on the web site of the NRC?
25 Radio activity that is released into the environment in any way. (BF-F-7) 26 27 Comment: Could you specifically address the effluent from Browns Ferry. What do you all 28 actually put into the river, itself?(BF-B-1) 29 30 Comment: I want to know whether the millirem is per what or per person. What it meant when 31 you gave that answer, when you said equal to a dose of... Is that what a person can get by 32 being in the water at the point of the -- at the pipes? (BF-D-1) 33 34 Response: NRC is a regulatory agency charged with assuring the public health and safety.
35 NRC does this by providing the industry with regulations as well as conducting plant inspections.
36 The licensee is allowed to release gaseous and liquid effluents to the environment, but the 37 releases must be monitored and meet the requirements of 10 CFR Part 20, Appendix B, Table 2; 38 therefore, contaminants may be present and detectable offsite. However, the release limits 39 have been designed and proven to be protective of the health and safety of the public and 40 environment. The NRC sets limits on radiological effluents, requires monitoring of effluents and 41 foodstuffs to assure those limits are met, and has set dose limits to regulate the release of 42 radioactive material from nuclear power facilities. The regulations are intentionally conservative 43 and provide adequate protection for the public including the most radiosensitive members of the 44 population. TVA monitors its effluent and calculates an offsite annual dose caused by radioactive 45
Scoping Comment Report June 2004 13 Browns Ferry, Units 1, 2, and 3 liquid and gaseous effluents. These calculations are performed to demonstrate the licensees 1
compliance with its technical specifications and NRC regulations.
2 3
The NRC publishs two annual reports for Browns Ferry regarding environmental monitoring and 4
environmental effluents. The Annual Radiological Environmental Operating Report (AREOR) 5 and the Annual Radiological Effluent Release (ARER) Report are available to the public 6
through the NRC's Public Document Room in Rockville, Maryland or from the NRCs Electronic 7
Reading Room available online at http://www.nrc.gov/reading-rm.html. The comments provide 8
no new information, therefore, they will not be evaluated further.
9 10
- 8. Comments Concerning Cultural Resources 11 12 Comment: According to the information you provided, the EBCIs THPO has determined that 13 the proposed activities will not have an effect on any known cultural resources significant to our 14 Tribe. (BF-K-1) 15 16 Comment: We have also determined the undertaking will not have an affect on known cultural 17 resources listed on or eligible for the National Register of Historic Places provided that 18 archaeological site 1Li535 is avoided as stated in the BFN License Renewal Final Supplemental 19 EIS. (BF-K-2) 20 21 Response: The comments refer to Historic and Archaeological resources near Browns Ferry.
22 These issues will be addressed in Chapter 2 and Chapter 4 of the SEIS.
23 24 25
- 9. Comments Concerning Alternative Energy Sources 26 27 Comment: In our experience, the relicensing process has generally provided an inadequate 28 analysis of energy alternatives. (BF-L-15) 29 30 Comment: In addition, other electricity generating technologies, such as solar, wind, and 31 biomass should be investigated. (BF-L-17) 32 33 Comment: The League believes that an emphasis on conserving energy and using 34 energy-efficient technologies is by far the wisest and safest course of action 35 for our nation and state. (BF-N-3) 36 37 Comment: The League also believes that predominant reliance should be placed on 38 production of energy from renewable sources. (BF-N-5) 39 40 Comment: We have applauded and strongly support the TVAs initiation of a Green Power 41 Switch program whose wind, solar, and methane gas installations now produce electric power 42 for more than seven thousand residential and business users. At this time, however, TVAs 43 generational capacity under this program makes up less than one percent of its 44 capacity from the two, now operating Browns Ferry units. For ecological and 45 other reasons, the strongest market trends in the energy field, around the world 46 favor energy production from renewable sources and weight of public opinion is 47
Scoping Comment Report Browns Ferry, Unit 1, 2, and 3 14 June 2004 on the side of expansion of these sources, at least within the Tennessee part of 1
the Agency service area. (BF-N-6) 2 3
Response: The GEIS included an extensive discussion of alternative energy sources.
4 Environmental impacts associated with various reasonable alternatives to renewal of the 5
operating licenses for Browns Ferry will be discussed in Chapter 8 of the SEIS. The comments 6
did not provide significant, new information; therefore, they will not be evaluated further.
7 8
Comment: It should thoroughly assess and clearly delineate (2) the alternative 9
options and their economic, environmental and social benefits and costs. Delineation of 10 alternatives should include optimization of energy efficiency technologies, energy conservation, 11 and Green-Power-Switch program maximization. (BF-N-22) 12 13 Comment: It should also include comprehensive assessment and comparison of normal (4) 14 safety-related costs for nuclear plants relative to alternative, renewable-source generation 15 options, (BF-N-24) 16 17 Comment: The NRC must review in every respect these safety implications and costs 18 of nuclear-power sources as against the societal and environmental advantages 19 which renewable and substantially risk-free generation sources offer. (BF-N-27) 20 21 The Commission determined that an applicant for license renewal need not provide 22 an analysis of the economic costs or economic benefits of the proposed or alterative actions.
23 The comments did not provide significant, new information; therefore, they will not be evaluated 24 further.
25 26
- 10. Comments Concerning Surface Water Quality, Hydrology and Use 27 28 Comment: I will only focus on the high discharge temperature that will occur when all three 29 units are operating at 3952 Mega-watts Thermal. The existing five cooling towers are unable to 30 cool the water at peak summer conditions without derating an operating unit. (BF-I-1) 31 32 Comment: There is no concerted effort to built back cooling tower #4 or build additional cooling 33 towers to allow operation at 100% of Extended Power Uprate (EPU) without derating all three 34 units or having to take one off-line. Studies have been conducted by TVAs Norris labs to 35 validate this assertion. (BF-I-2) 36 37 Comment: I believe there is a planned effort to allow Unit 1 to continue in its effort to restart 38 with paying for the adequate cooling to meet the discharge limits. This is being driven by a 39 fervent desire to hold the restart costs down and not impact schedule dates. (BF-I-3) 40 41 Response: These comments refer surface water quality issues. These issues will be 42 addressed in Chapters 2 and 4 of the SEIS.
43 44 Comment: The Nuclear Regulatory Commission should evaluate the impacts of extended 45 generation from a regional perspective and should investigate state-level political concerns that 46
Scoping Comment Report June 2004 15 Browns Ferry, Units 1, 2, and 3 may affect that ability to dedicate large water resources for extremely long periods of time.
1 (BF-L-9) 2 3
Comment: The NRC should require updated water use information for the region on current 4
water needs, as in what industries and municipalities are currently using and are projected to 5
use in the future as population centers continue to grow. (BF-L-12) 6 7
Comment: Since construction of the Browns Ferry plant some four decades ago, Tennessee 8
and the region have experienced enormous growth in population, with corresponding demands 9
on water--our most important and life-necessary natural resource. (BF-N-16) 10 11 Comment: Since Unit 1 has not operated since 1985, and all of the reactors came on-line for a 12 time in the mid-to-late 1970s, thorough water withdrawal and water consumption analyses, along 13 with fish and vegetation studies, must be done using updated data (not referring back to original 14 operating license information). (BF-L-10) 15 16 Comment: Further, the impact of the water withdrawn and its effect on the flow of the 17 Tennessee River should be evaluated not during just normal conditions but in times of drought, 18 which have impacted the region when Browns Ferry Unit 1 was not even operating. (BF-L-11) 19 20 Comment: We have strong concerns regarding nuclear power plant impacts on the regions 21 water resources. Reactors like those at Browns Ferry consume through evaporation 22 about 20,000 gallons per minute; their flow-through rate exceeds 600,000 gallons 23 per minute and their direct and indirect cost to the water resource exceeds 50 24 gallons per each kilowatt hour of electricity they generate. (BF-N-14) 25 26 Comment: Given their huge withdrawal demands, it is imperative that the NRC 27 consider the water impacts from the Browns Ferry reactors in a comprehensive way 28 and from the perspective of all human and wildlife needs and all competing uses 29 over the longer-term future. (BF-N-17) 30 31 Comment: We believe, therefore, that committing to electricity generation such large 32 water withdrawals as are needed for safe operation of the Browns Ferry reactors, 33 for more than three decades hence, may not be wise when generation options which 34 have no or minimal impacts, e.g. from renewable sources, are available. (BF-N-19) 35 36 Response: These comments refer to water use and water use conflicts. These issues will be 37 addressed in Chapter 4 of the SEIS.
38 39 Comment: Possible threats to water security in the region under various climate-change 40 scenarios must also be considered in this context. (BF-N-18) 41 42 43 44
- 13. Comments Concerning Postulated Accidents 45 46
Scoping Comment Report Browns Ferry, Unit 1, 2, and 3 16 June 2004 Comment: Directly relevant to Browns Ferry Unit 1 concerns about restart and the subsequent 1
operating extension are the accident projections from the Brookhaven National Laboratory Study 2
in 1997 for a closed BWR for an area within 50 miles of the plant: population dose of 38 million 3
rem, 15, 300 latent fatalities, 140 square miles of condemned land, and a cost of $48 billion 4
(NUREG/CR-6451, April 1997). (BF-L-4) 5 6
Comment: I believe that the people of the Tennessee Valley may be in real danger from a 7
major nuclear accident if these concerns prove to be accurate. (BF-A-4) 8 9
Response: The effects of accidents are considered in both environmental and safety reviews 10 for license renewal. Postulated accidents, including design based and severe accidents, will be 11 addressed in Section 5.0 of the SEIS.
12 13
- 12. Comments Concerning Uranium Fuel Cycle 14 15 Comment: Further, spent fuel casks, both for onsite storage and for transportation, have not 16 undergone adequate testing to demonstrate thorough safety and containment of radiation, both 17 during normal usage and during various accident scenarios. (BF-L-22) 18 19 Comment: Again, the industrys inclination to take every opportunity to cut costs (in attempting 20 to make nuclear energy appear remotely viable, economically) creates a disturbing tension here, 21 with nuclear utilities gravitating towards the casks that are cheapest and the least tested. (BF-L-22 23) 23 24 Response: The NRC is committed to preventing detrimental health impacts to the public. NRC 25 has regulations covering the long-term storage of spent fuel onsite as well as packaging and 26 transport of radioactive material. These regulations regarding packaging and transport of 27 radioactive material are found at 10 CFR Part 71. NRC regulations related to exposure to the 28 public are found at 10 CFR Part 20. In addition, the U.S. Department of Transportation and the 29 U.S. Environmental Protection Agency have regulations to protect the public from health effects 30 associated with radiation. U.S. Department of Transportation regulations related to 31 transportation of radioactive material are found at 49 CFR Part 173, and the Environmental 32 Protection Agency regulations related to radiation are found at 40 CFR Parts 190 through 194.
33 34 The safety and environmental effects of long-term storage of spent fuel onsite has been 35 evaluated by the NRC, and, as set forth in the Waste Confidence Rule, the NRC generically 36 determined that such storage can be accomplished without significant environmental impact. In 37 the Waste Confidence Rule, the Commission determined that spent fuel can be stored onsite for 38 at least 30 years beyond the licensed operating life, which may include the term of a renewed 39 license. The NRC has a certification process for casks, regulated by 10 CFR Part 72. Such 40 wastes are under continual licensing control. The comments did not provide significant, new 41 information; therefore, they will not be evaluated further.
42 43
- 13. Comments Concerning Issues Outside the Scope of License Renewal: Emergency 44 Response and Preparedness, Need for Power, Operational Safety, and Safeguards and 45 Security, Aging Management, MOX fuel, Decommissioning, Restart of Browns Ferry, Unit 46 1, Cost-Benefit Analysis 47
Scoping Comment Report June 2004 17 Browns Ferry, Units 1, 2, and 3 Emergency Response and Preparedness 1
2 Comment: NRC and TVA, both of you know that there is not one evacuation plan at any nuclear 3
facility in America that meets NRC standards and cannot be carried out for that accident that will 4
only happen at 2:00 AM in the morning while the children are home asleep. (BF-C-16) 5 6
Response: Emergency preparedness is an ongoing process at all plants, including Browns 7
Ferry. Each nuclear plant must have an approved emergency plan, as required by 10 CFR Part 8
50, that is revised periodically and required to be up to date. Emergency planning is part of the 9
current operating license and is outside the scope of the environmental analysis for license 10 renewal. The comment did not provide significant, new information and it does not pertain to 11 the scope of license renewal as set in 10 CFR Part 51 and Part 54, therefore, it will not be 12 evaluated further.
13 14 Need for Power 15 16 Comment: The NRC should investigate TVAs projected energy needs as they have a history of 17 overestimating their power output (i.e. TVA projected in the 1970s that they would need to build 18 17 reactors). For instance, TVA has not produced an Integrated Resource Plan in the past five 19 years that would document a need for this action to take place. TVA should be required to 20 explore energy efficiency and conservation measures that could be implemented in within their 21 service territory to offset the needs of license extension. (BF-L-16) 22 23 Comment: TVA has projected to run Browns Ferry at a 93% capacity factor even though no 24 other utilities or nuclear plants are achieving these factors with BWR designs (BWRs are 25 averaging capacity factors in the low to mid 80% range). Further, Unit 1 has not operated since 26 1985 and when it did operate, it had a low capacity factor. The NRC should research realistically 27 achievable capacity factors and require TVA to address the gap in capacity factor that will 28 result, inevitably affecting the costs of electricity generated by the plant. (BF-L-6) 29 30 Comment: In general, the League of Women Voters supports energy policies that work to 31 reduce growth rates. This is of especial note for TVA in whose service area per 32 capita electricity consumption ranks highest in the nation and which has failed 33 to engage in significant efforts at managing the demand side of electric energy. (BF-N-2) 34 35 Comment: The EIS should critically examine (l) the need for the proposed license 36 actions, especially in light of absence of a current Integrated Resource Plan by 37 the TVA. (BF-N-21) 38 39 Response: The need for power is specifically directed to be outside the scope of license 40 renewal (10 CFR 51.95 (c)(2)). The purpose and need for the proposed action (renewal of an 41 operating license) is to provide an option that allows for power generation capability beyond the 42 term of a current nuclear power plant operating license to meet future system generating needs, 43 as such needs may be determined by State, utility, and where authorized, Federal (other than 44 NRC) decision makers. The comments did not provide significant, new information and it does 45 not pertain to the scope of license renewal as set in 10 CFR Part 51 and Part 54; therefore, it will 46 not be evaluated further.
47
Scoping Comment Report Browns Ferry, Unit 1, 2, and 3 18 June 2004 Operational Safety 1
2 3
4 5
6 7
8 9
10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 31 32 33 34 35 36 37 Radioactive sources are in controlled systems. Exposure to radiation occurs when 38 there is a breach in one of the systems, such as a leaky pipe. Worker safety is important to 39 NRC. Regulations require that workers wear personal protective equipment, appropriate 40 dosimetry, and practice ALARA when working in areas where they maybe potentially exposed to 41 radiation contamination.
42 43 44 45 Comment: The other event of major significance was the fire at Browns Ferry in 1975 during 46 which there were periods of time when the operators had no control of the reactors and could 47
Scoping Comment Report June 2004 19 Browns Ferry, Units 1, 2, and 3 not even determine what the conditions of operation were (including the critical water level in the 1
reactors). During this fire, the facility came very close to entering into a meltdown situation. (BF-2 A-13) 3 4
Comment: Yes, I know that TVA says it has the best safety record in the industry. Who says 5
so? INPO and McGraw Hill. INPO is a secret nuclear industry society that will not share the 6
good nor the bad with the public, so we have trust you boys to give us the party line each year 7
they come for inspection visits. And McGraw Hill is a TVA contractor and will say whatever they 8
are paid to say. So much for independence. So much for TVAs great safety records. (BF-C-7) 9 10 Comment: Recurrent, safety-related difficulties had been observed at this Unit at least since 11 the 1975 fire which destroyed its safety equipment for core and plant cool down, avoiding by 12 sheer luck--as reported-- a potentially catastrophic external release of radiation. (BF-N-9) 13 14 Response: Operational safety is outside the scope of the environmental review. An NRC 15 safety review for the license renewal period is conducted separately. Although a topic may not 16 be within the scope of review for license renewal, the NRC is always concerned with protecting 17 health and safety. Any matter potentially effecting safety can be addressed under processes 18 currently available for existing operating license absent a license renewal application. The 19 comments did not provide significant, new information and do not pertain to the scope of the 20 license renewal as set in 10 CFR Part 51; therefore, they will not be evaluated further.
21 22 Safeguards and Security 23 24 Comment: (5) the safety related costs arising from todays national-security needs. (BF-N-25) 25 26 27 Comment: In the post 9/11 national reality, nuclear installations have become known to be 28 priority targets for international terrorism. This new reality, beyond all other factors demands a 29 re-thinking of the way our energy future should be shaped and of the role of inherently 30 dangerous technologies such as nuclear power, in this future. (BF-N-26) 31 32 Comment: In our view, the immense new security threats which nuclear plants--especially of 33 design and age such as at Browns Ferry--pose to our region argue against expansion through 34 re-opening/re-licensing of Unit 1 and against 20-year extension beyond the next decade, for the 35 other units. (BF-N-28) 36 37 Comment: These licenses should not be renewed, but to do so without mandating stringent 38 and thorough requirements for massive safety and security upgrades would also be reckless and 39 irresponsible. (BF-L-27) 40 41 Comment: The Browns Ferry nuclear plant is a BWR-Mark I GE-4 design which has numerous 42 inherent safety flaws: the spent-fuel pool is elevated above ground level and is vulnerable from 43 above; the reactor itself is located above ground level; and it lacks a traditional containment 44 dome and instead has a thin steel shell. (BF-L-2) 45 46
Scoping Comment Report Browns Ferry, Unit 1, 2, and 3 20 June 2004 Comment: In light of terrorism concerns, which are essentially ignored in the relicensing 1
process, the BWR facility is also vulnerable to attacks such as those posed by 2
shoulder-launched missiles. Though the NRC will inevitably disregard these concerns, we 3
believe that they are relevant to be reviewed during this process. (BF-L-3) 4 5
Comment: The NRC conceded soon after 9/11 that the design basis threat for which nuclear 6
power plants are constructed to be able to withstand does NOT include impacts from jetliners of 7
the type used on 9/11. Considering that nuclear power plants would be a prime target for 8
terrorists, the perennial tension between the industrys desire to cut costs in order to appear 9
economically viable and the significant expense of thorough, effective security is now all the 10 more salient after we have witnessed a massive terrorist attack within our nations borders.
11 (BF-L-18) 12 13 Comment: The challenges involved in making Browns Ferry absolutely secure against a 14 terrorist attack from outside the plant perimeter would be enormous, both financially and 15 logistically, and only further highlight the hopeless nature of attempting to provide complete 16 safeguarding and security of this inherently dangerous technology. For instance, to place 17 anti-aircraft weaponry at a nuclear plant would involve developing protocols for determining 18 when/how an aircraft is presenting a clear threat, who would be authorized to operate the 19 weapon, and who would decide when to fire on an aircraft. Additionally, any weaponry onsite at 20 a nuclear facility must also be secured such that it could not be used by saboteurs or intruders 21 that successfully gain onsite access. Further consideration must be made of the considerable 22 hazard that residents would face in the event of an accidental firing of the weapon, or the 23 consequences that would result from an engaged target being missed. Clearly, the mere 24 presence of such weaponry would only add to the risks already faced by the communities 25 surrounding the plant, and is ultimately an untenable security solution. (BF-L-19) 26 27 Comment: Security of the spent/irradiated nuclear fuel pools at Browns Ferry is also another 28 issue that must be seriously addressed in evaluating TVAs application for license renewals for 29 the three reactors. Currently, the highly radioactive spent fuel from the Browns Ferry reactors 30 is stored in fuel pools that are located in buildings which could hardly be described as robust.
31 The pools are also situated several stories above ground-level. The vulnerability of these pools 32 to a 9/11-style terrorist attack is real, and it is substantial. (BF-L-20) 33 34 Comment: Neither the opening of Yucca Mountain nor the creation of an independent spent 35 fuel storage installation (ISFSI) onsite will reduce the dangerous vulnerability of the fuel pools at 36 Browns Ferry. Despite its ultimate destination, all nuclear fuel that is removed from the reactor 37 core must be moved, at least temporarily, to the fuel pools, to allow for cooling. This cooling of 38 the fuel takes several years. With or without the existence of an operating Yucca Mountain or 39 an ISFSI at Browns Ferry, there would always be a need for a spent fuel pool at the facility.
40 And without massive reinforcement and hardening these fuel pools are extremely vulnerable to 41 attack or sabotage. (BF-L-21) 42 43 Comment: In all likelihood, license renewal at Browns Ferry reactors would exacerbate existing 44 space issues regarding onsite spent fuel, and create 20 years worth of additional, dangerous 45 high-level waste, with no practicable or thorough means of securing it. (BF-L-24) 46 47
Scoping Comment Report June 2004 21 Browns Ferry, Units 1, 2, and 3 Comment: It should also be noted the less robust nature of the control room buildings, where a 1
successful attack could jeopardize proper operation and cooling of the reactor, and risk 2
meltdown. As long as these reactors are operating, this is yet another system that needs 3
extensive hardening and fortification, and added security overall. (BF-L-25) 4 5
Comment: The cost of such massive security measures would need to be covered fully by the 6
nuclear utilities, and not the ratepayers or taxpayers. It would be utterly irresponsible to renew 7
the licenses for Browns Ferry 1, 2 or 3 and force the costs of such safety and security upgrades 8
on the endangered public, especially if the upgrades themselves are inadequate or further 9
endanger the public. (BF-L-26) 10 11 Comment: Some folks, a long time ago suspected that nuclear plants and their materials would 12 be primary targets of terrorist. Im wondering how is that being handled now? How is this 13 transportation issue going to be addressed in the new age that were living in?(BF-F-4) 14 15 Response: NRC and other Federal agencies have heightened vigilance and implemented 16 initiatives to evaluate and respond to possible threats posed by terrorists, including the use of 17 aircraft against commercial nuclear power plants and independent spent fuel storage 18 installations (ISFSIs). Malevolent acts remain speculative and beyond the scope of a NEPA 19 review. NRC routinely assesses threats and other information provided to them by other Federal 20 agencies and sources. The NRC also ensures that licensees meet appropriate security levels.
21 The NRC will continue to focus on prevention of terrorist acts for all nuclear facilities and will not 22 focus on site-specific evaluations of speculative environmental impacts. While these are 23 legitimate matters of concern, they should continue to be addressed through the ongoing 24 regulatory process as a current and generic regulatory issue that affects all nuclear facilities and 25 many activities conducted at nuclear facilities. The NRC has taken a number of actions to 26 respond to the events of September 11, 2001, and plans to take additional measures. However, 27 the issue of security and risk from malevolent acts at nuclear power plants is not unique to 28 facilities that have requested a renewal to their license and, therefore, will not be addressed 29 within the scope of this Supplement. The comments did not provide significant, new information 30 and they do not pertain to the scope of license renewals set forth in 10 CFR Part 51 and Part 54, 31 therefore they will not be evaluated further.
32 33 Aging Management 34 35 Comment: I dont know tonight, if youre going to explain the technology that would enable 36 these plants to be considered safe for an additional 20 years. Of course, I dont claim that I 37 would understand everything about the technology, but I wondered are we going to have an 38 overview, to see why we should believe its okay for them to be extended another 20 years. (BF-39 F-2) 40 41 Response: The license renewal period is for up to 20 years. In revising the regulations that 42 address license renewal in 10 CFR 54, NRC determined that 20 years is appropriate to 43 demonstrate an adequate licensing basis. This time period offers reasonable assurance of 44 adequate protection assuming the current licensing basis is modified to account for age-related 45 safety issues to manage to adverse effects on systems, structures and components. The 46
Scoping Comment Report Browns Ferry, Unit 1, 2, and 3 22 June 2004 comment did not provide significant, new information and does pertain to the scope of license 1
renewals set forth in 10 CFR Part 51 and Part 54, therefore will not be evaluated further.
2 3
4 5
6 Comment: Not only does TVA propose to restart Unit 1, but also to increase its generating 7
capacity, despite its lack of actual operating experience. This decision is troubling given that 8
aging concerns of the nuclear power plant, including degradation, deterioration, and 9
embrittlement, are commonplace. (BF-L-5) 10 11 Comment: All of the reactors at Browns Ferry had an early history of many Reportable 12 Occurrences and SCRAMS that may have prematurely aged the structures of the containment 13 vessels of all three Browns Ferry Reactors...Large number of automatic shutdowns that occurred 14 on these reactors may have weakened the structures due to repeated thermal shocking of the 15 containment vessels. (BF-A-3) 16 17 Comment: The poor operating safety record of the Browns Ferry facility over the last 25 years, 18 and what the consequences of that may be to reducing the useful life of the reactors. (BF-A-6) 19 20 Comment: The potential for damaged structural integrity to one or all of the Browns Ferry 21 reactor containment vessels as a result of the large number of automatic reactor shutdowns 22 which may have occurred over the 25 (and eventually 40) year operating time. (BF-A-7) 23 24 Comment: This rapid cool-down of the hot reactor thermally shocks the reactor containment 25 structure as a result of the short time period over which the temperature of the whole structure 26 radically changes. These events cause stresses, strains, etc. to the reactor structure which 27 reportedly prematurely ages the reactor structure, reducing its strength and potentially reducing 28 its safe operating life. The reactor containment structure is what contains the nuclear reaction 29 This is violated and function and meltdown might occur. This wouldnt be such a significant 30 issue if the plant had a history or very few SCRAMS and a good operational safety record. I 31 found some of the data that I had recorded in 1980 about Reportable Occurrences at Browns 32 Ferry during that time and I have included the data below. This covers a period from 8-11 to 11-33 30 in 1988. Its almost four months. There were 23 of these occurrences in Reactor One, 21 in 34 Reactor Two, and 22 in Reactor Three. I dont know how many of these Reportable 35 Occurrences were SCRAMS, but what my vague memory recalls is that many of these were 36 SCRAMS. The data shows that 66 reportable events occurred in less than four months, 37 averaging about 16 per month or one every other day. This is not a good safety record for a 38 nuclear operating facility. If any significant percentage of these events were SCRAMS, this 39 would indicated that all reactors have experienced many SCRAMS over their 40 year life. BF-A-8 40 41 Comment: I asked them to do a lot of things but at least to report on the -- they should 42 investigate and report to the public about a detailed study of the SCRAMS, Reportable 43 Occurrences and/or safety violations which have happened to each reactor individually including 44 significance of these events relative to safe operating lifetime. (BF-A-9) 45 46 Comment: The difficulties are known to involve dangerous risk factors such as cracks in 47
Scoping Comment Report June 2004 23 Browns Ferry, Units 1, 2, and 3 emergency cooling systems, inappropriate cable wiring, and reactor-vessel 1
embrittlement and cracking. It seems quite inappropriate, therefore, to consider 2
extending an operations license for a reactor shut down so long ago, for such 3
problems. (BF-N-10) 4 5
Response: NRCs ongoing safety program focuses on prevention of safety problems so that 6
potential issues like aging and thermal shock do not lead to accidents. To the extent 7
that the comments pertaining to safety of equipment and aging are within the scope of license 8
renewal, these issues will be addressed during the parallel safety analysis review performed 9
under 10 CFR Part 54. Operational safety issues are outside the scope of 10 CFR Part 51 and 10 will not be evaluated further in this SEIS. The comments provide no new information and, 11 therefore, will not be evaluated further in the context of the environmental review. However, the 12 comments will be forwarded to the project manager for the license renewal safety review for 13 consideration.
14 15 Comment: TVA should be required to determine the structural soundness of the reactor 16 containment vessels using a non-invasive technique, if such a technique exists. (BF-A-10) 17 18 Comment: Im also not a nuclear engineer or anything. So what I contend is, if we had a 19 meltdown, there would be quite a significant environmental impact. (BF-A-12) 20 21 Comment: Obviously the economic advantages to extending the reactors life are huge, but the 22 magnitude of the disaster that would occur if a Meltdown" happened is beyond measure or 23 determination and if there is any significant risk of this then the reactor life should not be 24 extended. (BF-A-15) 25 26 Comment: TVA needs to do detailed investigations into the issue of the structural soundness of 27 each Browns Ferry reactor containment vessel prior to considering extending the life of these 28 units by 50%. (BF-A-14) 29 30 Response: NRCs ongoing safety program focuses on prevention of safety problems so that 31 potential issues like aging and thermal shock do not lead to accidents and subsequent 32 environmental impacts. The intent of the NRCs safety review is to determine if the licensee has 33 adequately demonstrated that the effects of aging will not adversely affect any systems, 34 structures, or components identified in 10 CFR 54.4. The safety review process includes site 35 inspections to assess whether the applicant has implemented and complied with the regulations 36 for license renewal. The inspection teams comprise technical, program, and operational experts 37 from the NRC and its consultants. Teams of specialized inspectors travel to the reactor site at 38 least twice and sometimes three times to verify whether the effects of aging will be managed 39 such that the plant can be operated during the period of extended operation without undue risk 40 to the health and safety of the public. The review results in a publicly available safety evaluation 41 report available online at http://nrc.gov. The comments provide no new information and, 42 therefore, will not be evaluated further in the context of the environmental review. However, the 43 comments will be forwarded to the project manager for the license renewal safety review for 44 consideration.
45 46 47
Scoping Comment Report Browns Ferry, Unit 1, 2, and 3 24 June 2004 Comment: I noticed when you were discussing the licensing for the additional 20 years. You 1
made a distinction between active systems that are continually inspected. I think they were 2
referred to as passive systems. I think it was your talk. Could you describe, and I assume those 3
will be the elements that will have the additional scrutiny, what are some of those things? (BF-G-4 4) 5 6
Response: Various structures and components are inspected as part of the license renewal 7
process. These include passive structures and components that perform an intended function 8
without moving parts or without a change in configuration, change in properties, or change of 9
state. These may include structures and components which are classified as inherently reliable 10 under the maintenance rule, or structures and components for which aging degradation is not 11 readily monitored. In addition, inspections long-lived structures and components 12 which are not subject to replacement based on a qualified life or specified time period are 13 required for license renewal. For further information on the requirements for license renewal 14 inspections, please refer to Inspection Procedure 71002, "License Renewal Inspection", which 15 can be downloaded from the NRC website at http://www.nrc.gov.
16 17 Comment: I guess, you know the aging. Everyone today would probably look at the Davis -- I 18 dont know how to say it -- Bessie as a -- well, an aging problem that might occur in a plant.
19 I guess I have one quick specific question to our inspectors is, I didnt see an inspection report 20 where that issue for the Browns Ferry Plant on the web site. Was that because its not subject 21 to that problem? Or I wasnt looking in the right spot? (BF-G-2) 22 23 Response: The NRC heightened its regulatory oversight of the Davis-Besse Nuclear Power 24 Station due to the discoveries of reactor pressure vessel head degradation. The Davis-Besse 25 Nuclear Power Station is a Pressurized Water Reactor (PWR). The degradation of the reactor 26 pressure vessel (RPV) head at Davis-Besse appears to be related to boric acid. Other factors 27 contributing to the degradation might include the environment of the RPV head during both 28 operating and shutdown conditions (e.g., wet/dry), the duration for which the RPV head is 29 exposed to boric acid, and the source of the boric acid (e.g., leakage from the CRDM nozzle or 30 from sources above the RPV head such as CRDM flanges). Browns Ferry has Boiling Water 31 Reactors (BWR). BWRs do not use boric acid, thus they dont have the accelerated corrosion 32 mechanism. In addition, the configuration of the reactor heads at Browns Ferry are a different 33 design than the reactor head at Davis-Besse. The problems experienced at Davis-Besse 34 appear to be confined to pressurized water reactors that use boric acid. The comment provides 35 no new information and, therefore, will not be evaluated further in the context of the 36 environmental review.
37 38 Comment: I know that in aging issues for airplanes and things like that theres the concept of 39 the fleet leader or something that has been operating the longest, as being an indicator of what 40 problems other members of the fleet will have. I was wondering if anyone here can tell me if 41 there are reactors of the same design as Units 1, 2 and 3 that are substantially older and could 42 be considered a fleet leader for the purpose of aging. In other words, are 1, 2, and 3 the oldest 43 of their design or are they somewhere in the middle, or are they pretty much unique? (BF-G-3) 44 45 Response: NRC has applied the knowledge from lessons learned to improve the safety review 46 for license renewal. NUREG-1801, Generic Aging Lessons Learned (GALL) contains 47
Scoping Comment Report June 2004 25 Browns Ferry, Units 1, 2, and 3 recommendations on specific areas for which generic existing programs should be augmented 1
for license renewal and documents the technical basis for each such determination. This report 2
was based on information in over 500 documents: Nuclear Plant Aging Research (NPAR) 3 program reports sponsored by the Office of Nuclear Regulatory Research, Nuclear Management 4
and Resources Council (NUMARC, now NEI) industry reports addressing license renewal, 5
licensee event reports (LERs), information notices, generic letters, bulletins, and reports 6
provided by the Union of Concerned Scientists (UCS) in a letter dated May 5, 2000. The GALL 7
report provides a technical basis for crediting existing plant programs and recommending areas 8
for program augmentation and further evaluation. The comment provides no new information 9
and, therefore, will not be evaluated further in the context of the environmental review.
10 11 12 MOX Fuel 13 14 Comment: Whenever youre doing your EIS, will you address in that EIS that TVA is going to 15 use a new type of fuel, downblending from nuclear weapons grade material? Will that come into 16 the mix? And if so, will you address in the EIS how that mix will change as result of the new 17 fuel? (BF-C-2) 18 19 Comment: In an EIS how can you -- that this is not a secret that what TVAs doing here. To 20 come to Browns Ferry with this new theory on fuel, and Im wondering why it wouldnt be an 21 issue for an EIS, since its going to change the make-up of what you dump into the river through 22 waste water...And if youre not addressing it, why not? (BF-C-3) 23 24 Comment: The whole plan here is to provide TVA with an outlet for nuclear weapons materials 25 made into fuel for this plant. (BF-C-10) 26 27 Comment: Has anyone said out loud that the French will carry large amounts of American 28 taxpayers money back home to France from TVA and the US government as they "work" on this 29 process? Does anyone know about the millions of TVA dollars that TVA is spending up at 30 Erwin, Tennessee at Nuclear Fuel Services so that TVA and the french group, Framatome can 31 get cozy in bed together? (BF-C-11) 32 33 Comment: Will the NRC analyze the effects of burning nuclear weapons materials at this plant.
34 Has the NRC got out their pencils and wrote up some pie-in-the-sky answer for an untried, 35 untested process TVA will be using in these units? And before the boys at TVA and the 36 Frenchies get their boxers in was, the process has not been tested in the US. (BF-C-12) 37 38 Comment: It will cost the ratepayers enormous amounts of money for the Erwin, Tennessee 39 connection and the French nuclear industry to collect money from TVA while the NRC plays the 40 fiddle and the TVA money burns. (BF-C-13) 41 42 Comment: In 1995 TVAs public relations people publicly stated that if they wanted to burn this 43 type fuel in TVA reactors then "an Environmental Impact Statement would have to be done."
44 Does this mean that you, NRC, and you, TVA, recognize that a full EIS must be produced prior 45 to a license extension? (BF-C-15) 46 47
Scoping Comment Report Browns Ferry, Unit 1, 2, and 3 26 June 2004 Response: The NRC staff has determined that MOX fuel issues are outside the scope of 1
license renewal at Browns Ferry. The use of MOX fuel will be addressed in a separate 2
environmental review if and when an application to use MOX fuel at Browns Ferry is received.
3 The comments provide no new relevant information and, therefore, will not be evaluated further 4
under this SEIS.
5 6
Decommissioning 7
8 Comment: The NRC should evaluate the decommissioning trust fund balances for TVAs 9
Browns Ferry units and how decommissioning will be impacted by extending the operating 10 licenses of all three units...According to a General Accounting Office (GAO) report in 2003, all of 11 TVAs nuclear power plants were found to be below the benchmark of sufficiency for 12 decommissioning trust fund balanceswith the Browns Ferry units being among nuclear plants 13 with the poorest decommissioning fund status. This is extremely problematic. (BF-L-7) 14 15 Comment: The NRC should also ensure that sufficient decommissioning funds would be in 16 place in order to protect utility ratepayers and taxpayers. (BF-L-8) 17 18 Comment: Extending the license for another 20 years at any nuclear power production facility 19 in the US is simply a way for the industry to delay the fact that decommissioning funds are not 20 available for these plants. (BF-C-5) 21 22 Comment: If TVA had the money to decommission Unit One it would already be a done deal.
23 In Fifteen years to sit in "Administrative Hold." Too bad that no such action is permitted in NRC 24 rules. But rules don't count here do they? (BF-C-6) 25 26 Response: Regulations are provided in 10 CFR 50.75 that establish the requirements for 27 indicating to NRC how a licensee will provide reasonable assurance that funds will be available 28 for the decommissioning process. The cost of renewal versus decommissioning is a business 29 decision that NRC does not control. The Commission has determined these issues are outside 30 the scope of the environmental analysis for license renewal.
31 32 Restart of Browns Ferry, Unit 1 33 34 Comment: Finally, we must comment on the unprecedented attempt by TVA and the NRC to 35 simultaneously restart Browns Ferry 1 (after nearly 20 years in the non-defined regulatory status 36 of administrative hold) and extend its operating license for 20 additional years. Because 37 Browns Ferry should rightly have had its operating license revoked after it was shut down in 38 1985 due to a failure at [Browns Ferry Nuclear Plant] to consistently maintain a documented 39 design basis and to control the plants configuration in accord with that basis, the plant should 40 now be required to go through NRCs license application process, just as any new plant would.
41 Twisting NRCs administrative process for restarting problem plants on temporary shutdown, 42 Inspection Manual Chapter 0350, to resuscitate a plant that has been all but left to crumble for 43 nearly 20 years is an approach thats just too convenient for TVA. (BF-L-28) 44 45 Comment: To ensure optimal safety at the plant, TVA should be required to bring everything to 46 plant up to current design technical specifications (as described in over 1,200 letters that NRC 47
Scoping Comment Report June 2004 27 Browns Ferry, Units 1, 2, and 3 has issued to licensees since Browns Ferrys shutdown), and then apply for a new license. If, 1
after some period of operation without disaster following a restart, TVA could then apply for a 2
license extension. (BF-L-29) 3 4
Comment: The NRC should, instead, require full remediation of all technical and 5
design problems which have placed safety operations at risk in the past. (BF-N-11) 6 7
Comment: To attempt to do both simultaneously only further bolsters the case that the NRC is 8
captured by the industry it is charged with regulating, and it is once again greasing the skids for 9
a licensee to just coast through substantive, safety-related problems without serious oversight 10 and regulation of their activities. (BF-L-30) 11 12 Comment: I have major concerns concerning the restart of the Browns Ferry Reactor that has 13 been mothballed for so long. (BF-A-2) 14 15 Comment: With letter of May 14, 2003 we had urged of the Board of Directors of the TVA a 16 decision against the restarting of Unit 1 of the Browns Ferry plant. (BF-N-1) 17 18 Comment: The Agency should allow provisional re-start of Unit 1 under its current license, at 19 best, or under new-license standards. (BF-N-12) 20 21 Comment: Public protection would seem to demand that the NRC closely monitor and evaluate 22 the operation of Unit 1 after re-start and grant license extension only after its performance has 23 proved safe. (BF-N-13) 24 25 Response: Browns Ferry is currently in the process of restarting Unit 1. This action is occurring 26 under the current operating license. The restart of this unit does not require a separate licensing 27 action and is not part of license renewal, however Unit 1 must meet the current licensing 28 requirements prior to restart. Restart of Unit 1 is outside the scope of the environmental review 29 for license renewal.
30 31 Cost-Benefit Analysis 32 33 Comment: Tennessee Valley Authority (TVA) has a congressionally mandated debt ceiling of 34
$30 billion. TVA is currently carrying a debt of approximately $25 billion along with other 35 obligations that could be construed as debt (e.g. leaseback contracts, pre-purchase of electricity, 36 etc.) that are between $3-5 billion, bringing them very close to exceeding that debt-ceiling. With 37 estimates of $1.8 billion for the restart of Browns Ferry Unit 1, TVA is close to meeting or 38 exceeding the $30 billion limit. The Nuclear Regulatory Commission (NRC) should thoroughly 39 review the economic situation at TVA along with the estimated cost projections of relicensing the 40 three Browns Ferry nuclear reactors, along with other projected costs associated with other 41 projects. (BF-L-1) 42 43 Comment: The fiscal prudence of TVAs expenditure of at least $2 billion estimated to bring 44 Unit 2 back from mothball status should be weighed against longer-term economic, marketing, 45 and social advantages of investment in energy sources of the future instead of last centurys.
46 (BF-N-7) 47
Scoping Comment Report Browns Ferry, Unit 1, 2, and 3 28 June 2004 Response: The cost of relicensing, in addition to TVAs standing debt, is outside the scope of 1
the environmental review. The decision to apply for relicensing is a business decision that NRC 2
does not control. The comment provides no new relevant information and, therefore, will not be 3
evaluated further under this SEIS.
4 5
- 14. Request for Information 6
7 Comment: I wanted to know what the proposed dates were for decommissioning the units, and 8
when they were originally built. (BF-F-1) 9 10 Response: Construction permits were granted in 1967 and 1968; construction was completed in 11 1973 (Unit 1), 1974 (Unit 2), and 1976 (Unit 3). There is no specified decommissioning date.
12 Nuclear power plants cease operation for a variety of reasons. The NRC grants a license for a 13 period of 40 years. At the end of the license period, the licencee can seek to renew the 14 operating license of the plant for another 20 years, or can cease operations before the 40-year 15 licensing period has been completed. Reasons for the decision to decommission can be 16 financial or NRC can order the licensee to cease operation for safety reasons. The comment 17 provides no new relevant information and, therefore, will not be evaluated further under this 18 SEIS.
19 20 Comment: Who are the inspectors that look into the different components that may be 21 vulnerable to aging? And are those reports made public? (BF-F-3) 22 23 Response: Inspections are conducted by NRC inspectors. Routine operational inspections of 24 the plants are conducted daily by four onsite NRC inspectors. In addition, the license renewal 25 inspection program consists of three separate inspections to support the decision on an 26 application for license renewal. At a minimum, a scoping inspection and aging management 27 inspection are conducted. An optional third inspection will be performed, if needed, to verify 28 items identified by the staff, Advisory Committee on Reactor Safeguards, and regional 29 administrator that are needed to close open items from the technical review of the application or 30 previous inspections. This final inspection would be performed prior to the staff's 31 recommendation regarding the approval or disapproval of the application. License renewal 32 inspections are conducted by inspectors from the NRC office in Atlanta and from NRC 33 headquarters in Washington D.C. The inspection reports will be available to the public through 34 the NRC's Public Document Room in Rockville, Maryland or from the NRCs Electronic Reading 35 Room available online at http://www.nrc.gov/reading-rm.html, before the Commission makes its 36 decision.
37 38 Comment: Theyre issuing this in December?(BF-A-1) 39 40 Response: The SEIS will be issued to the public on December 17, 2004. The public meeting to 41 discuss comments on the SEIS is scheduled for January 20, 2005. The comment provides no 42 new relevant information and, therefore, will not be evaluated further under this SEIS.
43 44 Comment: I want to know if the ACRS may -- that will come here to the site, will it be open to 45 the public and will we be notified of it?...But do the regs require you to have an on-site meeting 46 at some point before the ACRS? (BF-C-1) 47
Scoping Comment Report June 2004 29 Browns Ferry, Units 1, 2, and 3 Response: The Advisory Committee on Reactor Safeguards (ACRS) is independent of the 1
NRC staff and reports directly to the Commission, which appoints its members. During the 2
license renewal process the ACRS acts as an independent third-party oversight group that 3
reviews and makes recommendations on renewal applications to the Commission before the 4
Commission rules on whether the licenses should be renewed. ACRS reports are made part of 5
the record of the application and made available to the public, except to the extent that security 6
classification prevents disclosure. Most committee meetings are open to the public and any 7
member of the public may request an opportunity to make an oral statement during the 8
committee meeting. These meetings are held in a central location, which may or may not be 9
onsite. The comment provides no new relevant information and, therefore, will not be evaluated 10 further under this SEIS.
11 12 Comment: Would you ask him to specify the exact document on this report? [MR. CAMERON:
13 The question is, the annual report on emissions, that the off site dose report. Mike, can you give 14 that to -- unless you know right off the top of your head]. (BF-C-4) 15 16 Response: The NRC publishs two annual reports for Browns Ferry regarding environmental 17 monitoring and environmental effluents. The Annual Radiological Environmental Operating 18 Report (AREOR) and the Annual Radiological Effluent Release (ARER) Report are available 19 to the public through the NRC's Public Document Room in Rockville, Maryland or from the 20 NRCs Electronic Reading Room available online at http://www.nrc.gov/reading-rm.html.
21