ML103220015

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Supplemental Scoping Summary Report Regarding Make-Up Pond C for the William States Lee III Nuclear Station, Units 1 and 2, Environmental Review
ML103220015
Person / Time
Site: Lee  Duke Energy icon.png
Issue date: 12/22/2010
From: Sarah Lopas
NRC/NRO/DSER/RAP3
To: Robert Schaaf
NRC/NRO/DSER/RAP3
S Lopas, NRO/DSER/RAP3 301-415-1147
References
Download: ML103220015 (83)


Text

December 22, 2010 MEMORANDUM TO: Robert G. Schaaf, Chief Environmental Projects Branch 3 Division of Site and Environmental Reviews Office of New Reactors FROM: Sarah L. Lopas, Project Manager /RA/

Environmental Projects Branch 3 Division of Site and Environmental Reviews Office of New Reactors

SUBJECT:

SUMMARY

REPORT FOR THE SUPPLEMENTAL ENVIRONMENTAL SCOPING PROCESS FOR THE WILLIAM STATES LEE III NUCLEAR STATION, UNITS 1 AND 2 COMBINED LICENSE APPLICATION From May 24, 2010, through July 2, 2010, the U.S. Nuclear Regulatory Commission (NRC) staff conducted a supplemental scoping process to determine the scope of the NRCs review of a supplement to the environmental report submitted by Duke Energy Carolinas, LLC for the combined licenses application for the William States Lee III Nuclear Station, Units 1 and 2 (Lee Nuclear Station). As part of the supplemental scoping process, the NRC staff held a public scoping meeting in Gaffney, South Carolina, on June 17, 2010, to solicit public input regarding the scope of the environmental review as it pertains to the addition of Make-Up Pond C, a proposed off-site reservoir that would serve as a source of supplemental cooling water for Lee Nuclear Station.

The NRC staff has prepared the enclosed supplemental scoping summary report, which identifies comments either received at the public scoping meeting, or by letter or electronic mail, and provides responses to those comments. In accordance with Title 10 of the Code of Federal Regulations, Part 51.29(b), all participants of the scoping process (who have provided mailing information) will be provided with a copy of the scoping summary report. The transcript of the scoping meeting is publicly available in the NRC Agencywide Documents and Management System under Accession Number ML101760446.

CONTACT: Sarah L. Lopas, NRO/DSER 301-415-1147

R. Schaaf The next step in the environmental review process is the issuance of a draft environmental impact statement (DEIS), scheduled for July 2011. Notice of the availability of the DEIS and the procedures for providing comments will be published in an upcoming Federal Register Notice.

Docket Nos.: 52-018 and 52-019

Enclosure:

Supplemental Scoping Summary Report cc: See next page

ML103220015 NRO-002 OFFICE NRO/DSER/RAP3:PM NRO/DSER/RAP3:LA OGC NRO/DSER/RAP3:BC NAME SLopas MBrown KRoach RSchaaf /DEP for/

DATE 9/23/2010 9/29/2010 10/14/2010 12/ 22 /2010 Environmental Impact Statement Supplemental Scoping Process Regarding Make-Up Pond C Summary Report William States Lee III Nuclear Station, Units 1 and 2 Combined Licenses Cherokee County, South Carolina December 2010 U.S. Nuclear Regulatory Commission Rockville, Maryland

Introduction By letter dated December 12, 2007, the U.S. Nuclear Regulatory Commission (NRC) received an application from Duke Energy Carolinas, LLC (Duke) for combined construction permits and operating licenses (combined licenses or COLs) for the William States Lee III Nuclear Station, Units 1 and 2 (Lee Nuclear Station). The proposed site for the Lee Nuclear Station is in the eastern portion of Cherokee County in north-central South Carolina, approximately 8 miles southeast of Gaffney, on the west side of the Broad River just upstream of the Ninety-Nine Islands Hydroelectric Plant.

As part of the COL application, Duke submitted an Environmental Report (ER) prepared in accordance with the requirements of Title 10 of the Code of Federal Regulations (10 CFR)

Part 51, the NRCs regulations that implement the National Environmental Policy Act of 1969, as amended (NEPA). The NRC also follows Council on Environmental Quality NEPA regulations to the extent set forth in 10 CFR 51.10 and 10 CFR 51.14(b). NRC regulations related to the environmental review of COL applications are contained in 10 CFR Part 51 and 10 CFR 52, Subpart C.

The U.S. Army Corps of Engineers (USACE), Charleston District, is participating in the NEPA process as a cooperating agency. The Memorandum of Understanding between USACE and NRC on environmental reviews related to the issuance of COLs can be found at the NRC Agencywide Documents Access and Management System (ADAMS), Accession No. ML082540354. The request for cooperation on the Lee Nuclear Station environmental review, dated March 30, 2009, can be found at Accession No. ML090700384.

ADAMS is accessible at http://www.nrc.gov/reading-rm/adams.html. Members of the public who do not have access to ADAMS or who encounter problems in accessing the documents located in ADAMS should contact the NRC Public Document Room reference staff by telephone at 1-800-397-4209 or 301-415-4737, or via e-mail at pdr@nrc.gov.

Duke submitted Revision 1 of the Lee Nuclear Station ER on March 30, 2009, and a supplement to Revision 1 of the ER (Supplemental ER) on September 24, 2009. The revised ER describes the potential environmental impacts of construction and operation of two nuclear units at the Lee Nuclear Station site. The supplemental ER describes the environmental impacts of Dukes plan to construct and operate an additional offsite reservoir (Make-Up Pond C) as a source of supplemental cooling water for the proposed Lee Nuclear Station. Both ERs include an evaluation of the environmental consequences of alternatives, including the proposed action, and any mitigating actions that could be taken. Revision 1 of the ER and the Supplemental ER 1

are available in ADAMS under Accession Nos. ML090990348 and ML092810308, respectively.

Both are also available on the Internet at http://www.nrc.gov/reactors/new-reactors/col/lee.html.

The NRC and USACE staff are preparing an environmental impact statement (EIS) that will document the environmental review of the Duke COL application. The proposed action being evaluated is NRC approval of the Duke application to build and operate two new baseload nuclear power generation facilitiesLee Nuclear Station, Units 1 and 2. The EIS will include an evaluation of the environmental impacts of the proposed action, the environmental impacts of alternatives to the proposed action, including the no-action alternative; alternatives related to the facility cooling and circulating water systems (including Make-Up Pond C); and alternatives available for reducing or avoiding adverse environmental effects. The EIS will also address alternative energy options. Finally, the EIS will include an evaluation of alternative sites to determine if there is an obviously superior alternative to the proposed site.

NRC staff is also conducting a safety review of the Duke COL application in accordance with NUREG-0800, Standard Review Plan for the Review of Safety Analysis Reports for Nuclear Power Plants: LWR Edition, and NUREG-1555, Standard Review Plans for Environmental Reviews for Nuclear Power Plants.

The NRC conducted a public scoping process for the original ER from March 20 through May 20, 2008. The scoping summary report for the original Lee Nuclear Station scoping process is available in ADAMS at Accession No. ML082390635. On May 24, 2010, in accordance with 10 CFR 51.26, the NRC and the USACE initiated an additional opportunity for the public to participate in the scoping process related to Make-Up Pond C, as described in the supplemental to the ER, by publishing a Notice of Intent to Conduct a Supplemental Scoping Process for the Supplement to the Environmental Report in the Federal Register (75 FR 28822). Through the notice, the NRC also invited Duke; Federal, Tribal, State, and local government agencies; local organizations; and the public to provide comments on the supplemental information regarding Make-Up Pond C that was not available during the initial scoping process in 2008. The public participated in the scoping process by providing oral comments at the public meeting on June 17, 2010, and/or by submitting written comments to the NRC by July 2, 2010. Comments received after July 2, 2010, were included as practicable.

The scoping process provided an opportunity for public participation to identify issues to be addressed in the EIS and highlight public concerns and issues related to Make-Up Pond C. The Notice of Intent (75 FR 28822) identified the following objectives of the scoping process:

  • Determine how the supplemental information on Make-Up Pond C impacts the EIS scope and identify significant issues regarding Make-Up Pond C to be analyzed in depth
  • Identify and eliminate from detailed study those issues that are peripheral or that are not significant as they pertain to Make-Up Pond C 2
  • Identify any environmental assessments and other EISs that are being prepared or will be prepared that are related to the supplement information on Make-Up Pond C, but not part of the EIS scope being considered
  • Identify other environmental review and consultation requirements related to the supplemental information on Make-Up Pond C and the USACE
  • Identify parties consulting with the NRC and the USACE under the National Historic Preservation Act of 1966, as set forth in 36 CFR 800.8(c)(1)(i)
  • Identify any cooperating agencies and, as appropriate, allocate assignments for preparation and schedules for completing the EIS to the NRC, USACE, and any additional cooperating agencies
  • Describe how the EIS preparation will include the supplemental information on Make-Up Pond C and identify any contractor assistance to be used.

The public scoping meeting on the supplemental to the ER was held at the Restoration Church International in Gaffney, South Carolina, on June 17, 2010. The NRC announced the meeting by issuing press releases and publishing notices in local newspapers in South Carolina and North Carolina, including The Gaffney Ledger, Spartanburg Herald-Journal, York Enquirer-Herald, The State (Columbia), The Blacksburg Times, Charlotte Observer, and the Gaston Gazette. Approximately 100 members of the public attended the evening scoping meeting. The scoping meeting began with NRC and USACE staff members providing a brief overview of the review process for COL applications and the NEPA process, followed by a description of the proposed Make-Up Pond C. After the prepared statements, the meeting was opened for public comments. Thirty-four (34) scoping meeting attendees provided either written statements and/or oral comments that were recorded and transcribed by a certified court reporter.

At the conclusion of the scoping period, NRC staff reviewed the transcripts of the scoping meeting and all written material received, and identified individual comments. The meeting summary, issued on July 2, 2010, and the transcript of the meeting are available electronically for public inspection in the NRC Public Document Room or from the Publicly Available Records component of ADAMS under Accession Nos. ML101800423 and ML101760446, respectively.

In addition, 14 documents were submitted at the scoping meeting, including 6 letters and 17 e-mails received during the scoping period. All comments received orally during the scoping meeting or in writing during or after the meeting were considered by NRC staff.

Table 1 identifies the individuals providing comments in alphabetical order, their affiliation if provided, and the ADAMS accession number that can be used to locate the correspondence.

Accession numbers indicate the location of the written comments in ADAMS.

3

Comments were consolidated and categorized according to topic within the proposed EIS or according to the general topic if outside the scope of the EIS. Comments with similar specific objectives were combined to capture the common essential issues that had been raised in the source comments. Once comments were grouped according to subject area, NRC staff determined the appropriate response for the comment. The comment categories are listed in Table 2 in the order presented in this document.

Table 3 lists the comment categories in alphabetical order, with commenter names and correspondence identification (ID) number (document number-comment number) for each comment identified for each category. The rest of this document presents the comments with the NRC staff responses organized by topic category.

Table 1. Individuals Providing Comments During the Comment Period Comment Source and Commenter Affiliation (if stated) ADAMS Accession # Correspondence ID Arnason, Deb Letter (ML101740338) 0010 Meeting Transcript 0001-6 (ML101760446)

Barczak, Sara Southern Alliance for Letter (ML101900426) 0030 Clean Energy Barnett, Barbara A. Four Seasons Sierra Email (ML101750764) 0021 Committee of Henderson Co. NC League of Women Voters Email (ML101750764) 0021 of Henderson Co., NC Meeting Transcript Comments the same as (ML101760446) Correspondence ID #0021 Bliss, Rachel Letter (ML101740335) 0009 Meeting Transcript 0001-20 (ML101760446)

Boger, Paul Greater York Chamber of Meeting Transcript 0001-13 Commerce (ML101760446)

Breckheimer, Steve Email (ML102290307) 0037 Brooks, Tim Nestle Prepared Foods Meeting Transcript 0001-8 (ML101760446)

Clements, Tom Friends of the Earth Email (ML092680877) 0002 Meeting Transcript 0001-31 (ML101760446)

Cook, Jim Cherokee County Meeting Transcript 0001-26 Development Board (ML101760446) 4

Table 1. (contd)

Comment Source and Commenter Affiliation (if stated) ADAMS Accession # Correspondence ID Corbett, Susan Chair, South Carolina Meeting Transcript 0001-30 Sierra Club (ML101760446)

Craig, Anne Letter (ML101740334) 0008 Meeting Transcript Comments the same as (ML101760446) Correspondence ID #0008 Cross, John URS JSCC Project Email (ML101740616) 0026 Dolan, Bryan Duke Energy Meeting Transcript 0001-5 (ML101760446)

Drake, Joan W. Email (ML101760352) 0023 Fair, Gabriel Students for Meeting Transcript 0001-22 Environmental Action (ML101760446)

Forrester, Mike State Representative Meeting Transcript 0001-3 District 34 (ML101760446)

Gregg, Ben South Carolina Wildlife Letter (ML101820646) 0032 Federation Haire, Wenonah G. Catawba Indian Nation Letter (ML102110494) 0039 Hale, Kendall Email (ML101720639) 0003 Hallock, Judith Letter (ML102030057) 0034 Hancock, Mandy Southern Alliance for Letter (ML101740336) 0011 Clean Energy Letter (ML101820355) 0011 Letter (ML101820355) 0030 Letter (ML101900426) 0030 Meeting Transcript Comments the same as (ML101760446) Correspondence ID #0011 Hansborough, Letter (ML101890551) 0028 Hilbert J.

Hicks, Katie Clean Water for North Letter (ML101740343) 0017 Carolina Meeting Transcript Comments the same as (ML101760446) Correspondence ID #0017 Hildebrandt, Lorena Meeting Transcript 0001-23 (ML101760446)

Hogue, David Mayor of Blacksburg, SC Meeting Transcript 0001-4 (ML101760446)

Hopper, Sara South Carolina Meeting Transcript 0001-14 Manufacturers Alliance (ML101760446) 5

Table 1. (contd)

Comment Source and Commenter Affiliation (if stated) ADAMS Accession # Correspondence ID Howarth, Robert F. Western N. Carolina Letter (ML101740337) 0012 Physicians for Social Responsibility Meeting Transcript 0001-27 (ML101760446)

Ledford, Judy and Email (ML101750766) 0022 Glenn LeVander, Valerie Global Warming Task Letter (ML101740342) 0016 Force of Henderson Co.

NC Meeting Transcript Comments the same as (ML101760446) Correspondence ID #0016 Littlejohn, Lanny F. South Carolina Letter (ML101740332) 0007 McCall, Pat Email (ML101720649) 0018 Mixon, Michael C. Shaw Power Group Email (ML101740613) 0027 Mominee, DBNPS Chemistry Email (ML101720644) 0019 Katharine N.

Moss, Dennis Carroll South Carolina Letter (ML101740333) 0007 Meeting Transcript 0001-1 (ML101760446)

Moss, Steve South Carolina Letter (ML101740331) 0007 Meeting Transcript 0001-2 (ML101760446)

Olsen, Mary Southeast Office of Letter (ML101740340) 0014 Nuclear Information and Resource Service Meeting Transcript 0001-15 (ML101760446)

Pace, Eric Carolina Chapter of the Meeting Transcript 0001-21 N. American Youth (ML101760446)

Generation in Nuclear Peeler, Harvey S. South Carolina Letter (ML101740344) 0007 Pennington, Lee Letter (ML102030058) 0033 Richards, Kitty- Meeting Transcript 0001-19 Katherine (ML101760446)

Richardson, Don Western North Carolina Letter (ML101740341) 0015 Physicians for Social Responsibility Meeting Transcript 0001-25 (ML101760446) 6

Table 1. (contd)

Comment Source and Commenter Affiliation (if stated) ADAMS Accession # Correspondence ID Robbs, Kayla Cherokee Co. Chamber Meeting Transcript 0001-18 of Commerce (ML101760446)

Scott, Darrell South Carolina Chamber Meeting Transcript 0001-10 of Commerce (ML101760446)

Smith, Brian Email (ML101750767) 0024 Smith, Clyde E. Cleveland County Water Letter (ML102070103) 0035 (Butch)

Swinton, D.C. Palmetto Environmental Meeting Transcript 0001-24 Action Coalition (ML101760446)

Thomas, Bill Pisgah Group, NC Sierra Email (ML101810248) 0029 Club Thomas, Ellen Email (ML102290314) 0038 Letter (ML101740339) 0013 Thrift, Debbie Cliffside Modernization Email (ML101740618) 0025 Project Vejdani, Vivianne SC Department of Letter (ML102160393) 0036 Natural Resources Ware, Steve Nestle Prepared Foods Meeting Transcript 0001-7 (ML101760446)

Williams, Debralee Meeting Transcript 0001-28 (ML101760446)

Wilson, Caroline D. South Carolina Dept. of Email (ML101720651) 0020 Archives and History Zeller, Lou Blue Ridge Meeting Transcript 0001-9 Environmental Defense (ML101760446)

League 7

Table 2. Comment Categories

1. Comments Concerning Process - COL
2. Comments Concerning Process - NEPA
3. Comments Concerning Site Layout and Design
4. Comments Concerning Land Use - Site and Vicinity
5. Comments Concerning Hydrology - Surface Water
6. Comments Concerning Hydrology - Groundwater
7. Comments Concerning Ecology - Terrestrial
8. Comments Concerning Ecology - Aquatic
9. Comments Concerning Socioeconomics
10. Comments Concerning Historic and Cultural Resources
11. Comments Concerning Health - Radiological
12. Comments Concerning Accidents - Severe
13. Comments Concerning the Uranium Fuel Cycle
14. Comments Concerning Transportation
15. Comments Concerning Decommissioning
16. Comments Concerning Cumulative Impacts
17. Comments Concerning the Need for Power
18. Comments Concerning Alternatives - Energy
19. Comments Concerning Alternatives - System Design
20. Comments Concerning Benefit-Cost Balance
21. General Comments in Support of the Licensing Action
22. General Comments in Support of the Licensing Process
23. General Comments in Support of Nuclear Power
24. General Comments in Support of the Applicant
25. General Comments in Opposition to the Licensing Action
26. General Comments in Opposition to Nuclear Power
27. Comments Concerning Issues Outside Scope - Emergency Preparedness
28. Comments Concerning Issues Outside Scope - Miscellaneous
29. Comments Concerning Issues Outside Scope - NRC Oversight
30. Comments Concerning Issues Outside Scope - Safety
31. Comments Concerning Issues Outside Scope - Security and Terrorism 8

Table 3. Comment Categories Comment Category Commenter (Comment ID)

Accidents-Severe

  • Corbett, Susan (0001-30-10)
  • Hallock, Judith (0034-3)
  • Richards, Kitty-Katherine (0001-19-3)

Alternatives-Energy

  • Arnason, Deb (0001-6-1) (0010-7)
  • Barczak, Sara (0030-2) (0030-3) (0030-8)
  • Barnett, Barbara A. (0021-1)
  • Bliss, Rachel (0001-20-4) (0009-4)
  • Corbett, Susan (0001-30-4)
  • Craig, Anne (0008-3)
  • Fair, Gabriel (0001-22-1) (0001-22-4)
  • Hallock, Judith (0034-4)
  • Hancock, Mandy (0011-3) (0011-4) (0011-5) (0011-8) (0011-14)

(0030-2) (0030-3) (0030-8)

  • Hicks, Katie (0017-5) (0017-7)
  • Howarth, Robert F. (0001-27-1) (0001-27-2) (0001-27-3) (0012-2)
  • LeVander, Valerie (0016-6)
  • McCall, Pat (0018-2)
  • Mominee, Katharine N. (0019-3) (0019-4)
  • Olsen, Mary (0001-15-6)
  • Richardson, Don (0001-25-6) (0015-2)
  • Swinton, D.C. (0001-24-1) (0001-24-4)

Alternatives-System Design

  • Zeller, Lou (0001-9-3)

Benefit-Cost Balance

  • Barnett, Barbara A. (0021-2) (0021-3)
  • Bliss, Rachel (0009-6)
  • Corbett, Susan (0001-30-8) (0001-30-9) (0001-30-11)
  • Drake, Joan W. (0023-2) (0023-5)
  • Fair, Gabriel (0001-22-2)
  • Hale, Kendall (0003-1)
  • Hicks, Katie (0017-2)
  • Hildebrandt, Lorena (0001-23-4) (0001-23-5)
  • Howarth, Robert F. (0012-1) (0012-4)
  • LeVander, Valerie (0016-2) (0016-3) (0016-4) (0016-5) (0016-7)
  • Moss, Dennis Carroll (0001-1-3)
  • Olsen, Mary (0001-15-4) (0001-15-5) (0001-15-10) (0014-6)

(0014-7)

  • Richardson, Don (0015-1)
  • Scott, Darrell (0001-10-5)
  • Swinton, D.C. (0001-24-2)
  • Thomas, Bill (0029-7)
  • Thomas, Ellen (0038-4)
  • Ware, Steve (0001-7-2) 9

Table 3. (contd)

Comment Category Commenter (Comment ID)

Cumulative Impacts

  • Barczak, Sara (0030-9)
  • Hale, Kendall (0003-7)
  • Hancock, Mandy (0011-13) (0030-9)
  • Olsen, Mary (0014-1)

Decommissioning

  • Corbett, Susan (0001-30-6)

Ecology-Aquatic

  • Clements, Tom (0001-31-12) (0001-31-14)
  • Gregg, Ben (0032-1) (0032-3)
  • Smith, Clyde E. (Butch) (0035-4)
  • Thomas, Ellen (0013-4)
  • Vejdani, Vivianne (0036-9) (0036-10) (0036-11)

Ecology-Terrestrial

  • Clements, Tom (0001-31-15)
  • Pennington, Lee (0033-3) (0033-4)
  • Vejdani, Vivianne (0036-2) (0036-5) (0036-6) (0036-7) (0036-8)

Health-Radiological

  • Arnason, Deb (0001-6-3)
  • Bliss, Rachel (0009-5)
  • Breckheimer, Steve (0037-3) (0037-4)
  • Drake, Joan W. (0023-3) (0023-6)
  • Hale, Kendall (0003-5)
  • Richardson, Don (0001-25-4) (0015-5)
  • Thomas, Bill (0029-1)
  • Thomas, Ellen (0013-5) (0013-9) (0038-7) (0038-8)
  • Zeller, Lou (0001-9-1)

Historic and Cultural

  • Breckheimer, Steve (0037-8)

Resources

  • Wilson, Caroline D. (0020-1)

Hydrology-Groundwater

  • Pennington, Lee (0033-2)

Hydrology-Surface Water

  • Arnason, Deb (0001-6-2) (0010-1) (0010-2) (0010-4) (0010-8)
  • Barczak, Sara (0030-1) (0030-5) (0030-6) (0030-7)
  • Barnett, Barbara A. (0021-4) (0021-5)
  • Bliss, Rachel (0001-20-1) (0009-1)
  • Breckheimer, Steve (0037-5)
  • Clements, Tom (0001-31-2) (0001-31-3) (0001-31-5) (0001-31-6)

(0001-31-7) (0001-31-8) (0001-31-9) (0001-31-10) (0001-31-11)

(0001-31-16) (0002-1) (0002-2)

  • Craig, Anne (0008-2)
  • Dolan, Bryan (0001-5-2) (0001-5-3)
  • Gregg, Ben (0032-2) (0032-4) (0032-5)
  • Hale, Kendall (0003-4)
  • Hallock, Judith (0034-1)
  • Hancock, Mandy (0011-2) (0011-7) (0011-9) (0011-10) (0011-11)

(0011-12) (0030-1) (0030-5) (0030-6) (0030-7) 10

Table 3. (contd)

Comment Category Commenter (Comment ID)

  • Hicks, Katie (0017-1)
  • Hildebrandt, Lorena (0001-23-1) (0001-23-2)
  • Littlejohn, Lanny F. (0007-2)
  • Mominee, Katharine N. (0019-2)
  • Moss, Dennis Carroll (0007-2)
  • Moss, Steve (0007-2)
  • Olsen, Mary (0001-15-7) (0001-15-8) (0014-2)
  • Peeler, Harvey S. (0007-2)
  • Scott, Darrell (0001-10-4)
  • Smith, Clyde E. (Butch) (0035-2) (0035-3)
  • Thomas, Bill (0029-6)
  • Thomas, Ellen (0013-10) (0038-1) (0038-5)
  • Vejdani, Vivianne (0036-1) (0036-3) (0036-12) (0036-13)
  • Zeller, Lou (0001-9-2)

Land Use-Site and Vicinity

  • Breckheimer, Steve (0037-7)

Need for Power

  • Barczak, Sara (0030-4)
  • Boger, Paul (0001-13-1)
  • Breckheimer, Steve (0037-1)
  • Hancock, Mandy (0011-6) (0030-4)
  • Hopper, Sara (0001-14-2)
  • Moss, Dennis Carroll (0001-1-1)

Opposition-Licensing Action

  • Arnason, Deb (0001-6-4)
  • Bliss, Rachel (0001-20-6)
  • Drake, Joan W. (0023-1)
  • Hancock, Mandy (0011-1)
  • Hicks, Katie (0017-6)
  • LeVander, Valerie (0016-1)
  • Olsen, Mary (0001-15-1)
  • Swinton, D.C. (0001-24-5)
  • Thomas, Bill (0029-8)

Opposition-Nuclear Power

  • Arnason, Deb (0010-6)
  • Corbett, Susan (0001-30-1) (0001-30-12)
  • Craig, Anne (0008-1)
  • Fair, Gabriel (0001-22-5)
  • Hallock, Judith (0034-5)
  • Hansborough, Hilbert J. (0028-1)
  • Howarth, Robert F. (0001-27-4) (0012-3)
  • Richardson, Don (0001-25-1) (0001-25-5) (0015-6) (0015-7)
  • Thomas, Ellen (0013-1) (0013-11)
  • Williams, Debralee (0001-28-1)
  • Zeller, Lou (0001-9-8) 11

Table 3. (contd)

Comment Category Commenter (Comment ID)

Outside Scope-Emergency

  • Pennington, Lee (0033-1)

Preparedness

  • Swinton, D.C. (0001-24-3)

Outside Scope-

  • Richardson, Don (0015-4)

Miscellaneous Outside Scope-NRC

  • Arnason, Deb (0010-3)

Oversight

  • Olsen, Mary (0014-4)

Outside Scope-Safety

  • Clements, Tom (0001-31-13)
  • Thomas, Ellen (0038-9)
  • Zeller, Lou (0001-9-4) (0001-9-5) (0001-9-6) (0001-9-7)

Outside Scope-Security and

  • Hale, Kendall (0003-3)

Terrorism

  • Hicks, Katie (0017-4)
  • Thomas, Ellen (0013-2)

Process- COL

  • Arnason, Deb (0010-5) (0010-9)
  • Bliss, Rachel (0001-20-3) (0009-3)
  • Clements, Tom (0001-31-1) (0002-3) (0002-4) (0002-5)
  • Haire, Wenonah G. (0039-1)
  • Olsen, Mary (0001-15-11)
  • Thrift, Debbie (0025-2)

Process-NEPA

  • Olsen, Mary (0001-15-3)

Site Layout and Design

  • Clements, Tom (0001-31-4)

Socioeconomics

  • Bliss, Rachel (0001-20-2) (0009-2)
  • Boger, Paul (0001-13-2)
  • Breckheimer, Steve (0037-6)
  • Corbett, Susan (0001-30-3)
  • Cross, John (0026-2) (0026-5)
  • Littlejohn, Lanny F. (0007-1)
  • Mixon, Michael C. (0027-2)
  • Moss, Dennis Carroll (0007-1)
  • Moss, Steve (0007-1)
  • Olsen, Mary (0001-15-2)
  • Peeler, Harvey S. (0007-1)
  • Smith, Brian (0024-1)
  • Thomas, Ellen (0038-2) (0038-3)
  • Thrift, Debbie (0025-3)
  • Vejdani, Vivianne (0036-4)

Support-Licensing Action

  • Boger, Paul (0001-13-4)
  • Brooks, Tim (0001-8-1)
  • Cook, Jim (0001-26-1) (0001-26-3)
  • Cross, John (0026-1) 12

Table 3. (contd)

Comment Category Commenter (Comment ID)

  • Forrester, Mike (0001-3-1) (0001-3-2)
  • Hogue, David (0001-4-2)
  • Hopper, Sara (0001-14-1) (0001-14-4) (0001-14-6)
  • Ledford, Judy and Glenn (0022-1)
  • McCall, Pat (0018-1)
  • Mixon, Michael C. (0027-1)
  • Moss, Dennis Carroll (0001-1-4) (0001-1-5)
  • Moss, Steve (0001-2-1) (0001-2-2)
  • Pace, Eric (0001-21-1)
  • Robbs, Kayla (0001-18-1)
  • Scott, Darrell (0001-10-1)
  • Smith, Clyde E. (Butch) (0035-1)
  • Thrift, Debbie (0025-1)
  • Ware, Steve (0001-7-1) (0001-7-3) (0001-7-4)

Support-Licensing Process

  • Bliss, Rachel (0009-8)
  • Pace, Eric (0001-21-2)
  • Richards, Kitty-Katherine (0001-19-1)

Support-Nuclear Power

  • Brooks, Tim (0001-8-2)
  • Cross, John (0026-3) (0026-4)
  • Dolan, Bryan (0001-5-1)
  • Hopper, Sara (0001-14-3)
  • Mominee, Katharine N. (0019-1)
  • Pace, Eric (0001-21-3)
  • Scott, Darrell (0001-10-2) (0001-10-3)

Support-Applicant

  • Boger, Paul (0001-13-3)
  • Cook, Jim (0001-26-2)
  • Hogue, David (0001-4-1)
  • Hopper, Sara (0001-14-5)
  • Moss, Dennis Carroll (0001-1-2)
  • Robbs, Kayla (0001-18-2)

Transportation

  • Thomas, Bill (0029-3)

Uranium Fuel Cycle

  • Barnett, Barbara A. (0021-6)
  • Bliss, Rachel (0001-20-5) (0009-7)
  • Breckheimer, Steve (0037-2)
  • Corbett, Susan (0001-30-2) (0001-30-5) (0001-30-7)
  • Drake, Joan W. (0023-4) (0023-7)
  • Fair, Gabriel (0001-22-3)
  • Hale, Kendall (0003-2) (0003-6)
  • Hallock, Judith (0034-2)
  • Hicks, Katie (0017-3) 13

Table 3. (contd)

Comment Category Commenter (Comment ID)

  • Hildebrandt, Lorena (0001-23-3)
  • Olsen, Mary (0001-15-9) (0014-5)
  • Richards, Kitty-Katherine (0001-19-2) (0001-19-4)
  • Richardson, Don (0001-25-2) (0001-25-3) (0015-3)
  • Thomas, Bill (0029-2) (0029-4) (0029-5)
  • Thomas, Ellen (0013-3) (0013-6) (0013-7) (0013-8) (0038-6) 14

Lee Units 1 and 2 Combined License Public Scoping Comments and Responses The comments and suggestions received as part of the supplemental scoping process are summarized and discussed below. Comments are grouped by category. Parenthetical numbers after each comment refer to the correspondence ID number (document number-comment number) and the commenter name.

The draft EIS will take into account the relevant issues raised during the scoping process. The comment period for the draft EIS will offer the next opportunity for interested Federal, State, Tribal, and local government agencies; local organizations; and the public to provide input to the NRC environmental review process. Comments received for the draft EIS will be considered in the preparation of the final EIS which, along with the staffs Safety Evaluation Report (SER), will be considered in the decision by the NRC on Dukes COL application for the Lee Nuclear Station.

1. Comments Concerning Process - COL Comment: A number of you were at the scoping meetings in 2008, and I'm quite concerned that at that time this issue of insufficient water was not addressed during scoping. A lot of the members of the public spoke out, and the NRC has said that tonight, and I want a full explanation of why the issue of inadequate water for the reactors was not discussed at that time, and I don't think that we've heard that reason tonight. (0001-31-1 [Clements, Tom])

Comment: Duke was aware of water demands at the time of the EIS scoping meeting so it is hard to understand why this lake is being proposed now and not at the start of the whole EIS process. This reflects very poorly on both Duke and the NRC in that the water supply and use issue was of concern to the public 1.5 years ago and the low-flow impacts well-known at that time. (0002-3 [Clements, Tom])

Comment: If the NRC had been on its toes and truly working in the public interest, this issue of need for more water would have been on the table from the start of the environmental review process. That the NRC did not realize or admit the stresses being posed to the Broad River by the proposed reactors, as was reflected in a letter from the SC Department of Natural Resources, with which I'm sure you are familiar, is hard to accept. This does call into question the NRC's ability to adequately review Duke's environmental documentation.

(0002-4 [Clements, Tom])

Comment: I expect a full public explanation to be offered both by the NRC and Duke as to why we have only learned this far along into the process about the need for a new make-up water 15

lake (of unknown size). Many of us saw this coming a long time ago and speculated on the possibility that Duke would pose a new lake, so either the NRC and Duke are way behind in their analysis of impacts to the Broad River or the plan for a new lake existed earlier and is only just now being revealed. But I am open to any other explanation as to why we are only learning about this proposed lake at this late point. (0002-5 [Clements, Tom])

Response: The NRCs regulations that implement the National Environmental Policy Act of 1969 (NEPA) are contained in Title 10 of the Code of Federal Regulations (CFR) Part 51, Environmental Protection Regulations for Domestic Licensing and Related Regulatory Functions. Title 10 CFR 51.29(a)(2) states that scoping will Determine the scope of the statement and identify the significant issues to be analyzed in depth. Scoping for the environmental impact statement (EIS) should ensure that public and agency concerns are identified early and properly studied. In the case of Make-Up Pond C, it was during the original scoping process that the South Carolina Department of Natural Resources (SCDNR) identified the need for a contingency supply of cooling water during periods of low flow in the Broad River.

The identification of the Broad River low-flow issue by SCDNR is an example of how NEPA and the scoping process were successfully implemented. As a result, Duke Energy Carolinas, LLC (Duke) amended the Lee Nuclear Station project by adding the proposed Make-Up Pond C to serve as a source of supplemental cooling water during low-flow periods in the Broad River.

The NRC and the U.S. Army Corps of Engineers (USACE) considered this a big enough change to the Lee Nuclear Station project scope to necessitate another round of scoping and another public scoping meeting.

The SCDNR letter can be found in the NRC Agencywide Documents Access Management System (ADAMS) under Accession No. ML081430553. ADAMS is accessible at http://www.nrc.gov/reading-rm/adams.html. Persons who do not have access to ADAMS or who encounter problems in accessing the documents located in ADAMS should contact the NRC Public Document Room reference staff by telephone at 1-800-397-4209 or 301-415-4737, or via e-mail at pdr@nrc.gov.

The NRC and the USACE are in the process of examining the environmental impacts of building and operating the Lee Nuclear Station (and Make-Up Pond C) and will address water use issues in Chapter 5 of the draft EIS. At the time of the original and supplemental scoping periods, the NRC was not in the position to make any preliminary determinations regarding environmental impacts associated with the proposed Lee Nuclear Station.

Comment: Again, back to the issue of federal agencies working together and disclosure.

You're working with the Army Corps of Engineers; that's good. But how about the National Oceanic and Atmospheric Administration? How about the projections for the droughts that are on their records for this area? (0001-15-11 [Olsen, Mary])

16

Response: Title 10 CFR 51.28 identifies who should be invited to participate in the scoping process, which includes Federal, State, and local agencies, and affected Native American tribes. The NRCs environmental review process invites other governmental agencies to assess whether or not they should be considered cooperating agencies under the regulatory structure afforded by the Presidents Council on Environmental Quality. The environmental review process also invites these agencies to identify whether or not they have a particular expertise on an issue that may be invaluable to the NRC, or have consultation roles under other statutes that have a bearing on site-specific issues.

For the Lee Nuclear Station environmental review, the NRC has contacted Federal agencies such as the U.S. Fish and Wildlife Service and the American Council on Historic Preservation, numerous Native American tribes, and South Carolina and North Carolina resource agencies.

As the comment states, the USACE Charleston District is participating in the environmental review as a cooperating agency. The NRC may also use data from other Federal and State agencies when evaluating the environmental impacts of building and operating the Lee Nuclear Station.

Comment: A couple years ago reactors, like I said earlier, were closed down because of a drought in our area in Tennessee. I want to be assured that the Army Corps of Engineers and the NRC can be trusted with this project. (0001-20-3 [Bliss, Rachel])

Comment: I want to be assured that the Army Corp of Engineers and the NRC can be trusted with this project. In recent years they have failed us along with corporations they regulate.

(0009-3 [Bliss, Rachel])

Comment: I know you cannot (for reasons I fail to understand) address anything but this permit and have brought our concerns to the further attention of Congress and the President.

(0010-5 [Arnason, Deb])

Comment: I have been here before with the NRC when I attended Gaffney SC hearing on this Lee reactor May 1, 2008. I was informed, in a joking way, by a NRC employee that my opposition was useless and this Lee Reactor was a foregone conclusion. (0010-9 [Arnason, Deb])

Response: NRC approval of an application for a combined license (COL) is not a foregone conclusion. The NRC's responsibility is to regulate the nuclear industry to protect public health and safety, and the environment. Accordingly, the licensing process for COL applications is specified in 10 CFR Part 52. The NRCs environmental regulations are contained in 10 CFR Part 51 and guidance for NRC staff responsible for environmental review of new reactor license applications is documented in NUREG-1555, Standard Review Plans for Environmental Reviews for Nuclear Power Plants. The environmental review process includes a detailed review of an applicant's COL application, and considers public comments received 17

during scoping periods as well as consultations with Tribal, State, and Federal agencies to determine the environmental effects of building and operating the nuclear power facility.

By letter dated February 10, 2009, NRC received official notice of the USACEs interest in becoming a cooperating agency for the Lee COL EIS (ADAMS Accession No. ML090690283).

The NRC agreed by letter dated March 30, 2009 (ADAMS Accession Number ML090700384) to invite USACE to serve as a cooperating agency in the preparation of the EIS for this licensing action. USACE is committed to following the letter of the law (i.e., the Clean Water Act) as it applies to the proposed Lee Nuclear Station project.

Comment: The Catawba wishes to be consulted on any ground disturbing activities on this project. (0039-1 [Haire, Wenonah G.])

Response: As outlined in 36 CFR 800.8(c), Coordination with the National Environmental Policy Act of 1969 (NEPA), the NRC is coordinating compliance with the National Historic Preservation Act, Section 106, in fulfilling its responsibilities under NEPA. The NRC will consult with the Catawba Indian Nation for NRC-authorized activities associated with the Lee Nuclear Station COL application. The Catawba Indian Nation will have an opportunity to consult and comment on the project through the NEPA process. The NRC will provide the Catawba Indian Nation copies of Dukes responses to NRC requests for additional information and associated cultural resource reports.

Comment: I believe if more people in support of these projects were kept well informed there would be a greater attendance and more of a show of support. I was not aware of the public hearing last week or I too would have attended in person. (0025-2 [Thrift, Debbie])

Response: The NRC staff used a number of methods to inform the public about the scoping meeting. The Notice of Intent to Conduct a Supplemental Scoping Process for the Supplement to the Environmental Report was published in the Federal Register on May 24, 2010 (75 FR 28822). In addition, public notice was provided through local newspaper ads and press releases, as well as on the NRC website. Meeting announcements were published in the following local newspapers: The Gaffney Ledger, Spartanburg Herald-Journal, York Enquirer-Herald, The State (Columbia), Blacksburg Times, Charlotte Observer, and Gaston Gazette.

The staff appreciates the concern raised by the commenter and will continue to look for ways to improve public notification of these meetings.

2. Comments Concerning Process - NEPA Comment: So cutting now to the scoping issues, the National Environmental Policy Act does allow consideration of options, of course; that's what the whole process is. There's a no-action alternative. But currently I have never heard of a federal agency being honest about the situation that we're in with this site. (0001-15-3 [Olsen, Mary])

18

Response: The no-action alternative; i.e., denial of COL, energy conservation and efficiency, demand-side management, new generation alternatives, purchased electrical power, alternative energy technologies (including renewable energy resources such as wind and solar), and the combination of alternatives will be addressed in Chapter 9 of the EIS. For acceptable alternatives, the potential for environmental impacts will be assessed against that of the proposed Lee Nuclear Station. If one of the acceptable alternatives is environmentally preferable to the proposed action, economic impacts will also be compared.

3. Comments Concerning Site Layout and Design Comment: A couple things about the AP-1000 reactor, and I want to point out a few things because the NRC hasn't done it, from the environmental report. If people don't know, the reactors that are being looked at here have never been built anywhere in the world. They are under construction in China, but they have never been built anywhere. The design is not certified in the United States, and they do not have a license from the Nuclear Regulatory Commission. So why is so much site preparation going on at the Duke site here and at the SCE&G site if the reactors aren't even licensed and the whole overall project does not have a license? (0001-31-4 [Clements, Tom])

Response: Revision 15 of the Westinghouse AP1000 Design Control Document (DCD) is a certified design (10 CFR Part 52, Appendix D). In its COL application, Duke referenced Revision 17 to the AP1000 DCD, which NRC accepted for review but has not yet approved.

NRC regulations allow the applicant for a COL to reference a design that is undergoing design certification. Site preparation activities not related to nuclear safety, also termed preconstruction activities, may be performed by the applicant prior to the conclusion of the COL application review. The impacts of preconstruction activities will be addressed in Chapters 4 and 7 of the EIS. Applicants engaging in preconstruction activities do so at their own risk as NRC approval of an application for a COL is not a foregone conclusion. This comment provides no new information related to the environmental review of the proposed action and will not be addressed in the EIS.

4. Comments Concerning Land Use - Site and Vicinity Comment: Flooding the area for Make-Up Pond C will flood valuable farmland (0037-7 [Breckheimer, Steve])

Response: A description of current land uses, as well as land-use impacts during development and operation of the proposed facilities will be discussed in Sections 2.2, 4.1, and 5.1 of the EIS. Additionally, Chapter 10 will discuss Irreversible and Irretrievable Commitments of Resources, in accordance with Section 102(2)(C)(v) of NEPA.

19

5. Comments Concerning Hydrology - Surface Water Comment: I do want to mention briefly the construction of Pond C. Pond C is a critical component to the Lee Station's success. .... Duke Energy also evaluated the environmental impact of the pond and concluded that it would result in the least impact to the environmental as compared to other options. (0001-10-4 [Scott, Darrell])

Comment: We're talking about water withdrawals; we're talking about Pond C. We are in a situation where power generated with steam is causing two-thirds of the water we take out to not produce any power at all. It's just thermodynamics; it's just condensing steam back to water to make power. So if we do the numbers on this site, the projections are more than 30 million gallons a day, but round down to make it easy: 30 million gallons a day that's actually like, you know, going off the site as steam. Two-thirds of that, or 20 million gallons, didn't even make electric power. (0001-15-7 [Olsen, Mary])

Comment: I think it's time that our federal agencies put into their disclosures the withdrawal of water that could be drinking water, that could be used in an environmental natural ecosystem versus uselessness. (0001-15-8 [Olsen, Mary])

Comment: I'm concerned about the state of the Broad River if another containment pond is built using water that would ordinarily go into the Broad River directly. We need further information about how this water use will affect communities downstream (0001-20-1 [Bliss, Rachel])

Comment: Duke Energy's proposal for this cooling lake demonstrates the flaws of the Lee nuclear reactor plans in regards to water. According to Section 5.2.1 of Duke's report on the environmental impacts of the Make-Up Pond C, the necessity of this cooling lake is due to the need to compensate for low flow on the Broad River. They admit in their report that the region has been drought-stricken in the past and continues to be. My question to the Nuclear Regulatory Commission, as well as Duke Energy, is why permit or build a nuclear reactor, which, according to the Department of Energy, is the highest water consumer of any energy technology, in a drought-prone area, especially when, according to climate models, we face an escalating threat of future droughts in the region. (0001-23-1 [Hildebrandt, Lorena])

Comment: I'd also like to see information in the environmental report on how long the make-up ponds would last in case of low flow and drought in the Broad River.

(0001-23-2 [Hildebrandt, Lorena])

Comment: I want to know now how much evaporation there is from the lake and what's going to replace the evaporated water. Is that going to come from this tiny little creek? Or is it going to be pumped from the Broad River? (0001-31-10 [Clements, Tom])

20

Comment: Also, what happens to London Creek when the lake is emptied down to its lowest amount and possibly there's not any discharge to the Broad River? We heard that it's going to go down to 17,500 acre feet, I believe, so what happens to the creek under these circumstances? (0001-31-11 [Clements, Tom])

Comment: As I said, you don't have to be against nuclear power to be concerned about how this is going to impact the Broad River. We heard at the earlier scoping meeting, we heard tonight that if this project goes forward, the name of the Broad River is going to have to be changed to the Skinny River, but I'd go just a little bit further. Because of the hot water being discharged into the river, that's going to affect aquatic life downstream, we might well just have to change the name to the Hot & Skinny River, because that may well be the case if this goes forward. (0001-31-16 [Clements, Tom])

Comment: And it does appear that this reactor project hinges on this new lake. It's down to the water in a new lake to provide cooling water for the reactors during low flow. And to me, this is an admission of the vulnerability of the project, that it's not really viable, that this is the wrong place for nuclear reactors, even if you're pro-nuclear. If you want nuclear reactors to be built, this is not the place to do it, because the Broad River is not large enough to handle these reactors. (0001-31-2 [Clements, Tom])

Comment: And I want to dispute something that was said earlier by the representatives who spoke and by the Chamber of Commerce. We heard them say that the new water withdrawal bill that was passed by the legislature this year and signed by the governor is going to regulate these new reactors. Well, that's quite interesting to hear, because at the Nuclear Advisory Council -- the Governor's Nuclear Advisory Council meeting last Thursday a spokesperson from the Department of Health and Environmental Control made clear the new bill does not regulate water withdrawal for nuclear reactors. That's the role of the Federal Energy Regulatory Commission. So there's not going to be any control by the state, it appears. I asked one of the representatives outside to please clarify, and he didn't really want me asking him the question, because they want to make the presentation that the state is going to regulate the water withdrawal, and I don't think that's the case. To read the law it's very unclear, but DHEC's interpretation is that the reactors are not regulated. (0001-31-3 [Clements, Tom])

Comment: And I wanted to point out -- and some people have already done this, but pulling directly from the Duke environmental documents, they say that 60,000 gallons per minute will be withdrawn from the river, with a use of 28,000 gallons per minute, maximum. According to my calculations, this is 86 million gallons a day withdrawn from the river, and 41 million gallons used through evaporative cooling. (0001-31-5 [Clements, Tom])

Comment: Also, the environmental report says that Make-Up Pond C will have a maximum depth of approximately 116 feet, that the dam height will be 132 feet, and to me -- and its 620 acres in size. And to me this is a lake and it's not a pond. The environmental report -- and I think 21

this is something that you really need to think about -- says, London Creek, on which the lake would be built, was flowing during both the March and September 2008 sampling events, when they were doing this study. However, between sampling events, London Creek ceased to flow in many places due to severe to extreme drought conditions in the region. And it goes on to say, "Prior to the September sampling period, riffle areas in London Creek dried up, leaving only isolated pools". We're talking about a small creek that's going to provide the emergency water that's need in low-flow periods of the river. This is not a sizeable body of water on which this lake is being proposed. (0001-31-6 [Clements, Tom])

Comment: I'd like to make a request and then just point out some things that I'd like to see the EIS cover. I request that the NRC, in the tables, provide the volumes in gallons per minute as well as acre-feet, because when you read them, you have to make the interpretations yourself, and the question already came up tonight and the NRC couldn't answer that: How many acre-feet were in gallons. (0001-31-7 [Clements, Tom])

Comment: Also the question needs to be explained: How many days' worth of use of water for cooling is in this lake? As I recall from the environmental document, it's only a few. This is only going to provide extra operating capacity. I don't know; maybe it's five days. It's not going to provide a margin for keeping the reactors going in any case if there's an extreme drought like we had a few years ago. (0001-31-8 [Clements, Tom])

Comment: And I want to know how much discharge there is from the new lake into the Broad River at different flows of the river. At some point is there going to be no water discharged from the -- from London Creek and the lake into the river, because it's all being captured for storage?

(0001-31-9 [Clements, Tom])

Comment: An evaluation of the water needs for the station was included as a part of the environmental report. This included a thorough analysis of many factors, such as available water sources; upstream, downstream water users' needs; environmental considerations, and station water needs. It also included a review of historical data, including the potential impact of drought conditions on area water resources and station operation. The Ninety-Nine Islands reservoir will be the primary source of water in this station. In addition, the site currently has two ponds; one designed for station use during drought periods instead of using the Ninety-Nine Islands reservoir. These ponds can be refilled from rain, runoff, and water from Ninety-Nine Islands reservoir during high river flow periods. (0001-5-2 [Dolan, Bryan])

Comment: Based on our additional evaluation and discussions, as well as alternatives for use, where we considered other options for maximizing the efficient use of water and minimizing our environmental impact, we determined adding another pond on the Lee site would provide additional drought contingency during prolonged droughts and further ensure the availability of water for the regional ecology and downstream water users. (0001-5-3 [Dolan, Bryan])

22

Comment: Comments on Make-Up Pond C: And I'm glad you provided some information, and I would like some more, as people have requested: the size of the pond relative to evaporation needs of the reactor. But I'd like those over the life of the reactors. (0001-6-2 [Arnason, Deb])

Comment: Duke's nuclear power plant at Lee, if constructed, would consume four times as much water as all public and industrial users in Cherokee County combined.

(0001-9-2 [Zeller, Lou])

Comment: Given that we have long know about the possible stresses to the Broad River by the consumptive use of water by the proposed Lee reactors, as was raised more than a year ago during scoping comments, it strikes me as strange that Duke has now come back to propose a new cooling-water lake. It was quite clear last year that the low flow of the Broad River - which one person during oral scoping comments said should be renamed the Skinny River if the reactor project went forward - would not be sufficient to supply both the reactors and provide water for the flow of the river during low-flow periods. (0002-2 [Clements, Tom])

Comment: Nuclear power plants use enormous amounts of water; in a era of increasing drought and water shortages, we cannot afford to do this. (0003-4 [Hale, Kendall])

Comment: My understanding is Duke Energy will withdraw the water needed to operate the Lee plant from the Broad River at the Ninety-Nine Islands Reservoir, and that during drought conditions Duke will rely on drought contingency ponds as the source of water for the plant's needs rather than withdrawing water from the Broad River. This seems prudent to me because it will allow for the water in the river during low-flow conditions to be available for downstream users and for protecting the river's ecology. As a South Carolina legislator, I am familiar with the South Carolina Surface Water, Permitting, Use and Reporting Act which was approved by the S.C. legislature and signed by the Governor earlier this month. Duke's proposed plans to withdraw water from on-site drought contingency ponds, during drought periods, is perfectly aligned with what our state environmental permitting and environmental resource agencies advocated in this legislation. Specifically, the legislation states that when minimum flow conditions exist in the river, the water withdrawer is to stop withdrawing consumptive quantities of water from the river and begin withdrawing water from a supplemental source such as a drought contingency pond. Duke Energy is proposing the construction of an additional drought contingency pond, which it would utilize during prolonged drought periods. I fully support Duke's request to construct this additional drought contingency pond. Again, I want to point out that Duke's plans to use two drought contingency ponds during low river flow conditions directly aligns with the expectations and requirements stated in the S.C. surface water legislation.

(0007-2 [Littlejohn, Lanny F.] [Moss, Dennis Carroll] [Moss, Steve] [Peeler, Harvey S.])

Comment: The production of nuclear power compromises our safety in several areas including our right to clean, non radioactive water sources. (0008-2 [Craig, Anne])

23

Comment: I am concerned about the state of the Broad River, if another containment pond is built using water that would ordinarily go into the Broad river directly. We need further information about how the water use will affect communities downstream. (0009-1 [Bliss, Rachel])

Comment: Although Duke has submitted a supplemental plan to construct an additional source of water to be designated Make-Up Pond C, I cannot fathom how it would be enough, especially in times of drought and water wars between southern States. This must also be projected at least 20 years out considering climate change is rapidly drying up this area. How dare we allow for-profit corporations to suck us dry? (0010-1 [Arnason, Deb])

Comment: I would hope you are aware that each existing and each new reactor will EVAPORATE millions of gallons of water PER DAY PER REACTOR (35Mgw/day@Lee) -unlike paltry lawn watering or car washing regulations where at least the water will find its way back into the water table of the region where it is used! (0010-2 [Arnason, Deb])

Comment: I have a joke for you, although it's not original: Granting this permit will turn the Broad River into the Skinny River. Please now take my concerns seriously or the fallout will be on all of us. (0001-6-4 [Arnason, Deb])

Comment: Does Duke Energy assure you they have the technology and expertise to prevent any disasters or, in this specific case, provide enough water to make up for their projected water evaporation without sacrificing the needs of human beings for fresh water over the next 20 years or the life of the reactor? How can anyone believe that when the future is so uncertain?

(0010-4 [Arnason, Deb])

Comment: The application also mentions that average surface water use (public and industrial) in Cherokee County was 8.4 million gallons per day. This means that on a daily basis the Lee plant could use six to ten times the amount of surface water used by everyone else in the county combined. The plant will be competing with other important water users in South Carolina and the region. Yet, the application does not acknowledge the impacts this may have, nor does it ponder the impacts this could have during severe drought conditions, such as we regularly experience. The NRC needs to address all of these serious issues in the draft EIS.

(0011-11 [Hancock, Mandy])

Comment: The Broad River, from which the Lee site will rely, is already stressed from the drought and a variety of industrial and municipal users. Further, other proposals, such as Duke's efforts to expand the Cliffside coal plant in NC, and SCE&G's proposal to build two reactors in Jenkinsville, SC also aim to use huge amounts of water from the Broad River. The full extent of these proposed impacts are not discussed in the application. The NRC needs to analyze not only the Broad River of today, but the Broad River of tomorrow, which is slated for more development. The application even states that an estimated 56 percent increase in water 24

demand is projected from 1997 to 2020 for the North Carolina portion of the Broad River basin.

How will the Broad River be able to provide enough water for all these needs?

(0011-12 [Hancock, Mandy])

Comment: The proposal to impound the Broad River to create a 620 acre make up pond would forever alter the ecosystem of this area. These risks are not adequately addressed in Duke's revised report. (0011-2 [Hancock, Mandy])

Comment: Duke and the NRC already know that this region has historically suffered from severe droughts as Duke's revised report references the 2005 South Carolina Water Use Report Summary that says the last multi-year drought was in 2008. The National Drought Mitigation Center shows the immediate vicinity of Gaffney to be currently suffering abnormally dry conditions. The Supplement lists recorded statewide droughts since 1925 that show a pattern of getting more frequent and longer lasting droughts. The proposal of creating Make Up Pond C is simply illogical-what actually makes sense is to pursue less water intensive energy options to begin with instead of costly engineering measures that will negatively impact the environment, add to the cost, and ultimately waste even more water. (0011-7 [Hancock, Mandy])

Comment: According to Duke's application, the two Lee reactors will withdraw during normal use 50-86 million gallons of water per day (mgd) from the Broad River 9 and consume, or lose, 35-41 mgd resulting in an overall consumptive loss of approximately 50-70%.'?? This is unacceptable in a region in which water resources are already stressed.

(0011-9 [Hancock, Mandy])

Comment: Duke and SCG&E are planning Cliffside Coal Plant and 5 nuclear reactors on the Broad (2 at Lee in Gaffney and 3 at Summer in Jenkinsville). This is not sustainable and jeopardizes the entire Broad River watershed and drinking source for Columbia, SC.

(0013-10 [Thomas, Ellen])

Comment: The water withdrawals from the Broad River are in direct conflict with drinking water needs of Columbia, SC and will have its greatest impact during draught when the water needs of the City will be greatest. (0014-2 [Olsen, Mary])

Comment: We strongly oppose the proposed reactors for many reasons. First, the water evaporation from the Broad River due to cooling operations would be unacceptable. The Broad River already receives hot discharges and loses water from THREE other existing or planned nuclear reactors in SC and a coal plant in NC. In addition to the 47 million gallons of water per day the facility would withdraw, returning only a quarter of this amount, our calculation based on the reactor specifications indicate that the facility could cause evaporation of up to five and a half BILLION gallons per year in "forced evaporation" downstream due to hot discharges. This reduced flow is harmful to wildlife and reduces the amount of water available to downstream communities, such as Union and Columbia, who use the Broad as a drinking source.

25

Construction of cooling pond C would not improve the state of the Broad River, as London Creek is tributary to the river, and thus any evaporation from the pond will impact overall river flows. The mean monthly discharge of many NC rivers and streams has been generally decreasing in the past decade, due to two extended periods of drought. Especially with these drought conditions and the possibility of interstate water conflicts, a closer examination of the allocation implications of permitting these reactors is imperative. (0017-1 [Hicks, Katie])

Comment: I strongly urge development of at least the third pond identified in the June 18, 2010 Craig Peters Report distributed by NEI. There is no debate regarding paramount concerns for confidence and assured availability of uninterrupted cooling water sources, and there have been recent instances of extreme drought in the southern regions.. There is not debate that all engineering / mechanical advantages available to provide uninterrupted water source must be perused. It is my opinion that additional water ponds should also be considered for simple process water hold-up. Typical examples would be a hold up pond for circulating cooling water to provide short term hold up on site for oxidation biocide degradation and/or station drain run-off hold-up ponds for the inadvertent oil leaks, both providing short term hold-up/mitigation potential prior to return to open water sources. (0019-2 [Mominee, Katharine N.])

Comment: Water is an issue. Droughts and heat waves cause nuclear reactors to be unreliable and inoperable because federal regulations require plants to shut down when water temperatures reaches 90 degrees. (0021-4 [Barnett, Barbara A.])

Comment: The Lee plants cannot function without 50 million gallons of water a day from the Broad River and 35 million gallons would evaporate from the cooling towers. Nuclear Reactors would consume four times as much water as all public and industrial users in Cherokee County combined (Duke Energy License Application Environmental Report Sec. 2.3.2). In the summer South Carolina is hot and humid with daytime temperatures averaging near 90 degrees and have reached 100 degrees. (0021-5 [Barnett, Barbara A.])

Comment: This nuclear plant will require the construction of a lake to ensure a reliable source of cooling water, consuming up to 55 cubic feet of water per second from the Broad River. With global warming/climate change there can be no assurance that the flow of the Broad River will remain at its current levels or that its water will be essential for drinking or agriculture in the future. (0029-6 [Thomas, Bill])

Comment: The proposal to impound the Broad River to create a 620 acre make up pond would forever alter the ecosystem of this area. These risks are not adequately addressed in the Environmental Report and must be thoroughly examined by the Nuclear Regulatory Commission (NRC) in the draft Environmental Impact Statement (DEIS).

(0030-1 [Barczak, Sara] [Hancock, Mandy])

26

Comment: This region has historically suffered from severe droughts. Yet Duke's application references the 2005 South Carolina Water Use Report Summary that says the last multi-year drought was in 1998.4 The National Drought Mitigation Center shows the immediate vicinity of Gaffney to be currently suffering abnormally dry 5 conditions. The Supplement lists recorded statewide droughts since 1925 that show a pattern of getting more frequent and longer lasting.

The proposal of Make Up Pond C, to be used to provide supplemental water during drought and/or low flow periods in a region prone to severe drought and temperatures, seems extreme and dangerous. (0030-5 [Barczak, Sara] [Hancock, Mandy])

Comment: According to Duke's application, the two Lee reactors will withdraw during normal use 50-86 million gallons of water per day (mgd) from the Broad River 7 and consume, or lose, 35-41 mgd, returning only 30-50% back to the river. Overall consumptive loss will be approximately 50-70%. This is unacceptable in a region in which water resources are already stressed. The application also mentions that average surface water use (public and industrial) in Cherokee County was 8.4 million gallons per day. This means that on a daily basis the Lee plant could use six to ten times the amount of surface water used by all other users in the county combined. Though the proposed plant will be competing with other important water users in South Carolina and the region, the application does not acknowledge the impacts this may have, nor does it ponder the impacts this could have during severe drought conditions. The NRC needs to address this in the DEIS. (0030-6 [Barczak, Sara] [Hancock, Mandy])

Comment: The Broad River, from which the Lee site will rely, is already stressed from the drought and a variety of industrial and municipal users. Further, other proposals, such as Duke's efforts to expand the Cliffside coal plant in North Carolina, and SCE&G's proposal to build two reactors in Jenkinsville, South Carolina at the V.C. Summer site also aim to use huge amounts of water from the Broad River. The full extent of these cumulative impacts is not discussed in the application. The NRC needs to analyze not only the Broad River of today but also the Broad River of tomorrow, which is slated for more development. The application states that an estimated 56 percent increase in water demand is projected from 1997 to 2020 for the North Carolina portion of the Broad River basin. How will the Broad River be able to provide enough water for all these needs? (0030-7 [Barczak, Sara] [Hancock, Mandy])

Comment: Also, downstream of the proposed Lee facilities the Broad River enjoys our state's Scenic River status, reflecting a stream of exceptional quality and diversity. Hence, measures to protect these assets are not only prudent, but should be required by the license and related permits. (0032-2 [Gregg, Ben])

Comment: ...it is our understanding that Duke's proposed water withdrawals are consistent with the spirit, intent, and specifications of the [South Carolina Surface Water Withdrawal and Reporting] Act. (0032-4 [Gregg, Ben])

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Comment: the proposed water management plan presented by Duke appears consistent with the requirements of its FERC license for the Ninety-Nine Islands Hydroelectric Station.

(0032-5 [Gregg, Ben])

Comment: I am not satisfied that there will be enough water to service this proposed reactor due to our severe recent drought and associated water evaporation. (0034-1 [Hallock, Judith])

Comment: Given the fact that the proposed power plant is a regional solution we are perplexed as to why Duke Energy has not considered a more regional option to supply the additional storage of water for the project. CCW has been working for more than 10 years on the development of a reservoir on the First Broad River to supply potable water for our water system as well as the City of Shelby water system. CCW presented this idea to Duke Energy during its study of the Broad River Water Supplies conducted in 2007. It is our understanding that Duke's study indicated there was an inadequate supply of water from the Broad River during extreme drought conditions and that an additional supply of raw water was needed for cooling water for the proposed Lee Nuclear Station. Duke's conclusion as to inadequate water supply supports the position of CCW as to the need for an additional supply of raw water.

(0035-2 [Smith, Clyde E. (Butch)])

Comment: Now that a second reservoir is needed (Make-up pond C) CCW requests that USNRC and the USACOE re-evaluate the use of a proposed joint reservoir on the First Broad River. (0035-3 [Smith, Clyde E. (Butch)])

Comment: The ER Supplement states that the proposed Make-Up Pond C would be an off-site, man-made reservoir, formed by impounding London Creek; a tributary of the Broad River, northwest of Make-Up Pond B. Make-Up Pond C would be used to provide supplemental water during drought and/or low flow periods. Make-Up Pond C would be filled using water pumped through Make-Up Pond A and Make-Up Pond B, or directly from the Broad River. The Make-Up Pond C dam would be downstream of Lake Cherokee and upstream of the confluence of London and Little London creeks. The Make-Up Pond C dam crest elevation would be 660 ft msl, and the spillway crest elevation would be 650 ft msl. Make-Up Pond C would have a maximum depth of approximately 116 ft and a total storage volume of approximately 22,000 ac-ft. The surface area at the normal pond level of 650 ft msl would be approximately 620 ac. The usable storage capacity would be approximately 17,500 ac-ft. Normal water surface elevation for the proposed Make-Up Pond C would be 650 ft. At times when natural stream flows to Make-Up Pond C are inadequate to maintain a full pool condition, the reservoir would receive supplemental inflows from the Broad River. If permitted, Pond C, at 632 acres would be the largest reservoir permitted in the state of South Carolina since Lake Russell in the mid-l 970s.

(0036-1 [Vejdani, Vivianne])

Comment: The proposed flooding of approximately 6 mi of stream will require mitigation for unavoidable impacts to waters of the U.S. as required by section 404(b)(1) of the Clean Water 28

Act, consistent with criteria set forth in the Federal Mitigation Rule (Rule). The Rule establishes set criteria, or elements, that must be addressed in every mitigation plan. Among these 12 elements is the collection of baseline information for the impact site. In keeping with this requirement, a geomorphological assessment of the entire reach of London Creek and its tributaries within the impact zone should be conducted. This geomorphological assessment should include, but not be limited to, the following:

  • Dimension, pattern and profile features of London Creek and its tributaries,
  • Bankfull width, discharge and velocity of London Creek,
  • Substrate analysis for London Creek and tributaries, and
  • Inventory of riffle/pool complexes, falls, shoal areas and woody debris in London Creek and tributaries.

These baseline monitoring parameters will be necessary to ensure that aquatic habitat quality in the mitigation reaches is commensurate with impacted reaches, and appropriate mitigation is provided to replace lost values and functions of London Creek and its tributaries if they are impounded.

In order to adequately mitigate all identified impacts, the Licensee will be required to develop a comprehensive mitigation plan. For impacts to the amount of wetlands and stream that will be involved to develop Pond C, such a mitigation plan should encompass more than simple wetland and stream impact restoration and compensation. DNR requests continued discussion with the Licensee and appropriate regulatory agencies regarding mitigation to include identification of the potential impacts to fish, wildlife and habitat resources by the construction of Pond C. (0036-12 [Vejdani, Vivianne])

Comment: DNR has concluded the Licensee has conducted a thorough and exhaustive review of the need for obtaining additional water supply for safe operation of the proposed facility during periods of extreme drought. A number of the alternatives that have been put forward for additional water supply represent engineering solutions exceeding the capability for DNR analysis. DNR is satisfied the Licensee has identified the least damaging alternative to natural resources for provision of additional water supply based on comparison of alternative supplemental water supply options. (0036-13 [Vejdani, Vivianne])

Comment: The proposed Pond C would back up to and interface directly with the Lake Cherokee dam, thus resulting in a number of potential impacts, such as the need for modification of the existing dam and emergency spillway, fencing and rip-rap of the down slope.

DNR and the Licensee have been engaged in productive discussion regarding avoidance and minimization of impacts to Lake Cherokee and its public use. (0036-3 [Vejdani, Vivianne])

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Comment: There is not enough water from the river to feed additional nuclear plants; the water will be needed for drinking and growing food. During extended drought, the units will have to be taken off line when the pond water runs out. (0037-5 [Breckheimer, Steve])

Comment: Duke and SCG&E are planning to expand Cliffside Coal Plant and want to add 5 new nuclear reactors (2 at Lee in Gaffney and 3 at Summer in Jenkinsville) on the mis-named Broad River, perhaps hoping that there will be no droughts such as those in 2005 and 2008.

This jeopardizes the entire Broad River watershed and drinking source for Columbia, SC -- and other farms and towns downstream, all the way to the Atlantic. (0038-1 [Thomas, Ellen])

Comment: The C-Pond would wipe out a substantial piece of forest, and would be dependent upon a stream which is known to have dried up during the drought of 2008, or (if pumped out of the Broad River) would significantly reduce the amount of water that would be needed downstream for agriculture and drinking water. (0038-5 [Thomas, Ellen])

Response: In the EIS, the review team will describe Make-Up Pond C, disclose the impacts to water resources, and discuss possible alternatives that would either eliminate the need for Make-Up Pond C or reduce its impacts. In Chapter 3, the review team will describe Make-Up Pond C and the dam that will impound the water that will form Make-Up Pond C. In Sections 4.2.1 and 5.2.1, the review team will discuss alterations of the hydrological system that will result during the development of Make-Up Pond C and during the operation of Make-Up Pond C, including the projected changes in downstream flows and the overall water budget for the plant during operation. In Sections 4.2.2 and 5.2.2, the review team will disclose the impacts to water resources, including downstream flows under current and reasonably foreseeable future conditions. In Section 9.4, the review team will discuss possible alternatives to the proposed system design that could either eliminate the need for Make-Up Pond C or reduce its impacts.

Comment: I see from the report you sent me that this is probably a useless exercise once again since this public comment supplemental scoping process is designed to weed out anything but comments on Make-Up Pond C for which you admittedly do not provide clear or easily-accessed information (size of pond relative to evaporation needs of reactor over the life of the said reactor(s), impacts on source and disbursement of pond water or radioactive contaminants expected, effects on environment in best and worst case-scenarios, etc.)

(0010-8 [Arnason, Deb])

Response: As stated in the response above, the draft EIS will present the results of the review teams analysis of environmental impacts associated with construction and operation of the proposed Lee Nuclear Station and Make-Up Pond C. The NRC maintains a webpage that contains links to documents associated with the Lee Nuclear Station COL review -

http://www.nrc.gov/reactors/new-reactors/col/lee.html - including Dukes Environmental Report, 30

the supplement to the Environmental Report regarding Make-Up Pond C, responses to the NRCs requests for additional information, meeting notices and summaries, and other information.

Comment: Can you tell me if the proposed new impoundment is on the Lee reactor site or actually on the Broad River itself? (0002-1 [Clements, Tom])

Response: The proposed Make-Up Pond C would be located northwest of the Lee Nuclear Station on London Creek, a tributary of the Broad River.

6. Comments Concerning Hydrology - Groundwater Comment: We are also on well water. The last time they were blasting and working at that site, some people in the area lost their wells and water. What are your plans to see we have plenty of safe water? Who should we contact in case we have a problem with our water supply?

(0033-2 [Pennington, Lee])

Response: The purpose of the EIS is to disclose the environmental impacts of constructing and operating the proposed Lee Nuclear Station. Section 2.3 of the draft EIS will address groundwater resources and Sections 4.2 and 5.2 will address potential impacts to groundwater during construction and operation of the proposed Lee Nuclear Station. The NRC has no jurisdiction over the business practices of private entities, and issues regarding these private business practices will not be addressed in the EIS.

7. Comments Concerning Ecology - Terrestrial Comment: ...how many trees are going to be cut during construction of the lake? And as far as I'm aware, this is a forested area. So a square mile of forest is going to be lost in South Carolina due to the construction of this lake. (0001-31-15 [Clements, Tom])

Comment: You are clearing for the lake and the site? (0033-4 [Pennington, Lee])

Response: Land will be cleared both for construction of the proposed Lee Nuclear Station and for Make-Up Pond C. The Make-Up Pond C area is largely forested. Land clearing impacts for both will be addressed in Chapter 4 of the EIS.

Comment: We already have a problem with wild animals in this area. What are doing about the animals in the area? (0033-3 [Pennington, Lee])

Response: It is unclear to which local wild animal problem the comment refers; therefore, the comment cannot be specifically addressed. However, the potential effects of the construction of the proposed Lee Nuclear Station on invasive biota will be addressed in Chapter 4 of the EIS.

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Comment: Sufficient information has been provided by the Licensee to evaluate the impact of the proposed Pond C on vegetation and cover. In addition to these studies, the Licensee hosted a 2-day site visit to allow DNR staff botanists to conduct a preliminary assessment of vegetation at the London Creek site. DNR personnel observed the London Creek riparian corridor to be minimally disturbed as compared with similar sites in the foothills of the upstate. While the ridge tops are impacted by silviculture practices, the steeper, north-facing bluffs demonstrate little disturbance. The lack of invasive, exotic species attests to the site's relative integrity.

(0036-5 [Vejdani, Vivianne])

Response: Biological information from available sources, including Duke and the South Carolina Department of Natural Resources will be used to describe the plant and animal communities in the Make-Up Pond C area in Chapter 2 of the EIS. A discussion of existing disturbances to and the relative integrity of extant terrestrial resources (including invasive species) in the Make-Up Pond C area will also be included.

Comment: The ER Supplement states that London Creek and its associated tributaries and forest cover likely provide a localized travel corridor for some species to and from the Broad River (Ninety-Nine Islands Reservoir) floodplain. This area is a travel corridor for migrating passerine birds which have been demonstrated to use major rivers and associated riparian corridors during migration periods. (0036-6 [Vejdani, Vivianne])

Comment: 2.4.1.2.2 Birds The following observations were noted:

  • A high number of migrant songbird species were observed, indicating that a diversity of migrant species use the forested stream corridor during migration. The connectivity of forested wetlands and river systems has been demonstrated to be important to neotropical migrants.

Forested areas are used because they provide the highest density of food resources. Migrant birds have, in some cases, flown thousands of miles and are building reserves to reach breeding grounds and successfully reproduce;

  • The widths of riparian stream zones at the London Creek site provides mixed hardwood forest habitat that is becoming more limited in the upstate; and
  • Steep rock formations create cove systems within the London Creek site, south of where they are commonly located, contributing to a diversity of habitat for bird species.

(0036-7 [Vejdani, Vivianne])

Response: Biological information from available sources, including Duke and the SCDNR, will be used to describe the plant and animal communities and their functions in the Make-Up Pond C area in Chapter 2 of the EIS. A discussion of migratory bird use of the London Creek watershed as a travel corridor to and from the Broad River floodplain; the contribution of wide riparian corridors to the relative integrity of the Make-Up Pond C area; and the contribution of cove systems to the diversity of avian habitat also will be included. Potential impacts to these communities from construction and operation of the proposed Lee Nuclear Station will be discussed in Chapters 4 and 5 of the EIS.

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Comment: Results of the herpetology study conducted by the Licensee's consultant indicate that, of 66 species that potentially occur onsite, 41 of these species were documented onsite (approximately 60% of potential species). The list of potential species comprised 25 amphibians and 41 reptiles. The study documented the presence of 19 amphibian species (76% of the potential species) and 18 reptile species (43% of the potential reptile species). Observing such a high percentage of potential species within a 1.5-year sampling period is an indication that the site supports a relatively healthy and diverse amphibian and reptile assemblage. Likewise, the salamander diversity observed at the London Creek site also is indicative of a relatively healthy and functional system. The herpetology survey documented 8 of 11 potential salamander species (72% of potential species). (0036-8 [Vejdani, Vivianne])

Response: Herpetofauna communities in the Make-Up Pond C area will be described in Chapter 2 of the EIS. A discussion of the diversity and relative integrity of the herpetofauna communities will also be included.

Comment: The Licensee proposes a 300 ft buffer around the Pond, 50 ft of which is proposed to be cleared, grubbed, grassed and maintained to prevent debris from washing into the reservoir. DNR concurs with the proposed 300 ft buffer but does not support clearing, grubbing, grassing and maintaining a 50 ft buffer adjacent to the shoreline. Pond C would likely naturalize and support a variety of aquatic life and wildlife. Riparian zones perform numerous ecological functions to include, but not be limited to: riparian plant communities provide excellent food, cover, and nesting sites for a variety of wildlife species and detritus and woody debris are an important source of energy and cover for aquatic life. Canopy cover helps to maintain water quality by reducing surface water temperatures. Riparian zones function as biofilters and remove nutrients and other pollutants from stormwater runoff before it enters rivers, lakes and streams. DNR looks forward to continued discussion with the Licensee in order to explore other alternatives for preventing debris from entering intake structures. (0036-2 [Vejdani, Vivianne])

Response: The NRC has no jurisdiction over land-clearing practices by Duke. Disposition of the 50-ft cleared buffer that was proposed all the way around and adjacent to Make-Up Pond C remains under discussion between Duke and the South Carolina Department of Natural Resources. The resolution of this issue and any associated impacts will be addressed in Chapter 4 of the EIS.

8. Comments Concerning Ecology - Aquatic Comment: DNR conducted a fisheries survey of London Creek per South Carolina Stream Assessment protocol on 12 May 2010. Eighteen species were collected during this sampling event (17 native species), including 4 state conservation priority species. The fish assemblage was similar overall to that reported by the Licensee from their 2008-2009 fish survey. No additional species to those reported by the Licensee were discovered. The sample section was 33

well forested and exhibited habitat conditions consistent with an intact Outer Piedmont watershed with substrate heterogeneity. At the time of DNR sampling, flows were above average. Sampling conducted by the Licensee did not demonstrate the presence of piscivorous fish in London Creek. (0036-10 [Vejdani, Vivianne])

Comment: Twenty-eight crayfish collections were made by Duke Energy in 2008 and 2009; these were collected and examined in May 2010 to determine species composition. In addition, crayfishes were sampled by DNR and Duke Energy personnel in 2010. Crayfishes collected from London Creek in the area proposed for impoundment (Pond C footprint) included:

  • Cambarus sp. cf. acuminatus (Cambarus sp. C) (listed in the ER Supplement as Cambarus acuminatus; it is an undescribed species being studied by John Cooper at North Carolina State Museum of Natural Sciences),
  • Cambarus reduncus (species collected by Duke Energy but not listed in the ER Supplement), and
  • Procambarus acutus None of the crayfish species are of conservation concern in South Carolina. ...Neither shells nor live individuals of any native freshwater mussels were encountered during any of the surveys conducted by DNR in 2010, and they were not discovered by the Licensee during the 2008 and 2009 surveys; thus, London Creek does not appear to support any native mussel species.

(0036-11 [Vejdani, Vivianne])

Comment: The Licensee conducted surveys for fish and macroinvertebrates in 2008. These surveys provide sufficient information regarding fish and macroinvertebrate resources. In addition to this information, DNR conducted a preliminary assessment of fishery and macroinvertebrate communities of London Creek and its tributaries. This assessment revealed that the proposed reservoir will represent the loss of intact Piedmont watershed and associated aquatic habitats and species. Overall, London Creek currently exhibits physical conditions consistent with a quality Piedmont stream, including a forested riparian corridor, channel sinuosity and habitat (riffle/pool) diversity, and coarse, clean substrate composition. London Creek is subject to the fluctuating flows typical of similar Piedmont streams.

(0036-9 [Vejdani, Vivianne])

Response: Biological and physical information from available sources, including Duke and the South Carolina Department of Natural Resources, will be used to describe the aquatic communities in and around London Creek in Chapter 2 of the EIS. Potential impacts on these communities from construction and operation of the proposed Lee Nuclear Station will be addressed in Chapters 4 and 5 of the EIS.

Comment: One of the more challenging hurdles is the issue of minimum release (minimum in-stream flows) from any proposed reservoir. This minimum release is being required by a 34

number of different organizations and resource agencies, including the US Fish and Wildlife Service (USF&WS). We trust that the USNRC and the USF&WS will impose the same requirements for minimum release if the Pond C option is pursued. CCW has discovered that this minimum release, depending upon the number, can have a major impact on the safe yield of any reservoir. The minimum release could impact the size of the proposed 620 acre pond C reservoir. (0035-4 [Smith, Clyde E. (Butch)])

Response: The NRC does not impose requirements for minimum in-stream flow; however, construction and operation of Make-Up Pond C would require permits from the USACE (Clean Water Act, Section 404) and the South Carolina Department of Health and Environmental Control (Clean Water Act, Section 401) and these agencies could require a minimum in-stream flow. Because the EIS will likely be finalized before such permits are obtained, details of minimum flow requirements, if any, will not be included in the EIS. However, the potential for minimum flow requirements and the potential impacts of station operation on Make-Up Pond C and London Creek will be addressed in Chapter 5 of the EIS.

Comment: And what is the impact to the river of water discharged during low flow that has been heated up, as we've heard before from other speakers, in the lake before it's discharged into the river, if it in fact is discharged? (0001-31-12 [Clements, Tom])

Comment: What's the impact of siltation to the river during construction...

(0001-31-14 [Clements, Tom])

Comment: "Thermal pollution" kills plants, fish, and other organisms, stressing the entire environment. The proposed W.S. Lee nuclear power plant could withdraw 47 million gallons of water per day from the Broad River and return only 1/4 back to the river. Hot water discharge and the release of radioactive contaminants and hazardous chemicals threaten wildlife and human health. (0013-4 [Thomas, Ellen])

Response: The review team will consider water-quality impacts resulting from construction and operation of the proposed Lee Nuclear Station on the Broad River, including siltation and temperature (thermal) effects, in Chapters 4 and 5 of the EIS. Cumulative water-quality impacts from the proposed Lee Nuclear Station will be addressed in Chapter 7 of the EIS.

Comment: The Broad River is an irreplaceable resource to our state, providing a unique suite of habitats critical for both wildlife and outdoor recreation. In this reach of the Broad River we have one of the state's few small mouth bass fisheries. (0032-1 [Gregg, Ben])

Response: The Broad River as it relates to wildlife resources and recreation, including the smallmouth bass (Micropterus dolomieu) fishery, will be addressed in Chapter 2 of the EIS.

Potential impacts on these resources from construction and operation of the proposed Lee Nuclear Station will be addressed in Chapters 4 and 5 of the EIS.

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Comment: The availability of Make-Up Pond C will essentially establish a floor for withdrawals from the river under these severe conditions. Shifting to Make-Up Pond C will, therefore, substantially mitigate the impacts of the proposed LNS operations during these especially sensitive periods, thereby providing for baseflows protective of recreational and riparian needs downstream, as well as for habitat and wildlife. (0032-3 [Gregg, Ben])

Response: The potential impacts on downstream habitats and recreational activities from Make-Up Pond C operation during drought periods will be addressed in Chapter 5 of the EIS.

9. Comments Concerning Socioeconomics Comment: But let's not overlook the other factors that Lee Nuclear Station will bring to this area: the 700-plus jobs that will be permanent for operation of the plant and the average salary that will approach $70,000. The majority of the employees will live in the county; they will spend their money in the county. There will be an influx of approximately 1000 to 1500 additional personnel each year for refueling needs, which will also generate additional revenue in the form of purchasing of food, living accommodations, and other items. There will be several million dollars that will be collected by the county for property taxes. These taxes will be used to improve schools, and as we all know, we do need improvements in our school systems. There will be operating expenses that will be met for the school systems. It will also help fund county services. (0001-13-2 [Boger, Paul])

Comment: So one point that I want to bring from a worker that I know in Texas about jobs is that while there may be 400 jobs advertised and there may be a multiplier effect that we've heard about this evening from various people, the other multiplier effect is the spouse who comes without a job, because most of these 400 people will move into the area because they require specialized training that's not available in the local community, and they bring with them a spouse and very often one or more teenagers, all of whom are looking for jobs. So you get 400 jobs and about 800 job seekers, so the net for Gaffney is not necessarily an increase in employment -- Gaffney, Blacksburg, this general area. (0001-15-2 [Olsen, Mary])

Comment: And then all of the major big reactor parts, the vessel and all those things, are made in Japan or South Korea. They have to be ordered years in advance and brought here. We don't make them; we don't have forges big enough in this country. We lost our steel industry -- our big forges years ago.

And so none of this stuff is actually made in the United States. All those jobs, all that money that we're spending to buy that is going to foreign countries. (0001-30-3 [Corbett, Susan])

Comment: Lee Nuclear Station will benefit our state in other ways, namely by creating thousands of construction jobs, providing hundreds of well paying jobs for decades to come, stimulating the local economy through the addition of service jobs to support the nuclear plant 36

and its workers, and providing a low-cost, safe, reliable, carbon-free, environmentally responsible source of electricity to our citizens.

(0007-1 [Littlejohn, Lanny F.] [Moss, Dennis Carroll] [Moss, Steve] [Peeler, Harvey S.])

Comment: I have worked several outages within the industry and know how beneficial these plants could be not only to the local economy there in Gaffney but to the entire upstate region.

(0026-2 [Cross, John])

Comment: These proposed plants in the Gaffney area would create an economic boon like nothing that has been experienced in the area and would create hundreds of permanent jobs and the opportunity for many other jobs for the re-fueling outages and work that comes with it.

Locoal [sic] housing would benefit, local business and hotels would benefit, local economy as a whole would benefit and South Carolina get s new, clean, viable power source.

(0026-5 [Cross, John])

Comment: Not only will these plants boost the local economy like never before it will sub -stain a large number of Full time jobs to the area but also will see added temporary jobs during re-fueling and so on. I think that It not need mentioned but this area of the country has lost many of its local jobs to the overseas textile industry causing many local residents to be un-employed.

(0027-2 [Mixon, Michael C.])

Comment: Workers to run the plant will be brought in from outside the county and will not employ Cherokee County residents. (0037-6 [Breckheimer, Steve])

Comment: Because of the economy, Duke Power is dredging up support in communities near the proposed plant with promises of jobs and cheap energy. Both of these promises are suspect. (0038-2 [Thomas, Ellen])

Comment: Historically, most of the people who build and maintain nuclear power plants are seasoned workers who come from other places. They bring families into the community who compete for existing jobs. Once the plant is built, the construction crew will either leave town or be unemployed. (0038-3 [Thomas, Ellen])

Response: Regional socioeconomic impacts such as impacts on the economy, employment, taxes, housing and schools associated with the construction and operation of the proposed Lee Nuclear Station will be considered in Chapters 4 and 5 of the EIS.

Comment: I would like to see nuclear energy developed in this area. There really is no economic development going on here at this time. I own a 5800 square foot commercial building on Old Georgia Highway in Gaffney and there is no market for it or other similar buildings because there is no new industry in the area. (0024-1 [Smith, Brian])

37

Comment: I am thankful that the Duke-Cliffside Modernization Project has provided many jobs for not only NC but also SC and surrounding states and a much needed update to this facility.

(0025-3 [Thrift, Debbie])

Response: These comments generally express support for the proposed action based on the potential positive socioeconomic impacts it would be expected to bring to the region.

Socioeconomic impacts from construction and operation of the proposed Lee Nuclear Station will be addressed in Chapters 4 and 5 of the EIS.

Comment: What happens as population, agriculture needs grow? Will these containment ponds continue to be licensed? (0001-20-2, 0009-2 [Bliss, Rachel])

Response: Socioeconomic impacts, such as population growth, will be addressed in Chapters 4 and 5 of the EIS.

Comment: The ER Supplement indicates the Licensee proposes no public use of the proposed reservoir. DNR appreciates the sensitive nature of operation of a nuclear generation station, however, London Creek constitutes waters of the U.S. and any impacts to it for purposes of a reservoir the size of the one being proposed should include an examination of compatible public use opportunities. These compatible public use opportunities might include fishing and boating opportunities and other compatible appreciative uses along the northern boundary, etc. DNR looks forward to continued discussion with the Licensee regarding potential, compatible public use opportunities on a portion of the proposed Pond C. (0036-4 [Vejdani, Vivianne])

Response: Recreational impacts will be addressed in Chapters 4 and 5 of the EIS. Providing public access for recreational activities on or within Make-Up Pond C is outside the scope of NRCs regulatory authority. The USACE role in the EIS as a cooperating agency on the EIS will be addressed in Section 1.3 and its discussion of environmental impacts related to the Clean Water Act in Section 9.5.

10. Comments Concerning Historic and Cultural Resources Comment: Based on the description of the Area of Potential Effect (APE) for the project and the identification of historic properties within the APE, SHPO concurs with the assessment that no historical properties listed in or eligible for listing in the National Register of Historic Places will be adversely affected by this project. Also, SHPO concurs with the recommendation for the plans to relocate the Service Family Cemetery (38CK142).

Our office is reviewed the eligibility of the Cherokee Falls Mill Village, as proposed in the survey.

We have determined that the village is not eligible for listing on the National Register of Historic Places. (0020-1 [Wilson, Caroline D.])

38

Response: Historic and cultural resources will be addressed in Chapter 2 of the EIS, and impacts on these resources will be discussed in Chapters 4 and 5. The South Carolina State Historic Preservation Officer's concurrence with the assessment of no historic properties adversely affected within the area of potential effects for Make-Up Pond C, concurrence with plans to relocate the Service Family Cemetery, and assessment of the Cherokee Falls Mill Village as ineligible for listing on the National Register of Historic Places will be incorporated into these chapters as part of compliance with the National Historic Preservation Act, Section 106 review process.

Comment: [Flooding the area for Make-Up Pond C ... ] could cover unique archeological sites.

Any environmental impact study should include an archeological survey of the area.

(0037-8 [Breckheimer, Steve])

Response: The Make-Up Pond C project area has been surveyed for historic and cultural resources, including an inventory and assessment of archaeological sites. The results of this survey will be summarized in Chapter 2 of the EIS and impacts will be addressed in Chapters 4 and 5.

11. Comments Concerning Health - Radiological Comment: I'd like impact on source and dispersement of pond water or radioactive contaminants that you expect. I'd like the effects on the environment in the best- and worst-case scenarios, just like this BP thing would certainly have been avoided if something had been looked into beforehand. (0001-6-3 [Arnason, Deb])

Comment: I'm talking about uranium 235 and plutonium. Just as an example -- and of course these plants turn out a couple hundred isotopes of various half-lives. But look at 238, the so-called depleted uranium. It's all over the Middle East from these shells that were used to penetrate tanks, and they're pyrophoric, so they vaporize, and they float off in the air, and they're in the ground, and the children play in them.

238: It is a half-life of 4-1/2 billion years. That's the half-life of 238: 4-1/2 billion years. How old is this planet? 4-1/2 billion years. Not to worry; it'll be safe in ten half-lives, which is 45 billion years. Some of us aren't going to be here then.

So we have contaminated -- we have already contaminated this earth, the only one we've got, forever. This earth is permanently contaminated with radiation. Everybody in this room -- I'm a doctor, and I've looked into this. Everybody in this room has got some strontium-90 in his bones

-- his or her bones.

39

Your bones, of course, surround your bone marrow, which makes your red and white cells and your platelets, and exposure to radiation by white cells results in leukemia, so the leukemia rate is bound to go up over the years. I'm sorry to say this, but we're all contaminated.

(0001-25-4 [Richardson, Don])

Comment: There is no safe level of radiation. Any potential leak threatens our water and the entire Broad River watershed (0003-5 [Hale, Kendall])

Comment: I personally would not want to drink water that has just earlier that day been used to cool a nuclear power plant. (0009-5 [Bliss, Rachel])

Comment: There is no "safe" level of radiation which can damage reproductive cells and lead to genetic mutations and cancer, damage the immune system, cause leukemia and more (World Health Organization) (0013-5 [Thomas, Ellen])

Comment: U238, has a half-life of 4.5 billion years, the age of our planet. Not to worry, we'll be safe after 10 half-lives, 45 billion years from now. We have thus contaminated Earth forever already, and everyone in this room has some Sr-90 in his or her bones, exposing bone marrow to the risk of leukemias and related malignancies and morbidity (0015-5 [Richardson, Don])

Comment: the potential for such facilities to pose the threat of severe damage to the environment and to human populations ... mitigate against the development of nuclear production and delivery services. (0023-3 [Drake, Joan W.])

Comment: I would not be interested in drinking water or eating fish from the Broad River if I were anywhere downstream of Gaffney. (0038-7 [Thomas, Ellen])

Comment: Blue Ridge Environmental Defense League opposes this project for a variety of reasons: Harmful radioactive pollution is released into the air and to the water from nuclear power plants on a routine basis. Of course, highly toxic radioactive waste is also stored on site in pools of water. (0001-9-1 [Zeller, Lou])

Comment: There is great potential for release of radiation into the atmosphere (0037-3 [Breckheimer, Steve])

Comment: [There is great potential for release of radiation into the ... ]water from nuclear plants (0037-4 [Breckheimer, Steve])

Comment: Our water supply is threatened by the potential for leaking radioactivity from the reactor (documented at dozens of sites today) (0013-9 [Thomas, Ellen])

Comment: I think of the plant in North Carolina that had to flush out its pipes in the midst of a hurricane, flooding farmlands and pig farms with radioactivity. (0038-8 [Thomas, Ellen])

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Response: These comments concern possible health effects from radiation exposure.

Chapter 5 of the EIS will address the potential radiation doses and the associated health effects from operation of the proposed Lee Nuclear Station. Impacts related to storage of radioactive waste will be addressed in Chapter 6 of the EIS. Cumulative radiological impacts will be described in Chapter 7. The NRC's regulatory limits for radiological protection are set to protect workers and the public from the harmful health effects of radiation on humans. These radiation standards reflect extensive scientific study by national and international standards-setting organizations, and incorporate conservative assumptions and models to account for differences in gender and age to ensure that workers and all members of the public are adequately protected from radiation.

12. Comments Concerning Accidents - Severe Comment: The history of production of nuclear energy is replete with ... accidental threat of radiation exposure to human populations and to the environment (0023-6 [Drake, Joan W.])

Comment: This location is within 50 miles of some 2.3 million people, including thousands of members of Sierra Club, both in North and South Carolina, who could be impacted by any serious nuclear incident at this facility (0029-1 [Thomas, Bill])

Comment: And so it's not clean and it's not safe. I mean, anytime, you know, Chernobyl or some Three Mile Island accident could happen. (0001-19-3 [Richards, Kitty-Katherine])

Comment: And you know what, if the Gulf oil spill has taught us anything, it's taught us that the worst case scenario can happen; it will happen eventually. We've been very lucky in this country that it hasn't happened. This community better get your evacuation plans well in hand and know where you're supposed to go. You better get your iodine pills and be ready. If nothing else, we've learned that complex systems can fail in complex ways that we can't even imagine.

(0001-30-10 [Corbett, Susan])

Comment: Catastrophic consequences of nuclear reactor failure come to mind i.e., Chernobyl and Three-Mile Island. (0034-3 [Hallock, Judith])

Response: The comments concern the potential for severe accidents at the proposed Lee Nuclear Station. The environmental impacts of postulated accidents, including severe accidents, will be addressed in Chapter 5 of the EIS.

13. Comments Concerning the Uranium Fuel Cycle Comment: And then we need to disclose about the waste as well, because every form of power that uses fuel makes waste. In the case of uranium fuel, its waste that can cause cancer, birth defects, nobody wants it. And I'll go on record that western North Carolina does not want a 41

granite repository, thank you very much. But I think it's time that the federal regulators that come out and talk to local communities about new waste generation happening in addition - you know, that's why you're going to withdraw all this water, is to cool that core to be sure that the nuclear meltdown doesn't happen. So, good, we're making waste, and so the regulator needs to disclose that the same regulator is considering changes its own regulations to make what is currently 120 years of temporary storage up to 300 years of temporary storage, because there is no plan for what to do with the waste that would be generated at the William States Lee site.

So does the local community know that you are being sited with not only a pond and a nuclear power plant but also a temporary storage site for waste up to 300 years.

(0001-15-9 [Olsen, Mary])

Comment: ...there's also the question of waste. If the Lee station goes on line, it will be a high-level nuclear waste dump for the foreseeable future, and that's just the facts.

(0001-23-3 [Hildebrandt, Lorena])

Comment: I'm worried about the waste. Barnwell is closing in 2038, so the waste that's generated here will not be able to go there after 2038. (0001-30-5 [Corbett, Susan])

Comment: They've been kicking this nuclear waste can down the road for over half a century.

They are no more equipped to deal with it now than they were when they started. They had to commission a blue-ribbon commission to study it again. It's ridiculous.

(0001-30-7 [Corbett, Susan])

Comment: Nuclear waste is very dangerous, lasts for years and we have no where to store it because of NIMBY. (0003-6 [Hale, Kendall])

Comment: Nuclear waste remains radioactive for millions of years; we still need effective nuclear waste management (0013-3 [Thomas, Ellen])

Comment: William States Lee if it goes on-line will be a high-level nuclear waste dump for the foreseeable future. (0014-5 [Olsen, Mary])

Comment: [Nuclear power] ... produces hazardous and long lasting waste...

(0017-3 [Hicks, Katie])

Comment: The permanent storage of radioactive waste remains unsolved regardless of the passage of federal legislation. (0021-6 [Barnett, Barbara A.])

Comment: the difficulties entailed in managing toxic waste disposal from such production, all mitigate against the development of nuclear production and delivery services.

(0023-4 [Drake, Joan W.])

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Comment: The history of the production of nuclear energy is replete with ... extreme difficulty in designing, managing, and securing facilities and effective processes for the disposal of toxic waste. (0023-7 [Drake, Joan W.])

Comment: There is still no resolution of the issue of safe disposal of long-lived hazardous nuclear waste from reactors in our nation, meaning that radioactive wastes will be stored on site as at other nuclear plants, adding to the hazards of the reactors themselves; and (An NRC study in 1997 calculated a fire in a spent fuel pool could produce 54,000 to 143,000 cancer deaths and would render 2,000 to 70,000 square kilometers of Agricultural Land uninhabitable.

(Caldicott, Nuclear Power is not the Answer, p.99-105)) (0029-2 [Thomas, Bill])

Comment: In the broader picture, I am concerned with nuclear power production related to uranium mining and the high-level nuclear waste production and storage.

(0034-2 [Hallock, Judith])

Comment: There is still no good plan for disposal of the radioactive waste that we already have let alone the waste from additional nuclear facilities. (0037-2 [Breckheimer, Steve])

Comment: Nuclear power reactors create plutonium which can be used to make bombs. It is one of the most toxic man-made substances known, remaining radioactive for more than 240,000 years (0013-6 [Thomas, Ellen])

Response: These comments concern the disposal of both low- and high-level radioactive waste, and the consequence of closing the Barnwell, South Carolina, low-level radioactive waste disposal facility. The impacts of the uranium fuel cycle, including interim storage and ultimate disposal of spent fuel and other radioactive waste, will be discussed in Chapter 6 of the EIS.

Comment: Uranium mining does create a lot of pollution in itself, and it's getting harder and harder to mine good stuff, so it costs more and more, and the processing of it, the mining of it, the transportation of it -- it's not clean. Obviously it does have a lot of radioactive waste that we have to deal with for hundreds of thousands of years with deformed children and babies and cancer and all this kind of stuff. (0001-19-2 [Richards, Kitty-Katherine])

Response: The comment concerns the potential for health impacts from radiation exposure from uranium mining. The impacts related to the uranium fuel cycle will be addressed in Chapter 6 of the EIS.

Comment: And, you know, when President Obama, who has tried to do some good things for the country, you know, I think, but when he keeps saying that nuclear waste is going to be recyclable -- you know, they're going to make sure that they can find a way to do that -- you 43

know, let's keep speaking out and saying, Where's your proof? You know, where have you got this genius scientist that has come up with a way? -- because it's not in existence.

(0001-19-4 [Richards, Kitty-Katherine])

Response: The comment concerns the potential for recycling spent nuclear fuel. The potential environmental impacts of the fuel cycle from recycling only the uranium from spent nuclear fuel will be addressed in Chapter 6 of the EIS. Recycling uranium and plutonium from spent nuclear fuel will not be addressed in the EIS. While Federal policy no longer prohibits recycling, additional research and development is needed before commercial recycling of spent fuel produced by U.S. nuclear power reactors occurs.

Comment: There is no reduction in the carbon footprint, as far as I can tell, when we consider the entire life cycle of the project, from construction, permitting, mining, cooling, and disposing of waste. (0001-20-5 [Bliss, Rachel])

Comment: We came here to talk about Make-Up Pond C, but we're really talking about the environmental impacts of the Lee nuclear plant as well. As we all know, fission -- the fission reaction directly does not involve carbon. A lot of people have been talking about nuclear as a carbon-free alternative, and a lot of people have been talking about that it's not carbon free. The fact is that it's not carbon free. It uses processes that use carbon. (0001-22-3 [Fair, Gabriel])

Comment: An analysis of the entire nuclear fuel cycle, the entire cycle, from exploration to decommissioning and storage, the whole thing, is highly carbon intensive. It has a huge carbon footprint, but they only count the footprint while they're operating the plant, when they turn the key and operate that -- well, we'll just start counting it -- I mean, if you had a Land Rover and you drove to the top of Pikes Peak in Colorado and coasted into the valley and then looked at your gas mileage, you'd say, Hey, this thing's getting 200 miles to a gallon. Well, that's what the nuclear industry's doing. (0001-25-2 [Richardson, Don])

Comment: There is no reduction in the carbon footprint when we consider the entire life cycle of the project from construction, mining, cooling and disposing of waste. (0009-7 [Bliss, Rachel])

Comment: While nuclear plants in operation do not themselves release carbon dioxide or other Greenhouse gases contributing to the scientific expectations of global warming, they are not carbon neutral, as the mining and purification of uranium-derived fuels does produce these gases; (0029-5 [Thomas, Bill])

Comment: Uranium mining is highly toxic, and so are processing and reprocessing. The reprocessing which nuclear advocates may argue makes it renewable, produce obscenely toxic chemicals along with the electricity, horrific bi-products which somehow must be hidden for hundreds of centuries, or at least until some genius discovers how to harmlessly neutralize 44

radiation and toxic chemicals, which may take a very long time. All of these activities have a serious carbon footprint, so the allegation that nuclear power is clean is untrue.

(0013-7, 0038-6 [Thomas, Ellen])

Response: These comments concern the greenhouse gas emissions of the entire fuel cycle and operation of the proposed Lee Nuclear Station. The impacts of greenhouse gas emissions from the life-cycle of fuel production, construction, operation, and decommissioning of the units will be presented in Chapters 4, 5, and 6, and in an Appendix of the EIS.

Comment: The study that I am familiar with was written by Jan Willem Storm van Leeuwen, a Dutch engineer, and the late Philip Smith, an American engineer. They concluded that a small amount of net energy can be gotten from nuclear power by using the highest-grade ores. But of course we used the highest-grade ores first, and they're running out.

There may be no net energy using low-grade ores, but the industry keeps alive, because there's support for the spinoff of bomb materials; in other words, the production of things that we can't sanely use. (0001-25-3 [Richardson, Don])

Comment: But when you think about it, uranium really comes from Russia and Kazakhstan and Canada. The kind of uranium we have in this country is very low grade and requires a lot of enrichment and is expensive and stuff like that; plus they made a huge mess uranium mining out west. (0001-30-2 [Corbett, Susan])

Comment: Nuclear Power is not renewable. Uranium mining is highly toxic and needs to be imported from foreign countries. Again, creates dependency for the USA (0003-2 [Hale, Kendall])

Comment: [Uranium ... is...] imported from foreign countries (0013-8 [Thomas, Ellen])

Comment: Further, an analysis of the entire nuclear cycle, done by Jan Willem Storm van Leeuwen and the late Philip Smith, concluded that a small amount of net energy can be gotten from nukes by using the highest grade ores-which are running out-and that there may be NO net energy from the remaining low-grade ores. (0015-3 [Richardson, Don])

Comment: Uranium itself is a finite resource like coal and oil, so nuclear power is not a sustainable energy source for the long term, like solar and wind-based energy sources (0029-4 [Thomas, Bill])

Response: These comments concern the availability of uranium to fuel the proposed Lee Nuclear Station. The irretrievable and irreversible commitment of resources, such as uranium, will be addressed in the context of the availability of the resource in Chapter 10 of the EIS.

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14. Comments Concerning Transportation Comment: The transportation of radioactive materials, fuels and waste, to and from the site is itself a hazardous activity subjecting the surrounding population along the transportation routes to health hazards from any accidents and radiation releases (0029-3 [Thomas, Bill])

Response: The radiological and nonradiological impacts of transporting unirradiated fuel, spent nuclear fuel, and radioactive waste to and from the proposed Lee Nuclear Station and alternative sites will be addressed in Section 6.2 of the EIS.

15. Comments Concerning Decommissioning Comment: Where will they decommission this reactor? What will they do with it? Chances are this community will get stuck with it. (0001-30-6 [Corbett, Susan])

Response: Title 10 CFR 50.75 requires the applicant to provide reasonable assurance that funding will be available for decommissioning activities at the time it is needed. The environmental impact of decommissioning a permanently shutdown commercial nuclear power reactor will be discussed in Chapter 6 of the EIS. In addition, NRC staff may consider information from Supplement 1 to NUREG-0586, Generic Environmental Impact Statement on Decommissioning of Nuclear Facilities, published in 2002, when analyzing the expected impacts of decommissioning.

16. Comments Concerning Cumulative Impacts Comment: Duke Power and SCE&G are planning to build a coal-fired plant, Cliffside, and 5 Nuclear Reactors on the Broad River. (0003-7 [Hale, Kendall])

Comment: As the NRC is aware, Duke already operates five reactors here in SC and several more nearby in NC. In fact, SC is the most nuclear power reliant state in the SE and the 3rd most reliant in the country. Further, a host of nuclear waste and nuclear industrial operations are here in SC. The Savannah River Site near Aiken is the most radioactive Department of Energy site in the nation. The Barnwell nuclear dump is also a radioactive hot spot. Nowhere in the application does it discuss the cumulative impacts of having all these facilities operating in SC.

Nor does it discuss the cumulative health impacts to Carolinians. The NRC must address these cumulative impacts to water resources and human health if it is to make a truly informed decision on adding two more reactors into this already radioactive mix.

(0011-13 [Hancock, Mandy])

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Comment:

  • The National Environmental Policy Act EXPLICITLY recognizes "truncation" as a key issue when it comes to the potential for federal actions to negatively impact our environment - that the integrated totality of federal activity must be assessed - not just in pieces that exclude the larger picture
  • On what basis does the Federal Regulator justify holding a scoping hearing on TWO power plants that are but 1/3 of the projected federally licensed powers plants to be impacting the Broad River? Six power plants: Cliffside, Summer x 3 and William States Lee x 2 are all in licensing actions now. Why is there no process that will assess ALL of those impacts -

cumulative, synergistic and additive? (0014-1 [Olsen, Mary])

Comment: In fact, South Carolina is the most nuclear power reliant state in the Southeast and the third most nuclear-reliant in the country, with about 58% of its electricity produced by nuclear power. ... Nowhere in the application does it discuss the cumulative impacts of having all these facilities operating nor does it discuss the cumulative health impacts to Carolinians.

(0030-9 [Barczak, Sara] [Hancock, Mandy])

Response: Cumulative impacts result from the combined effects of the proposed action and past, present, and reasonably foreseeable actions, regardless of who takes the actions. The appropriate geographic area and time period for considering cumulative impacts depend on the resource being affected and will be determined for each resource as part of the review teams evaluation. The impacts of building and operating the proposed Lee Nuclear Station on the Broad River and adjacent lands would be added to other known or reasonably foreseeable actions and stressors within the defined geographic area of interest. The results of cumulative impact analyses will be presented in Chapter 7 of the EIS.

Comment: And the revised report doesn't even consider the future implications of climate change. (0011-10 [Hancock, Mandy])

Response: The cumulative impacts analysis contained in Chapter 7 of the EIS will also include the potential effects of global climate change.

17. Comments Concerning the Need for Power Comment: As a high-growth state, South Carolina needs additional safe and reliable electricity.

As serving as a member of the delegation of the local county development board, that's one of the big questions: Can we provide infrastructure and electricity for people that are desiring to move to South Carolina to provide jobs for our citizens. (0001-1-1 [Moss, Dennis Carroll])

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Comment: The growing need of energy to power our own world is becoming more and more important every day. The 2234 megawatts of power Lee Nuclear Station will generate can and will go a long way in meeting energy needs of the future. (0001-13-1 [Boger, Paul])

Comment: If we are to sustain the economic healing of plants devastated by the recession, encourage the expansion of those in other facilities, and attract more new plants and the high-paying jobs that they bring with them, we must have the infrastructure to support their operations. First and foremost on that list of essential infrastructure is energy. Traditional industries like paper, textile, and chemistry are well known for their energy consumption. South Carolina now has significant automotive, aviation and advanced materials operations. All of these industries have fantastic potential for future growth in the state, and all are heavy energy users. As manufacturing companies decide to locate or expand in the state, they will need assurances about the availability and reliability of energy.

(0001-14-2 [Hopper, Sara])

Response: These comments express general support for additions to new electric generating capacity in North Carolina and South Carolina such as the proposed Lee Nuclear Station.

However, these comments provide no new information relevant to the environmental review and will not be addressed in the EIS.

Comment: Further, the NRC needs use updated information to reevaluate Duke's analysis for the new reactors in terms of the need for power given the economic downturn and reduction in demand. (0011-6 [Hancock, Mandy])

Comment: Additionally, the NRC needs to consider all of Duke's new power plant proposals, such as the new coal unit proposed for the Cliffside plant in North Carolina and how that affects the need for the proposed new reactors. (0030-4 [Barczak, Sara] [Hancock, Mandy])

Comment: The base load estimates to justify the building of these units is flawed. With a little bit of effort from the government and Duke Power, we could reduce power consumption and avoid having to build two expensive and potentially dangerous power plants.

(0037-1 [Breckheimer, Steve])

Response: Affected states or regions may prepare a need for power evaluation and an assessment of the regional power system for planning or regulatory purposes. In North Carolina and South Carolina, the need for power analysis may also be prepared by a regulated utility company and submitted to a regulatory authority, such as a state Public Utilities Commission (PUC). This analysis, called the Integrated Resource Plan (IRP), contains details on energy efficiency, demand-side management, and peak power reduction strategies, all of which are considered conservation activities. The state PUC also has regulatory authority over issuance of the Certificate of Public Necessity and Convenience, as well as rates and rate recovery regarding the construction and operation of new power plants. Duke submitted its 48

most recent IRP to both North Carolina and South Carolina in October 2010 (ADAMS Accession No. ML102980199), and accounted for the Cliffside Station in out-year capacity and margin projections. When another agency has the regulatory authority over an issue, the NRC defers to that agency's decision. The NRC staff will review the need for power and determine if it is (1) systematic, (2) comprehensive, (3) subject to confirmation, and (4) responsive to forecasting uncertainty. If the need for power evaluation is found to be acceptable, no additional independent NRC review is needed. Need for power will be addressed in Chapter 8 of the EIS and alternative energy supply options will be further evaluated and addressed in Chapter 9.

The information provided in these comments will be considered to determine whether it significantly affects the forecast upon which Duke relied for its need for power analysis.

18. Comments Concerning Alternatives - Energy Comment: And I understand the local community wants benefits, but I'm here to say that you could get three to four times more benefit through instituting a truly green non-nuclear energy base here. The job numbers are spectacular around the world for the development of non-nuclear renewal energy, and also energy efficiency which is delivered; not just telling people to change their light bulbs but actually going into homes and helping people with stopping the leaks of their insulation, putting in additional -- better windows, better insulation, better light bulbs, upgrading appliances. The whole wad is a number of issues around how we're spending our money, how we're making our jobs and what the quality of life is. (0001-15-6 [Olsen, Mary])

Comment: Conservation of energy is the best solution to our energy needs. Energy use has decreased in recent years, especially in the Asheville area, and we see, as conservation takes hold -- I don't believe any new plants will be needed. (0001-20-4 [Bliss, Rachel])

Comment: If we're going to provide new energy plant to meet the needs of the future citizens of South Carolina, we need to consider the needs for renewable energy.

(0001-22-1 [Fair, Gabriel])

Comment: Ladies and gentlemen, we South Carolinians face a crisis. That crisis is ignorance, ignorance to our need to avert -- or invest, rather, in energy efficiency and alternative sources.

South Carolina is 25th in population but 19th in energy consumption per capita. To put that into perspective, California, which is the most populous state in the Union, is 47th in energy per capita, and yet they still use a lot, but we are using far more per capita. New York, which has the largest city in the country, is 27th. (0001-24-1 [Swinton, D.C.])

Comment: People often praise nuclear energy on - as our savior from fossil fuels: a clean, efficient source. However, it's nowhere close to efficient and is ridiculously costly.

49

Both boiling-water reactors and pressurized-water reactors, which is the one that Lee county would be -- or Lee Nuclear Station would be, rather, only run at 33 percent efficiency.

The site would have to tap into other plants in the area for energy in the event of an emergency, increasing the strain on those plants, which also happen to run around 33 percent efficiency.

Add on top of that our decrepit electrical transport grid, and you have one big ball of waste --

wasted energy, that is. (0001-24-4 [Swinton, D.C.])

Comment: Other alternative means of power generation can be brought on line in less time, provide many more construction jobs for many more companies, and are less risky, do not require large taxpayer liability subsidy, and do not hold a threat to my health, your health, and ecological health posed by operation of nuclear plants and centuries or more of storing toxic radioactive waste. (0001-27-1 [Howarth, Robert F.])

Comment: Another compelling reason for my opposition to any more construction of nuclear power plants is well illustrated by comparing them to other available functional and healthier means of electrical power generation, comparison in terms of EROEI. That a new one for you?

That is energy return for energy invested. This comparison reveals that nuclear is number 15 out of 20 candidates that are currently available. There are 15 -- this means that there are 14 available sources more desirable than nuclear energy in terms of overall efficiency. I have a source for that, and it's listed here.

That is -- this overall energy -- this overall efficiency assessment includes and is composed of a whole system consideration from the extraction at the source, processing, construction, operation of the delivery plant, and cost of any subsequent waste handling and/or disposal.

(0001-27-2 [Howarth, Robert F.])

Comment: And what irks me is that right up the road in Greenville we have a perfectly good GE wind turbine plant making huge wind turbines, and right off our coast we have a DOE-certified 4 million watts of offshore wind-power potential, just sitting there waiting for us to use our amazing Charleston port as a staging ground for the eastern coast wind farm.

Why aren't we doing this? They are doing this -- I just drove to Chicago two weeks ago for a nuclear waste summit, and on the way I drove through Lafayette, Illinois -- Indiana. It was amazing. I didn't know it was there; it just suddenly appeared on the horizon. It was hundreds of wind turbines, really as far as the eye could see. And it was in pasture, and there were cows grazing, and it was amazing. They were just turning very slowly. I don't know how much power. I went to go home and Google that; I never figured it out. But they're doing it in other places, and we keep talking about, well, we're going to research this, we're going to research it. We just need to do it.

50

And the same thing with solar. I mean, we have 300 sunny days in this state, you know?

(0001-30-4 [Corbett, Susan])

Comment: When alternatives exist that would provide energy in safer, cleaner and more sustainable ways, that would provide jobs and leave our children and our children's children a safer, cleaner future, why is nuclear energy even being considered? (0008-3 [Craig, Anne])

Comment: Conservation of Energy is the best solution to our energy needs. Energy use has decreased in recent years and we see as conservation takes hold, no new plants will be needed. (0009-4 [Bliss, Rachel])

Comment: If the NRC could be concerned with the pocket books of the American people (probably not your Department either), it would be looking at the economic benefits of production-based-incentives for distributed customer-supplied solar energy so rapidly successful in cloudy Germany, several US municipalities, Ontario, Canada and spreading world-wide. The truth is nuclear energy in its current form is NOT the solution to US sustainable, renewable, clean energy needs. (0010-7 [Arnason, Deb])

Comment: Utilities in South Carolina have more affordable ways to meet the region's increasing demand for energy while protecting our water resources and tackling global warming.

Promoting energy efficiency measures and investing more resources in the region's wind, solar, and bio-energy industries instead of costly new reactors would benefit Duke Energy and offer economic development opportunities for the region, without draining our water resources or pocketbooks. The NRC must evaluate updated information on using a combination of these alternatives that are far less water intensive before allowing Duke Energy to commit billions of dollars, billions of gallons of water, and nearly an entire decade or more to building these reactors when that time and money could be better spent on less risky, more sustainable energy choices. (0011-3 [Hancock, Mandy])

Comment: Energy efficiency measures preserve our water resources, save consumers money and also pose no health or safety risks to the public. South Carolina utilities have significant resources to tap in these areas as outlined in a recent extensive report, Energy Efficiency in the South, by Georgia Tech and Duke University 1 and our report, Yes We Can: Southern Solutions for a National Renewable Standard. (0011-4 [Hancock, Mandy])

Comment: Renewable energy technologies, such as solar and wind, do not require extreme manipulation of our precious water resources. The revised Environmental Report still overlooks Duke's excellent wind resources within its service territory. The Clemson University Restoration Institute shows that South Carolina is poised to lead the charge toward renewable offshore wind energy with its high offshore wind capacity and to reap large economic benefits from the 51

manufacture of wind turbines. The NRC must evaluate a combination of energy efficiency, wind, solar, and clean bio-energy sources as a viable alternative to building expensive and risky new reactors. (0011-5 [Hancock, Mandy])

Comment: When comparing types of energy generation, nuclear power has higher rates of both water withdrawal and consumption than coal and natural gas and far more than renewable energy sources, such as wind and solar. An April 2010 report by the Georgia Institute of Technology and Duke University examined energy efficiency in the South and illustrated ways by which we could substantially reduce our energy needs, while simultaneously reducing our water consumption. According to the report: In the North American Electric Reliability Council (NERC) regions in the South, 8.6 billion gallons of fresh water could be conserved in 2020 (56%

of projected growth in cooling water needs) and in 2030 this could grow to 20.1 billion gallons of conserved water (or 45% of projected growth). (0011-8 [Hancock, Mandy])

Comment: Other alternative means of power generation can be brought on line in less time, provide many more construction jobs for many more companies, are less risky, do not require large taxpayer liability subsidy, and do not hold the threat to my health, your health, and ecological health posed by operation of nuclear plants and centuries of storing toxic radioactive wastes. (0012-2 [Howarth, Robert F.])

Comment: Meanwhile, cheaper, safer, job-rich and quicker alternatives are already growing exponentially as nuclear power fades away, and none of them is a terrorist target. They're decentralized and thus protected from failure. They are outperforming nukes every day.

(0015-2 [Richardson, Don])

Comment: [Nuclear power] ... cannot be built fast enough to be an effective climate solution in the short term. Cheaper, safer, more just alternatives - such as energy efficiency and conservation, solar, and wind - are a wiser investment. (0017-5 [Hicks, Katie])

Comment: In Western NC we have plentiful opportunities for energy efficiency and conservation, wind, and solar power. There is no need for such an unstable, expensive and water-intensive project. I urge you to investigate all the viable possibilities and not to permit these new reactors. (0017-7 [Hicks, Katie])

Comment: I also trust current comprehensive energy plans consider new energy generation in balance with reasonable implementation of reductions in energy consumption. Therefore, I encourage regulators to strongly recommend that comprehensive plans for new plants include consideration for incentives to encourage off-peak use, such as a significant reduced rate offering for off-peak residential uses (a profound positive initiative for seniors and other factions of the low income/unemployed facing uncertain economic futures... as it reduces residential consumption during peak hours ... ) (0019-3 [Mominee, Katharine N.])

52

Comment: I am also interested in the direction for renewable resources on the horizon. Rather than wind, is tidal energy under serious investigation? (0019-4 [Mominee, Katharine N.])

Comment: Nuclear power is a very costly enterprise, in fact, nuclear power would cost twice as much as renewable energy sources , e.g., solar, wind and geothermal power.

(0021-1 [Barnett, Barbara A.])

Comment: The NRC must evaluate these alternatives more thoroughly before allowing Duke Energy to commit the billions of dollars, millions of gallons of water, and nearly an entire decade to building these proposed reactors when that time and money could be better spent on less risky, more sustainable solutions. (0030-2 [Barczak, Sara] [Hancock, Mandy])

Comment: Duke's Environmental Report overlooks the excellent wind resources within its service territory. The Clemson University Restoration Institute shows that South Carolina is poised to lead the charge toward renewable offshore wind energy with its high offshore wind capacity and to reap large economic benefits from the manufacture of wind turbines. Wind, solar, clean bio-energy sources, and efficiency should be fully employed before building expensive and risky nuclear reactors. The NRC should evaluate the use of a combination of these energy choices in comparison to the proposed new reactors.

(0030-3 [Barczak, Sara] [Hancock, Mandy])

Comment: Duke Energy and its utility partners can meet demands using less water-intensive, affordable energy options. When comparing types of energy generation, nuclear power _has higher rates of both water withdrawal and consumption than coal and natural gas and far more than renewable energy sources, such as wind and solar. For example, according to the Department of Energy's National Renewable Energy Laboratory, developing just 1000 MW of wind in neighboring Georgia instead of traditional power plants could save 1628 million gallons of water per year. (0030-8 [Barczak, Sara] [Hancock, Mandy])

Comment: Why not spend the money on conservation and appropriate alternative energy and invest in a safe future for our children and grandchildren? (0034-4 [Hallock, Judith])

Response: The NRC does not establish or comment on public or private policy regarding electric power supply alternatives, nor does it promote the use of nuclear power as a preferred energy alternative. Decisions regarding which generation sources and alternatives to generation sources to deploy are made by Duke through least-cost planning and integrated resource plans. Additional regulatory purview is provided by bodies such as State energy-planning agencies, PUCs, and through State legislative actions. The discussion of various energy alternatives to the proposed project is pertinent to the extent that an energy alternative must reasonably be expected to meet the need for power as proposed (including the need for baseload power), whether singly or in combination. The alternatives must be technically viable and feasible. Chapter 8 of the EIS will include review of the need for power in the service 53

territory including the impacts of demand-side management and energy efficiency on the load forecast. Chapter 9 will include the no-action alternative (i.e., denial of a COL), energy conservation and efficiency, demand-side management, new generation alternatives, purchased electrical power, alternative energy technologies (including renewable energy such as wind, solar, and biomass), and the combination of alternatives. In addition, NRC staff is cognizant that information representative of current technology must be considered. For acceptable alternatives, the potential for environmental impacts will be assessed against that of the proposed project.

Comment: To create renewable energy sources, that would use carbon as well; however, the carbon in those is not -- is -- the carbon that is used in the Lee nuclear plant is -- from the start to the finish will be using carbon, and it's risky. (0001-22-4 [Fair, Gabriel])

Comment: Furthermore, comparison in terms of carbon footprint shows nuclear as having the third highest among these candidates, following only conventional coal and tar sands. It has a huge carbon footprint when you look at the whole ball of wax, the whole picture, which as I said I believe is the honest way to look at it. (0001-27-3 [Howarth, Robert F.])

Comment: In the current crisis to provide energy to meet our future needs, we demand that utilities utilize technologies to create an energy system that does not devour economic, environmental, and water resources. The inherent power in the Earth's environmental systems along with measures to reduce overall energy demand can provide the energy needed without degrading ecosystems and depleting life-necessary resources. There is an opportunity to do things differently and in smarter, non-radioactive ways. That opportunity must be seized for the sake of our communities and future generations. (0011-14 [Hancock, Mandy])

Comment: 350 parts per million is considered the safe upper limit of C02 in our atmosphere.

We are now at 392. Getting back to 350 means transforming our world. It means building solar arrays instead of coal plants, it means conservation is no longer the last resort, it means planting trees instead of clear-cutting rainforests, it means increasing efficiency and decreasing our waste. Getting to 350 means developing a thousand different solutions-and most of them will demand money. (350.org) (0016-6 [LeVander, Valerie])

Comment: It is very important that we reduce our dependency on foreign oil as quickly as possible. (0018-2 [McCall, Pat])

Response: The NRC is not involved in establishing energy policy; rather, it regulates the nuclear industry to protect public health and safety within existing policy. As part of its review of COL applications for new nuclear power plants under NEPA, the NRC does evaluate energy alternatives. Chapters 4, 5, 6, and 7 will include a review of the impacts associated with the construction and operation of the proposed Lee Nuclear Station, including an evaluation of carbon-based greenhouse gas emissions. The discussion of alternative energy sources in 54

Chapter 9 of the EIS will describe the potential environmental impacts from alternative energy sources, including estimated emissions of greenhouse gases, and provide an analysis of energy efficiency and renewable energy sources.

Comment: Well, why would we look to the nuclear industry to create more jobs? It's probably the most job-poor industry in the United States. That's when you start looking at your alternative energies, which are going to hire millions of people. This is a labor-intensive industry.

Renewable energy is labor-intensive; nuclear isn't. (0001-25-6 [Richardson, Don])

Comment: [production-based incentives for distributed customer-supplied solar energy]

creates more jobs than you'll ever see from Duke Energy; they can't fill all the jobs in Ontario, and I've been to Gainesville, and I know what they're able to do there. And the economy is just booming there, too. (0001-6-1 [Arnason, Deb])

Response: The NRC does not establish public policy regarding electric power supply alternatives, nor does it promote the use of nuclear power as a preferred energy alternative.

Decisions regarding which generation sources and alternatives to generation sources to deploy are made by Duke through least-cost planning and IRPs. The socioeconomic impacts of construction and operation of the proposed Lee Nuclear Station, including both job creation and job retention, will be addressed in Chapters 4 and 5 of the EIS. Job creation and retention for alternative energy technologies will not be addressed in the EIS.

19. Comments Concerning Alternatives - System Design Comment: A nuclear plant must have lower thermodynamic efficiency than even a coal-fired or any other fossil-fuel type plant. There's been a lot of concern about coal-fired power plants at Cliffside and elsewhere. That is, if a coal plant and nuke plant produce the same output, electrical, the nuke plant will create about 30 percent more waste heat discharged into the river.

This is because it is impossible to create superheated steam inside a nuclear reactor core using boiling or pressurized water for both moderator and heat transfer. Hot steam from burning coal or oil that turns a turbine in a fossil plant may be heated to nearly 2000 degrees before it gets to the turbine. This is called superheated or dry steam.

The best a nuke can do is much less than a thousand degrees and creates what is called saturated wet steam. So the best possible efficiency for a nuclear plant is about 30 percent lower than in a fossil-fuel plant. What does that mean for the present situation?

Well, in March the New York State Department of Conservation released a draft policy calling for power plants and other facilities that use water for cooling to recycle and reuse water 55

through closed-cycle cooling technology. That rule would affect six nuclear reactors in New York State, which may require some $2 billion investments in order to continue operating.

(0001-9-3 [Zeller, Lou])

Response: The Energy Information Administration (EIA) lists the average operating heat rates for the following technologies: coal, natural gas, petroleum, and nuclear. Information available from the EIA website indicates that the coal and nuclear technologies have very similar energy efficiencies as measured by heat rate (i.e., coal [10,378 btu/kwh] and nuclear [10,455 btu/kwh]).

However, because fossil-fired plants are capable of running higher turbine inlet pressures, their thermal efficiencies are higher than a nuclear power plant. For example, where a nuclear power plant may operate at 32 percent thermal efficiency, supercritical coal-fired power plants can operate at 40 to 43 percent thermal efficiency, while natural-gas-fired combined-cycle power plants may operate at 57 to 59 percent thermal efficiency. Steam-turbine metallurgy in any cycle configuration is currently limited to approximately 600°C (1112°F) at the turbine inlet.

Information regarding alternative system configurations, including alternative cooling configurations, will be addressed in Section 9.4 of the EIS. The EIA webpage can be accessed at http://www.eia.doe.gov/cneaf/electricity/epa/epat5p3.html.

20. Comments Concerning Benefit-Cost Balance Comment: The Lee Nuclear Station will benefit our state by creating construction jobs, stimulating the local economy through service jobs, provide low-cost, safe, reliable carbon-free electricity to our citizens. (0001-1-3 [Moss, Dennis Carroll])

Comment: The facility in Cherokee County will bring billions of dollars in investment to our state, create thousands of good-paying jobs for our citizens, produce reliable energy for our businesses, and, importantly, produce it cleanly and safely in a carbon-free manner (0001-10-5 [Scott, Darrell])

Response: These comments express general support for the proposed Lee Nuclear Station and imply that nuclear power plant emissions contain less carbon than other generation alternatives. Emissions from plant construction and operation will be evaluated in Chapters 4 and 5 of the EIS. Emissions from the uranium fuel cycle will be evaluated in Chapter 6.

Emissions from power generation alternatives will be evaluated in Chapter 9 of the EIS.

Socioeconomic impacts on the local economy through jobs will be discussed in Chapters 4 and 5 of the EIS. Benefits of the proposed project will be discussed in Chapter 10 of the EIS.

Comment: This site was under construction 30 years ago and subsequently canceled. It was canceled for economic reasons. Duke is currently in a situation where they don't have funding for this site; otherwise they wouldn't be having secret meetings with North Carolina legislators about changing North Carolina law in order to reach into the pockets of their customers in western North Carolina to pay for this thing. So what is the guarantee that you're not looking at 56

a NEPA process where you're going to look at an action alternative that has absolutely no benefit -- high impact and no benefit. That's what it had 30 years ago; that's what it could have now. (0001-15-4 [Olsen, Mary])

Comment: Providing this plant is not a good way to use money. This is a sink of the ratepayers' money, and it will only invest in a form of energy which is finite and which comes with risks.

(0001-22-2 [Fair, Gabriel])

Comment:

  • Why is NRC proceeding with this review when it is CLEAR that Duke is lacking funding for this project? It is reported that Duke is having secret meetings with "leaders" in the NC State legislature -because it must CHANGE NC LAW in order to get the money for this project.
  • Duke requires DELEGATED TAXATION for the construction of this site - effectively collecting money from its customers that is not fee for service ... and will NOT be refunded if the site in Cherokee County is canceled for a second time (0014-7 [Olsen, Mary])

Comment: Duke Energy wants permission to transfer the cost of building the nuclear power plants to electricity customers BEFORE the plants ever go online. This will increase electricity costs for years to come. And it is not inconceivable that the plant never will go online, as happened in Gaffney with the Cherokee plant in the 1980's. (0038-4 [Thomas, Ellen])

Response: The NRC's responsibility is to regulate the nuclear industry to protect public health and safety within existing policy. The NRC is not involved in establishing the rates paid by customers. Comments regarding funding and electricity rates will not be addressed in the EIS, however, the Benefit-Cost Balance section of Chapter 10 will discuss the costs of preconstruction, construction, and operation of two nuclear units at the Lee site.

Comment: And they have to use all this federal money, loan guarantees, and this is the thing about these loan guarantees. Yeah, it's a loan. But if they do what they did last time and leave 64 plants unbuilt, when they default this time, you and I are stuck with the bill. If they default, the taxpayer gets stuck, not the investor. (0001-30-9 [Corbett, Susan])

Comment: Building new nuclear power plants cost 6-8 billion dollars/reactor. With guaranteed government bail-outs; Which means my tax dollars! (0003-1 [Hale, Kendall])

Comment: Nuclear power is capital intensive and funding is elusive because financial investors find nuclear power a very risky venture, as does the insurance industry who will not indemnify them, therefore, the only alternative is government subsidies. (0021-2 [Barnett, Barbara A.])

Comment: The cost of nuclear power is high relative to other sustainable technologies when the safety, environmental and legal liability costs are factored in, (as demonstrated by the failure 57

of private investors to fund such plants without government subsidies and liability caps.

(0029-7 [Thomas, Bill])

Response: The NRC is not involved in establishing national energy policy, and issues related to the subsidization of nuclear power are outside the scope of the NRC's mission and authority.

A description of the benefits and costs of the proposed project will be provided in Chapter 10 of the EIS.

Comment: You construct Pond C and it never generates any electric power because people rise up in North Carolina and realize that energy efficiency and non-fuel-based energy technologies are the way to go and refuse to pay. (0001-15-5 [Olsen, Mary])

Comment: So, do we spend billions on this nuclear plant or do we spend billions on saving this planet. (0016-7 [LeVander, Valerie])

Response: Alternatives to the proposed Lee Nuclear Station will be discussed in Chapter 9 of the EIS. Costs will be discussed in Chapter 10 of the EIS.

Comment: So these are things in scoping that must be considered and weighed along with the construction of that pond. Is any power going to be generated here that might be construed as a benefit versus the very large impacts to this area by creating that pond?

(0001-15-10 [Olsen, Mary])

Comment: Building another plant may decrease the cost of energy to consumers years down the road, but at what cost? -- the severe alteration of the Broad River via water intake and thermal pollution, creating dead zones of aquatic life; the creation of tons of nuclear waste that only will be stored in South Carolina? (0001-24-2 [Swinton, D.C.])

Comment: A report released -- the proposed site area cannot sustain these proposed nuclear reactors without enormous strain placed on our rivers, environment, and ratepayers, not to mention the taxpayers' money. Besides the environmental irresponsibility of Duke Energy in proposing nuclear reactors in a drought-prone area, there's fiscal irresponsibility, especially in this recession. (0001-23-4 [Hildebrandt, Lorena])

Comment: Who is doing the modeling for this project? Are those who are responsible for modeling the feasibility of this project going to also profit if this project is approved?

(0009-6 [Bliss, Rachel])

Comment: On what basis does the Federal Regulator stand here with a straight face talking about "benefit" to justify "cost" to the Broad River and other aspects of the Piedmont environment? (0014-6 [Olsen, Mary])

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Comment: ...we urge you to consider the many disadvantages of nuclear energy in your environmental impact assessment. Nuclear power is expensive... (0017-2 [Hicks, Katie])

Response: The costs and benefits of the proposed Lee Nuclear Station will be discussed in Chapter 10 of the EIS.

Comment: A report released in 2009 revealed the soaring costs of nuclear energy. The economics of nuclear reactors' renaissance or relapse reported that during the previous year, the cost estimates from new generation reactors can range to a high of 30 cents from a low of 8.4 cents per kilowatt-hour. In contrast, energy efficiency costs about 3 cents per kilowatt-hour.

(0001-23-5 [Hildebrandt, Lorena])

Comment: It's not affordable. They're talking about 20 cents, and they're lying about it. My utility said it's going to cost us 7 cents a kilowatt hour; it's looking more like 20 cents, 25 cents, even, when they get it all built. (0001-30-8 [Corbett, Susan])

Comment: Stop the proposal of William States Lee Nuclear Power Plant in Gaffney, SC.,

because:

1. Nuclear Power is Expensive, $6 to $8 billion per reactor; with promised bailouts from our government. (0013-1 [Thomas, Ellen])

Comment: Another compelling reason for my opposition to any more construction of nuclear power plants is well illustrated by comparing them to other available, functional and healthier means of electrical power generation. Comparison in terms of EROEI, that is Energy Return For Energy Invested, reveals that nuclear is 15th out of 20 candidates (1). EROEI , also known as Net Energy, has been defined as the energy delivered by an energy-obtaining activity compared to the energy required to get it (2). That is, there are 14 sources more desirable than nuclear in terms of overall efficiency. This overall efficiency assessment includes a whole system consideration from the extraction at the source, processing, construction and operation of the delivery plant, and cost of any subsequent waste handling and/or disposal. This I believe is looking at the "whole picture" in the way it really is, in an honest way.

(0012-4 [Howarth, Robert F.])

Comment: A new series of recent studies have found that the capital costs of new conventional atomic reactors have gotten so high that even before you factor in fuel and operations, you're talking seventeen to twenty-two cents per kilowatt hour-which is two or three times what Americans currently pay for electricity. (Joe Romm, Exclusive Analysis, Part 1: The Staggering Cost of New Nuclear Power, ClimateProgress.org, January 5, 2009) (0016-3 [LeVander, Valerie])

Comment: The proposed Gaffney nuclear plant as well as other proposed nuclear plants will rob us of much needed capital to fund our shift to clean renewable energy. We have no more time to waste. (0016-5 [LeVander, Valerie])

59

Response: The NRC does not have authority under the law to ensure that the proposed plant is the least costly alternative to provide energy services under any particular set of assumptions concerning future circumstances. The potential for alternative non-nuclear technologies will be discussed in Chapter 9 of the EIS. The disclosure of the costs of the proposed action will rely on the best available estimate of financial costs with uncertainties noted. Associated costs that cannot be reliably quantified will also be discussed. The estimated overall internal and external benefits, costs, and associated environmental impacts of the proposed project will be addressed in Chapter 10.

Comment: As an alumna of the UNC-Chapel Hill Gillings School of Public Health, my familiarity with the extraordinary cost burden to taxpayers of the development of nuclear production facilities ... mitigate against the development of nuclear production and delivery services.

(0023-2 [Drake, Joan W.])

Response: The NRC does not have authority under the law to ensure the proposed Lee Nuclear Station is the least costly alternative to provide energy services under any particular set of assumptions concerning future circumstances. This authority and responsibility is most often the role of State regulatory authorities. The potential for alternative non-nuclear technologies will be addressed in Chapter 9 of the EIS. The disclosure of costs of the proposed Lee Nuclear Station will rely on the best available estimate of financial costs with uncertainties noted.

Associated costs that cannot be reliably quantified also will be discussed. The estimated overall internal and external benefits, costs, and associated environmental impacts of the proposed project will be addressed in Chapter 10 of the EIS.

Comment: Nuclear power died of market forces many decades ago but the industry, ever the opportunist for public subsidies, these many years later still keeps insisting that we try again, ignoring the final diagnosis. In my view, the entire industry needs professional help.

(0015-1, 0001-25-5 [Richardson, Don])

Comment: Bottom line: building enough conventional nuclear reactors to eliminate a tenth of the threat of global warming would cost about $8 trillion, not to mention running electricity prices through the roof. You'd need to open a new reactor every two weeks for the next forty years and, as the analyst Joe Romm points out, you'd have to open ten new Yucca Mountains to store the dangerous waste. Meanwhile uranium prices have gone up by a factor of six this decade, because we're running out of the easy-to-find stuff and miners are having to dig deeper.

(Bill McKibben, Eaarth,2010) (0016-4 [LeVander, Valerie])

Comment: The history of the production of nuclear energy energy [sic] is replete with record levels of inordinate public expense (0023-5 [Drake, Joan W.])

Comment: I believe investing millions of dollars required to bring on line a nuclear power plant is not a good investment. History demonstrates that cost always exceeds initial estimates, 60

financing is dependent on government subsidy in the form of liability insurance, and the 5 to 10 year or more construction time is too long. (0012-1 [Howarth, Robert F.])

Response: Issues related to costs associated with previous projects are outside the scope of the proposed action and will not be addressed in the EIS. The NRC is not involved in establishing national energy policy, and issues related to the subsidization of nuclear power are outside the scope of the NRC's mission and authority. The estimated overall costs and environmental impacts of the proposed project will be addressed in Chapter 10 of the EIS. The benefit-cost balance for the project will rely on the best available estimate of project timing and duration, while noting possible uncertainties that may affect those estimates.

Comment: And I know that the nuclear reactor is more than just one blowout protector away from a meltdown, but it's still a complex system with multiple possibilities of failure, and there is a liability cap on it as well. There's an $11 billion liability cap, I believe, and I saw a recent study that showed that a major accident in a fuel pool could be $500 billion, and you and I, again would pay for that, because there's a liability cap. (0001-30-11 [Corbett, Susan])

Response: The effects of accidents will be considered in both the environmental and safety reviews. Postulated accidents, including design-based and severe accidents, will be addressed in Chapter 5 of the EIS. The estimated overall costs and environmental impacts of the proposed project will be addressed in Chapter 10.

Comment: We feel that the Lee nuclear site will give Duke a better portfolio to give us inexpensive power that we require to keep people employed in Cherokee County and flexibility to enable that. (0001-7-2 [Ware, Steve])

Response: This comment expresses support for the proposed action. The costs and benefits of the proposed Lee Nuclear Station will be discussed in Chapter 10 of the EIS.

Comment: Included among our reasons [for opposing this nuclear plant] is this major factor-cost. While others here will speak to important environmental factors such as water, transport, safety, toxicity and storage, we wish to address cost. Why? Because moving to renewable clean energy is going to cost a lot of money. We are going to have to make choices in how we spend our public purse. As many economists, scientists and industry leaders have noted, there will not be enough money to both build expensive nuclear plants and fund research and implementation of non polluting energy sources. (0016-2 [LeVander, Valerie])

Response: Renewable energy resources will be considered in Chapter 9 of the EIS. The NRC does not have authority under its regulations to ensure the proposed Lee Nuclear Station is the least costly alternative to provide energy services under any particular set of assumptions concerning future circumstances. This authority and responsibility is most often the role of State regulatory authorities. Chapter 9 of the EIS will address the potential for alternative non-nuclear 61

technologies to provide the electricity that could be generated by the proposed power plants and their environmental impacts. The benefits and costs of the proposed project will be discussed in Chapter 10 of the EIS.

Comment: All costs are not included in the industry estimate of $11 billion, e.g., mining of uranium, transportation of uranium, enrichment plants, subsidy for construction, the temporary disposal of waste, the permanent disposal site, monitoring the Lee reactor, indemnifying the plant, dismantling and burial of the reactor. (0021-3 [Barnett, Barbara A.])

Response: The NRC staff will evaluate the environmental impacts of the uranium fuel cycle including the impacts of fuel manufacturing, transportation, and the onsite storage and eventual disposal of spent fuel. The estimated overall costs and environmental impacts of the proposed Lee Nuclear Station project will be addressed in the EIS. The benefit-cost evaluation for the project, which will be included in Chapter 10, will rely on the best available estimates of project timing and duration, while noting possible uncertainties that may affect those estimates.

21. General Comments in Support of the Licensing Action Comment: Duke's plan to withdraw from on-site drought contingency ponds is aligned with state environmental permitting by DHEC. (0001-1-4 [Moss, Dennis Carroll])

Comment: I fully support Duke's request to construct additional drought condition ponds that is required for the licensing process of Lee Nuclear (0001-1-5 [Moss, Dennis Carroll])

Comment: I'm here tonight to support the Lee Nuclear Station project and to ask the NRC to approve the construction and operating license for Duke Energy to move forward (0001-10-1 [Scott, Darrell])

Comment: The building of this make-up pond will not only --will do nothing more than strengthen the reliability and efficiency of the plant operation better known as Lee nuclear plant; therefore, the improvements to the environment will also benefit everyone.

(0001-13-4 [Boger, Paul])

Comment: The South Carolina Manufacturers Alliance has consistently supported the construction of the proposed nuclear reactors at the Lee Nuclear Station here in Cherokee County. (0001-14-1 [Hopper, Sara])

Comment: We believe strongly that the proposed construction of Make-Up Pond C will preserve the quality and quantity of the water in the Broad River. (0001-14-4 [Hopper, Sara])

Comment: Building Pond C is responsible water management. It is a commitment to respect the needs of other users. It is part of a comprehensive plan that will create stability within the 62

Broad River basin while at the same time facilitating the production of essential energy resources, resources without which South Carolina will not be able to grow.

(0001-14-6 [Hopper, Sara])

Comment: I think you probably know from the organization I represent that we support this project for the economic features that it will bring to our county. (0001-18-1 [Robbs, Kayla])

Comment: Duke Energy has an excellent track record that spans decades of providing reliable, safe electricity. We're confident that they will be able to operate this facility in a safe manner and will be cognizant of our Broad River, which we all greatly love and appreciate. So I fully support Duke's request to construct this additional -- this drought-contingency pond.

(0001-2-1 [Moss, Steve])

Comment: But I am confident in Duke Energy and what they're going to do for our county, and I'm comfortable of looking across the river about a mile down that I'll be able to see the reactors.

But it's going to be good for our county, and I plan on my grandchildren and their grandchildren continuing to kayak and swim in the Broad River for many years to come, and I strongly support this project. (0001-2-2 [Moss, Steve])

Comment: So we're here to discuss Make-Up Pond Charlie for the proposed Lee Nuclear Station. This make-up pond will be one of the many assurances that this nuclear power plant can operate safely and reliably. (0001-21-1 [Pace, Eric])

Comment: With a state unemployment rate among the highest in the nation, we're excited about the role this plant will serve in helping attract not only support industries but other manufacturers to our area as well. (0001-26-1 [Cook, Jim])

Comment: The Cherokee County Development Board fully supports the additional pond and the overall nuclear project. (0001-26-3 [Cook, Jim])

Comment: Duke has come to the table -- they've offered to do this additional lake, and I think that's commendable on their part, and I would encourage you to support this.

(0001-3-1 [Forrester, Mike])

Comment: I just want to say that I support this project (0001-3-2 [Forrester, Mike])

Comment: I think the addition of this pond is the smart thing to do (0001-4-2 [Hogue, David])

Comment: And myself and my cohort, who will be up next, we're just here in support of the proposed Lee nuclear site (0001-7-1 [Ware, Steve])

63

Comment: We also feel that the proposed supplemental cooling pond is a very intelligent move in Duke to try to mitigate any kind of drought conditions that may affect our water flow also.

(0001-7-3 [Ware, Steve])

Comment: So just in conclusion, Nestle, as the Gaffney organization, does support the Lee nuclear site (0001-7-4 [Ware, Steve])

Comment: Nestle, we do support the Lee nuclear facility, and Pond C appears to be a very intelligent decision (0001-8-1 [Brooks, Tim])

Comment: I favor the construction of the two plants discussed at the meeting in Gaffney, SC, June 17, 2010. (0018-1 [McCall, Pat])

Comment: WE SUPPORT THE NUCLEAR PLANTS NEAR GAFFNEY, SC.

(0022-1 [Ledford, Judy and Glenn])

Comment: I would like to show my support for the 2 Nuclear Plants proposed in Gaffney, SC.

(0025-1 [Thrift, Debbie])

Comment: I would like to also express my support for the proposed Nuclear Plants in Gaffney.

(0026-1 [Cross, John])

Comment: I would like to express my support of the 2 proposed reactors in the Gaffney, S.C.

area (0027-1 [Mixon, Michael C.])

Comment: CCW supports the development of the new Lee Nuclear Station and believes that clean, inexpensive, reliable power is a necessity to recover from the economic downturn and provide an improved standard of living for our customers and others in North Carolina and South Carolina. The Lee Nuclear Plant can provide this for our region. We also recognize that the proposed nuclear power plant is a regional solution to providing power to not only Duke Energy customers in South Carolina but also customers in North Carolina.

(0035-1 [Smith, Clyde E. (Butch)])

Response: These comments express support of Dukes COL application. They do not provide any new information relevant to the environmental review and will not be addressed in the EIS.

22. General Comments in Support of the Licensing Process Comment: And so that's something I'd like us to -- you know, when Mary Olsen mentioned the National Oceanic and Atmospheric Administration and such organizations that also are not --

you know, I would really support that, you know, that kind of an organization gets involved and other environmental groups get involved personally with the NRC and Army Corps and things 64

like that to ensure that the people who really do care and love the environment make sure that it is taken care of. (0001-19-1 [Richards, Kitty-Katherine])

Comment: Thanks for this opportunity to participate in this meeting. (0009-8 [Bliss, Rachel])

Response: These comments express support for public participation in the NRC COL process.

They do not provide any new information relevant to the environmental review and will not be addressed in the EIS.

Comment: The NRC writes laws that, if followed by nuclear operating companies, will ensure a minimum standard is being followed which protects the health and safety of the public, which is their mission statement. (0001-21-2 [Pace, Eric])

Response: This comment expresses general support for the NRC combined license application review process. It does not provide any new information relevant to the environmental review and will not be addressed in the EIS.

23. General Comments in Support of Nuclear Power Comment: There's no single one answer to solving our energy needs, but the creation of nuclear power as a sustainable energy source is a great start and could end up being one of South Carolina's greatest assets in the future. Nuclear power is the most viable and affordable bridge to energy independence for South Carolina. (0001-10-2 [Scott, Darrell])

Comment: ...businesses and residents alike are extremely supportive of expanded nuclear capacity in South Carolina. There are no other alternatives currently available that are as reliable as nuclear in providing baseload power in a carbon-free manner.

(0001-10-3 [Scott, Darrell])

Comment: We also understand that generating power can have significant impacts on our environment. It is the policy of the South Carolina Manufacturers Alliance to advocate a balance between economic development and preservation of our natural heritage. We believe nuclear power is consistent with that policy, as it is one of the only proven baseload technologies that does not emit greenhouse gases. (0001-14-3 [Hopper, Sara])

Comment: As power companies around the country take actions to ensure their generation capacity keeps pace with their service area demands, more and more of them will be turning to nuclear power as large generation and environmentally sound answers to add to their baseload generation.

65

Not only will the companies that build them benefit from the power that will be produced by the station, but the communities that are hosts to these stations will benefit as well, as many of the speakers tonight have already outlined. (0001-21-3 [Pace, Eric])

Comment: For more than 35 years nuclear energy has been a part of Duke Energy Carolinas' generation portfolio. As we plan for the future, we see the need to continue using nuclear energy to product electricity safely, reliably, and efficiently. (0001-5-1 [Dolan, Bryan])

Comment: I think we're all interested in nuclear power, basically because of the reduction of the carbon footprint. So as we said before, we're very much in favor of the project.

(0001-8-2 [Brooks, Tim])

Comment: I support the development of new nuclear energy generation plants of intelligent and environmental sensitive design. (0019-1 [Mominee, Katharine N.])

Comment: I not only feel that Nuclear is a clear and reasonable alternative to fossil fuels (0026-3 [Cross, John])

Comment: Nuclear Power is our best and most affordable solution at this time.

(0026-4 [Cross, John])

Response: These comments provide general information in support of nuclear power. They do not provide any new information relevant to the environmental review and will not be addressed in the EIS.

24. General Comments in Support of the Applicant Comment: Duke Energy has a excellent track record of providing reliable, safe, affordable nuclear power to South Carolina. This track record makes me confident that the Lee Nuclear Station will be operated safely and efficiently. (0001-1-2 [Moss, Dennis Carroll])

Comment: Duke has a strong history of citizenship and service in every community that it has located a power plant or other operating facility. This doesn't necessarily mean just the money that Duke will provide through taxes but also the services that it will provide through not only its own organizational needs but also through the employees that will work there.

These employees will be involved in United Way; they'll serve on boards; they'll serve on committees for other civic organizations. They'll be the people who will live next door to you who will raise their children in the same schools that you raise your children.

They'll be interested in the environmental impact of everything. They'll also monitor the plant.

They'll keep track of these things, and they'll ensure that the plant is operated efficiently, but 66

more importantly, these people will step up like you do; they'll become buddies in the school system; they'll help students learn to read.

They'll be volunteering for Boy Scouts, and they'll also be volunteering for Girl Scouts. They'll serve on the committees of the PTA, the PTO, and the school improvement councils.

The reason I know this is I've served with many of those people in those same functions.

They're interested in the community. They're not interested in destroying the community or making it a place that no one wants to come to.

They're very interested in making the community something that we can all live in, we can all be proud of. (0001-13-3 [Boger, Paul])

Comment: Duke Energy is one of the companies to follow -- one of the first companies to follow that requirement, and they should be commended for their leadership they are showing and the example they are creating for others to follow. (0001-14-5 [Hopper, Sara])

Comment: I'd also like to speak to -- about Duke Energy. We believe them to be good corporate citizens. They're involved in our communities. They live with us; they work with us, and we believe that they have nothing but good intentions for our county.

(0001-18-2 [Robbs, Kayla])

Comment: I would just like to make the point that I feel that this an excellent example of the diligent work that Duke Energy has done. (0001-26-2 [Cook, Jim])

Comment: Duke Power, Duke Energy has been good to Cherokee County over the years, and especially Blacksburg. (0001-4-1 [Hogue, David])

Response: These comments express support for Duke. They do not provide any new information relevant to the environmental review and will not be addressed in the EIS.

25. General Comments in Opposition to the Licensing Action Comment: It is no secret that we are here to oppose this project.... (0001-15-1 [Olsen, Mary])

Comment: But I personally cannot approve of this project as a citizen of this -- of the Carolinas, using the same worn-out standards that we've used in the past. (0001-20-6 [Bliss, Rachel])

Comment: Do not lie to yourselves. The mayor of Blacksburg, South Carolina Chamber of Commerce, South Carolina Manufacturers Alliance, Representatives Moss, Forrester, and the other Representative Moss, NRC, Duke, all that have been in favor of this plant, you need to stop lying to yourselves and admit that resources for a cleaner, greener future are available and 67

are viable, so much so we would be able to decrease the need for any new nuclear plants or coal fired power plants in this state; also to the point where we could decrease the amount that we currently have on line. (0001-24-5 [Swinton, D.C.])

Comment: ...we have serious concerns about Duke's push to build two new reactors here in Cherokee County. The uncertainties continue to escalate, putting ratepayers, taxpayers, and the environment at increasing risk. (0011-1 [Hancock, Mandy])

Comment: ...The Global Warming Task Force opposes this nuclear plant...

(0016-1 [LeVander, Valerie])

Comment: I do not support Duke's proposition to supply my region with new nuclear power.

(0017-6 [Hicks, Katie])

Comment: I write to expres opposition to the Proposed Nuclear Plant at Gaffney, SC.

(0023-1 [Drake, Joan W.])

Comment: The Pisgah Group of the Sierra Club wishes to go on record as opposed to construction of the Gaffney/Cherokee Falls nuclear plant, essentially the No Action alternative of any Environmental Impact Statement on the proposed cooling ponds. (0029-8 [Thomas, Bill])

Response: These comments express opposition to the construction and operation of the proposed Lee Nuclear Station. They do not provide any new information relevant to the environmental review and will not be addressed in the EIS.

26. General Comments in Opposition to Nuclear Power Comment: The faster this nation gets off of dirty energy and nuclear energy and the faster that we get to renewable and sustainable means of energy, the better off we'll be. I consider that salvation. Again, my name's Gabriel Fair. It's a pleasure speaking here today.

(0001-22-5 [Fair, Gabriel])

Comment: Nuclear power died many decades ago of market forces, but the nuclear industry, every the opportunist for public subsidies, these many years later still keeps insisting that we try again, ignoring the final diagnosis. (0001-25-1 [Richardson, Don])

Comment: The position of short-term, bottom-line, profit-thinking proponents of nuclear relies on huge taxpayer-supported government subsidies for liability insurance, relies on a narrowly defined partial-system efficiency assessment, and relies on refusing to look at the whole picture and the way it really is in an honest way. (0001-27-4 [Howarth, Robert F.])

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Comment: And I only have one thing to say, but I think that it speaks volumes. And that is that there's no insurance company on this planet that will insure a nuclear power plant.

(0001-28-1 [Williams, Debralee])

Comment: ....I like the idea of homegrown energy independence. It's one of the reasons that I'm opposed to nuclear power.... (0001-30-1 [Corbett, Susan])

Comment: So let's have some homegrown renewable energy. Let's have some energy efficiency. Nuclear power is just one ridiculous way to boil water. (0001-30-12 [Corbett, Susan])

Comment: As I said, we are opposed to nuclear power. (0001-9-8 [Zeller, Lou])

Comment: Nuclear power is "dirty." From the mining of uranium to thermal pollution to the waste, it is not clean, not renewable and it is dangerous. (0008-1 [Craig, Anne])

Comment: If NRC's mission was to determine whether any new nuclear reactors were needed and cooperated with other agencies to provide the best sources of energy, it would be obvious nuclear is NOT a good source because of the FACTS about nuclear I call them the 4W's and they apply to the current breed of reactors you are seeking to regulate - Water, Waste, Weapons and Wall Street wouldn't touch such a risky investment! (0010-6 [Arnason, Deb])

Comment: There is little doubt that we can do better for the health and well being of we taxpayers as well as for the environment than to build Nuclear. (0012-3 [Howarth, Robert F.])

Comment: I live 40 miles from Gaffney, having returned home to the mountains after a lifetime of working against nuclear weapons. Now I find this horrible idea happening in essentially my own back yard. (0013-11 [Thomas, Ellen])

Comment: Nuclear energy in all its forms, with the possible exception of isotopes for medical diagnosis and treatment, is the worst idea ever devised by human intelligence, an idea whose time really never came. (0015-6 [Richardson, Don])

Comment: Our 103 operating nukes are OLD, many with their operating lives dangerously extended. They will ALL have to be decommissioned over a short period of time, meaning there is no way even an Apollo program to build new ones could possibly keep up, so the industry will shrink dramatically even with the proposed new construction. (0015-7 [Richardson, Don])

Comment: Human management is NOT ready YET to take on the role of protecting the few remaining unscathed areas of the country where people can live healthy lives without the presence of a major catastrophe occurring in their waterways and/or disrupting their air quality.

Please learn from the past and better understand WHY? catastrophes so often happen. Let your intellect and undeniable conscience tell you to do the right thing in deciding whether to help with 69

our Nation's (our people's) energy consumption problem by allowing more Nuclear plants to be built.

Maybe, the way we have ,and are NOW being taught to live and what consumables we have been conditioned to need for the sake of our self fulfillment and notoriety IS the problem that needs to really be addressed.

PLEASE STOP the proliferation of granting unsafe solutions and having them then pushed-thru the United States congress by way of your committee's recommendations and all for the sake of the financial elite and their mighty bucks which they use to help persuade others. Others who, perhaps sometimes skew the conscience of the members of your commission in making less than articulate and conscionable decisions. (0028-1 [Hansborough, Hilbert J.])

Comment: It seems that we in the South have been targeted for more than our fair share of new and proposed nuclear reactors. This is not a legacy I want to leave for my grandchildren.

(0034-5 [Hallock, Judith])

Response: These comments express general opposition to nuclear power. They do not provide any new information relevant to the environmental review and will not be addressed in the EIS.

27. Comments Concerning Issues Outside Scope -

Emergency Preparedness Comment: What about actually putting this plant -a second nuclear plant on the other side of the largest population center in South Carolina, the upstate? Now we're cornering tons and tons of people with a possibility of some sort of emergency occurring. This is not the way to go.

(0001-24-3 [Swinton, D.C.])

Comment: I live 1 1/2 miles from the Lee site. Should you encounter a problem, what are your plans for evacuation? (0033-1 [Pennington, Lee])

Response: Emergency preparedness capabilities of the proposed facility, evacuation procedures, and evacuation routes are emergency planning issues that are outside the scope of the environmental review. As part of its site safety review, the NRC staff will determine, after consultation with U.S. Department of Homeland Security and Federal Emergency Management Agency, whether emergency plans submitted by Duke are acceptable. These comments will not be addressed in the EIS.

70

28. Comments Concerning Issues Outside Scope -

Miscellaneous Comment: We are daily watching the disaster in the Gulf of Mexico and acutely aware of what happens when public policy is co-opted by narrow, self-serving corporate interests. Not acting in the public interest-for the people who elected them-is one definition of treason, for which the time-honored punishment is, well, unpleasant. I remain amazed that Congress, for cash bribes, sells its votes and runs the risk. (0015-4 [Richardson, Don])

Response: This comment expresses a distrust of the Federal government and its agencies to regulate corporations. The issue raised in this comment is outside the scope of the environmental review process and will not be addressed in the EIS.

29. Comments Concerning Issues Outside Scope - NRC Oversight Comment: Is the Nuclear Regulatory Service similar to the US Minerals Management Service that has been overseeing the oil industry? If so, it should be a wake-up call to NRC to closely examine its ties to the nuclear industry. Enron said "Water Is The New Oil." We don't want to experience a BP-Deepwater-Horizon catastrophe where we all discover that nuclear regulation has been very lax. Are there violations already being ignored or regulations being skimped under assurances from monopoly corporations? (0010-3 [Arnason, Deb])

Comment: The Federal Regulator must give FULL DISCLOSURE: NRC is considering revisions for the licensing of on-site storage of high-level nuclear waste for up to several CENTURIES... it is already up to 120 years. (0014-4 [Olsen, Mary])

Response: The NRC takes seriously its responsibility under the Atomic Energy Act to protect public health and safety and the environment in regulating the U.S. nuclear power industry.

More information on NRC's roles and responsibilities is available on the NRC's website at http://www.nrc.gov/what-we-do.html. While the Atomic Energy Act of 1954 previously defined a role for the Atomic Energy Commission (AEC) in formulating a national energy policy, the Act, as amended in 1974 by the Energy Reorganization Act, created the NRC from the AEC's regulatory division to regulate the nuclear power industry. The Energy Reorganization Act segregated AEC's national policy role in the Energy Research and Development Administration, which later became the U.S. Department of Energy. NRC has no role in promoting nuclear power. Rather, the Congress and the President establish the energy policy of the United States, and the U.S. Department of Energy implements that policy at the direction of the President. NRC was created by Congress and designed so that it would not report to the same part of the government that was in charge of setting energy policy (i.e., any current administration). The public has been given the opportunity to participate in the rulemaking 71

process that established the regulations that govern its review process. The comments did not provide new information relevant to this EIS and will not be evaluated further.

30. Comments Concerning Issues Outside Scope - Safety Comment: What is the impact if the dam is breached or fails? Does that mean the reactors would have to be shut down until such time as the reactors [sic] are repaired? And it does appear that the operation of the reactor is down to just this single lake.

(0001-31-13 [Clements, Tom])

Response: The NRC considers the effects of the environment on a nuclear power plant in its Safety Evaluation Report, which analyzes all aspects of reactor and operational safety. The effects of a nuclear power plant on the environment are analyzed in its EIS. The length of time a power plant can operate under drought or low-flow conditions is a safety issue, and as such, is outside the scope of the environmental review and will not be addressed in the EIS.

Comment: ....the proposed reactors for the W.S. Lee site is the AP-1000 Westinghouse reactor, which we have labeled inherently dangerous in a report that we released last month and is posted to our website at bredl.org. If constructed, these reactors would be accidents waiting to happen. (0001-9-4 [Zeller, Lou])

Comment: The two problems with the AP-1000 are that [1.] modular construction of the reactor shield building and 800,000-gallon tank of water suspended above the reactor core, subjecting it to severe stress and instability in the event of an earthquake, a tornado, or a hurricane.

(0001-9-5 [Zeller, Lou])

Comment: [The two problems with the AP-1000 are ...] Number two, a ventilation system in the AP-1000 would allow the free flow of air from inside the reactor containment building to outside air, allowing radiation to escape in the event of a reactor core breach. (0001-9-6 [Zeller, Lou])

Comment: According to the nuclear engineers that we are in touch with, they used -- the unique AP-1000 design allows it to develop a condition that could lead to a reduction in wall thickness that would result in rapid release of radiation. These are not accounted for in the severe accident mitigation design alternatives. (0001-9-7 [Zeller, Lou])

Comment: I wonder how strong these new reactors will be, especially with the water tank perched ABOVE, vulnerable to the winds. (0038-9 [Thomas, Ellen])

Response: The NRC considers the effects of the environment on a nuclear power plant facility in its Safety Evaluation Report, which analyzes all aspects of reactor and operational safety.

The effects of the nuclear power plant on the environment are analyzed in its EIS. Reactor 72

design is a safety issue, and as such, is outside the scope of the environmental review and will not be addressed in the EIS.

31. Comments Concerning Issues Outside Scope - Security and Terrorism Comment: Plutonium is one of the most toxic substances known to man, and can used to make bombs. This encourages terrorist attacks and weakens our national security.

(0003-3 [Hale, Kendall])

Comment: Terrorist attacks or accidents or leakage from storms could cost thousands of lives and billions of dollars (0013-2 [Thomas, Ellen])

Comment: [Nuclear power] ... can contribute to the proliferation of nuclear weapons...

(0017-4 [Hicks, Katie])

Response: Comments related to security and terrorism are safety issues that are not within the scope of the NRC staff's environmental review. The NRC is devoting substantial time and attention to terrorism-related matters, including coordination with the U.S. Department of Homeland Security. As part of its mission to protect public health and safety and the common defense and security pursuant to the Atomic Energy Act of 1954, NRC staff is conducting vulnerability assessments for the domestic utilization of radioactive material. Since the events of September 11, 2001, NRC has identified the need for license holders to implement compensatory measures and has issued several orders to license holders imposing enhanced security requirements. Finally, the NRC has acted to ensure that applicants and license holders maintain vigilance and a high degree of security awareness. Consequently, NRC will continue to consider measures to prevent and mitigate the consequences of acts of terrorism in fulfilling its safety mission. Additional information about the NRC staff's actions regarding physical security since September 11, 2001, can be found on the NRC's public website (http://www.nrc.gov/).

73

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