ML13182A614

Issuance of Environmental Scoping Summary Report Associated with the Staff'S Review of the Application by Union Electric Company for Renewal of the Operating License for the Callaway Plant, Unit 1

ML13182A614
Person / Time
Site:	Callaway
Issue date:	09/09/2013
From:	David Wrona License Renewal Projects Branch 2
To:	Heflin A Union Electric Co
Fells C, 415-6337
References
Download: ML13182A614 (33)

Text

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 September 9, 2013 Mr. Adam C. Heflin Senior Vice President and Chief Nuclear Officer Union Electric Company P.O. Box 620 Fulton, MO 65251 SUBJECT ISSUANCE OF ENVIRONMENTAL SCOPING

SUMMARY

REPORT ASSOCIATED WITH THE STAFF'S REVIEW OF THE APPLICATION BY UNION ELECTRIC COMPANY FOR RENEWAL OF THE OPERATING LICENSE FOR THE CALLAWAY PLANT, UNIT 1

Dear Mr. Heflin:

The U.S. Nuclear Regulatory Commission (NRC) staff conducted an environmental seeping process and solicited public comments from February 24, 2012, to April 24, 2012. This process determined the scope of the staff's environmental review of the application for renewal of the operating license for the Callaway Plant, Unit 1 (Callaway). The seeping process is the first step in the development of a plant-specific supplement to NUREG-1437 Revision 1, "Generic Environmental Impact Statement for License Renewal of Nuclear Plants" (GElS). for Callaway.

As part of the seeping process, the staff held two public meetings in Fulton, MO, on March 14, 2012, to solicit public input regarding the scope of the review. The staff also received written comments by letter and through www.Regulations.gov. At the conclusion of the seeping process, the staff prepared the enclosed environmental seeping summary report identifying comments received during the seeping period. In accordance with Section 51.29(b) of Title 10 of the Code of Federal Regulations (1 0 CFR), the staff will send a copy of the scoping summary report to all who have participated in the seeping process.

The transcripts of the public seeping meetings are available for public inspection in the NRC Public Document Room (PDR), located at One White Flint North, 11555 Rockville Pike, Rockville, Maryland 20852, or from the NRC's Agencywide Documents Access and Management System (ADAMS). The ADAMS Public Electronic Reading Room is accessible at http://www.nrc.gov/readinq-rm/adams.html. The transcripts for the afternoon and evening meetings are listed under ADAMS accession numbers ML12095A400 and ML12096A386, respectively. Persons who encounter problems while attempting to access documents in ADAMS should contact the NRC's PDR reference staff by telephone at 1-800-397-4209 or 301-415-4737 or by e-mail at pdr.resource@nrc.gov.

A Heflin The draft supplement to the GElS is scheduled to be issued in November 2013. A notice of the availability of the draft document and the procedures for providing comments will be published in the Federal Register. If you have any questions concerning the staff's environmental review of this license renewal application, please contact the project manager, Ms. Carmen Fells, at 301-415-6337 or by e-mail at Carmen.Fells@nrc.gov.

Sincerely, David J. Wrona, Chief Projects Branch 2 Division of License Renewal Office of Nuclear Reactor Regulation Docket No. 50-483

Enclosure:

As stated cc w/encl: Listserv

B. Allen The draft supplement to the GElS is scheduled to be issued in November 2013. A notice of the availability of the draft document and the procedures for providing comments will be published in the Federaf Register. If you have any questions concerning the staff's environmental review of this license renewal application, please contact the project manager, Ms. Carmen Fells, at 301-415-6337 or by e-mail at Carmen.Fells@nrc.gov.

Sincerely, IRA by Elaine Keegan for/

David J. Wrona, Chief Projects Branch 2 Division of License Renewal Office of Nuclear Reactor Regulation Docket No. 50-483

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Environmental Impact Statement Scoping Process Summary Report Callaway Plant, Unit 1 Callaway County, MO September 2013 U.S. Nuclear Regulatory Commission Rockville, Maryland ENCLOSURE

Introduction The U.S. Nuclear Regulatory Commission (NRC) received an application from Union Electric Company, a subsidiary of Ameren Corporation and doing business as Ameren Missouri (Ameren), dated December 19, 2011, for renewal of the operating license for Callaway Plant, Unit 1 (Callaway). Callaway is located in Callaway County, approximately 10 miles southeast of Fulton, Missouri, and 80 miles west of the St. Louis metropolitan area. The purpose of this report is to provide a concise summary of the determinations and conclusions reached, including the significant issues identified, as a result of the seeping process in the NRC staff's (the staff's) environmental review of this license renewal application.

As part of the application, Ameren submitted an environmental report (ER) (Ameren 2011) prepared in accordance with Title 10 of the Code of Federal Regulations (1 0 CFR) Part 51, which contains the NRC requirements for implementing the National Environmental Policy Act of 1969 (NEPA). The requirements for preparation and submittal of ERs to the NRC are outlined in 10 CFR 51.53(c)(3).

On June 20, 2013, the NRC published a final rule (78 FR 37282) revising its environmental protection regulation, Title 10 of the Code of Federal Regulations (1 0 CFR) Part 51, "Environmental protection regulations for domestic licensing and related regulatory functions." The final rule updates the potential environmental impacts associated with the renewal of an operating license for a nuclear power reactor for an additional 20 years. The revised GElS, which updates the 1996 GElS, provides the technical basis for the revised rule. The revised GElS specifically supports the revised list of NEPA issues and associated environmental impact findings for license renewal contained in Table 8-1 in Appendix 8 to Subpart A of the revised 10 CFR Part 51. The final rule consolidates similar Category 1 and 2 issues, changes some Category 2 issues into Category 1 issues, and consolidates some of those issues with existing Category 1 issues. The revised rule also adds new Category 1 and 2 issues.

The final rule became effective 30 days after publication in the Federal Register. Compliance by license renewal applicants is not required until one year from the date of publication (i.e.,

license renewal environmental reports submitted later than one year after publication must be compliant with the new rule). Nevertheless, under NEPA, the NRC must now consider and analyze in its license renewal SEISs, the potential significant impacts described by the final rule's new Category 2 issues and, to the extent there is any new and significant information, the potential significant impacts described by the final rule's new Category 1 issues.

Additionally, regarding spent nuclear fuel, the NRC has made changes to the "Onsite storage of spent nuclear fuel" issue and the "Offsite radiological impacts of spent nuclear fuel and high-level waste disposal" issue as a result of the United States Court of Appeals decision in New York v. NRC, 681 F.3d 471 (D.C. Cir. 2012), which vacated the NRC's 2010 waste confidence decision and rule (75 FR 81032 and 81037; December 23, 2010). The Category 1 "Onsite storage of spent nuclear fuel" issue was revised to limit the period of time covered by the issue to the license renewal term. Similarly, the NRC revised the Category 1 "Offsite radiological impacts of spent nuclear fuel and high-level waste disposal" issue by reclassifying

the issue from a Category 1 issue with an impact level of small to an uncategorized issue with an impact level of uncertain. These issues are discussed in Chapter 6 of the draft SEIS.

On February 24, 2012, the NRC initiated the seeping process by issuing a Federal Register notice (77 FR 11171 ). This notified the public of the staff's intent to prepare a plant-specific supplement to the GElS regarding the application for renewal of the Callaway operating license.

The plant-specific supplement to the GElS is also referred to as the Supplemental Environmental Impact Statement or SEIS. The SEIS will be prepared in accordance with 10 CFR Part 51.

The seeping process provides an opportunity for public participation to identify issues to be addressed in the SEIS and to highlight public concerns and issues. The notice of intent identified the following objectives of the seeping process:

• Define the proposed action

• Determine the scope of the SEIS and identify significant issues to be analyzed in depth

• Identify and eliminate peripheral issues

• Identify any environmental assessments (EAs) and other environmental impact statements {EISs) being prepared that are related to the SEIS

• Identify other environmental reviews and consultation requirements

• Indicate the schedule for preparation of the SEIS

• Identify any cooperating agencies

• Describe how the SEIS will be prepared The NRC's proposed action is whether to renew the Callaway operating license for an additional 20 years.

The scope of the SEIS includes an evaluation of the environmental impacts of license renewal and reasonable alternatives to license renewal. The "Seeping Comments and Responses" section of this report includes specific issues identified by the comments. The subsequent NRC responses explain if the issues will be addressed in the SEIS and, if so, where they will likely be addressed.

Throughout the seeping process, the staff identified and eliminated issues that were not directly related to the environmental review. This report provides responses to comments that were determined to be out of the scope of this review.

The NRC is required to consult with the U.S. Fish and Wildlife Service under Section 7 of the Endangered Species Act in order to evaluate the potential impacts of continued operation on Federally-listed endangered species. In order to fulfill its obligations under the National Historic Preservation Act, the NRC initiated consultation with the Advisory Council on Historic Preservation and the Missouri State Historic Preservation Office.

"4" The NRC staff expects to publish the draft SEIS in November 2013.

The NRC, as an independent regulatory agency, routinely and extensively consults with Federal, State, Tribal, and local entities during development of EISs and EAs. The staff did not identify any cooperating agencies for this review.

The SEIS will be prepared by the staff with contract support from Ecology and Environment, Inc., and Pacific Northwest National Laboratory.

The NRC invited the applicant; Federal, State and local government agencies: Tribal governments; local organizations; and individuals to participate in the seeping process by providing oral comments at the scheduled public meetings or by submitting written comments before the end of the seeping comment period on April 24, 2012. The seeping process included two public meetings which were held on March 14, 2012, at Fulton City Hall, 18 East 41h Street, Fulton, MO 65251. The NRC issued press releases, purchased newspaper advertisements, em ailed information to State and local government agencies and delegates, and distributed flyers locally to advertise these meetings. Approximately 50 people attended the meetings.

Each session began with NRC staff members providing a brief overview of the license renewal process and the NEPA environmental review process. Following the NRC's prepared statements, the floor was opened for public comments. Eight attendees provided oral comments that were recorded and transcribed by a certified court reporter. One attendee asked a question related to storage of waste during the question and answer session of the evening meeting and that question has been included here due to the June 8, 2012, decision made by the U.S. Court of Appeals for the District of Columbia to vacate the NRC's Waste Confidence Decision and Rule. The transcripts of the comments from these meetings are included at the end of this report. The NRC issued a summary of the seeping meetings on April11, 2012 (NRC 2012).

All documents associated with this seeping process are available for public inspection in the NRC Public Document Room (PDR), located at One White Flint North, 11555 Rockville Pike, Rockville, Maryland 20852, or from the NRC's Agencywide Documents Access and Management System (ADAMS). The ADAMS Public Electronic Reading Room is accessible at http://www.nrc.gov/reading-rm/adams.html. Persons who encounter problems in accessing documents in ADAMS should contact the NRC's PDR Reference staff by telephone at 1-800-397-4209 or 301-415-4737 or by e-mail at odr.resource@nrc.gov. The ADAMS accession number for each document is listed below in Table 1.

In addition to the comments received at the meetings, the NRC also received two comments on www.Regulations.gov, both referencing the review. At the conclusion of the seeping period, the staff reviewed the transcripts, meeting notes, and all written material received in order to identify individual comments. Each comment was marked with a unique identifier including the Commenter ID (specified in Table 1) and a comment number, allowing each comment to be traced back to the transcript or www.Regulations.gov submittal (see example in Figure 1).

"5 "

Figure 1. Key to Identifiers "My name is John Doe!al and this comment relates }

to alternative energy sources.

I would also like to discuss my comments that }

relate to Aquatic Resources ... " 1 -2 1'1-AQ "My name is Jane Doe and my comment relates to }

Aquatic Resources .. " 2 AQ 1' 1 (a) Commenter name identified in Table 1.

(b) Commenter ID specified in Table 1.

(c) Sequential comment number (d) Technical category, presented in Table 2 and Table 3 Table 1 identifies the individuals providing comments and the assigned Commenter 10. For oral comments, the individuals are listed in the order in which they spoke at the public meeting.

Table 1 also includes the accession numbers of each source of comments in order to locate the original reference in ADAMS.

Comments were consolidated and placed into 1 of 27 technical issue categories, which are presented in Table 2. These categories are based on the topics that will be contained within the staff's SEtS for Callaway, as outlined by the GElS.

Once comments were grouped according to subject area, the staff determined the appropriate action for the comment. The action or resolution for each comment is described in the staff's responses in this report. Table 3 represents the location where the response to each technical category begins.

Table 1. Individuals Providing Comments During The Scoping Comment Period Each commenter is identified along with their affiliation and how their comment was submitted.

ADAMS Commenter Affiliation (if stated) 10 Comment Source Accession Number State Energy Director, Afternoon seeping Ed Smith Missouri Coalition for ML12095A400 meeting the Environment Alderman, Afternoon seeping Pamela Murray 2 ML12095A400 City of Holts Summit meeting Afternoon seeping ML12095A400 Member of Board meeting Kay Drey of Directors, 3 ML12101A419 Beyond Nuclear Articles submitted ML12101A423 Afternoon seeping Ruth Shaefer Resident 4 ML12095A400 meeting City Administrator, Afternoon seeping Bill Johnson 5 ML12095A400 Fulton, MO meeting

ADAMS Commenter .Affiliation (If stated) ID Comment Source Accession Number Evening seeping Frank Wise Resident 6 ML12096A386 meeting Mayor, Evening seeping LeRoy Benton 7 ML12096A386 City of Fulton, MO meeting County Commissioner, Evening seeping Doc Fritzer 8 ML12096A386 Callaway County, MO meeting Evening seeping Courtney Johnson Resident 9 ML12096A386 meeting Anonymous Missouri 10 www.Regulations.gov ML12062A071 Kurt Wadzinski Bureau of Land Management 11 www.Regulations.gov ML12076A124 Table 2. Technical Issue Categories. Each comment was placed in the appropriate category.

For Callaway, the comments fell into eight of the categories shown below.

Code Technical Issue Code Technical Issue License Renewal and NEPA AM Air Quality and Meteorology LR Process AL Alternatives NO Noise AE Aquatic Ecology NW Non-Radiological Waste Cl Cumulative Impacts OR Opposition to License Renewal DC Decommissioning/Deregulation OS Outside of Scope(aJ EC Environmental Concerns PA Postulated Accidents & SAMA ED Editorial PS Protected Species and Habitats EJ Environmental Justice RB Radiological Impacts to Biota FC Fuel Cycle RW Radiological Waste GE Geology SE Socioeconomics GW Groundwater SR Support for License Renewal Historical and archaeological HA sw Surface Water resources HH Human Health TE Terrestrial Ecology LU Land Use (aJ Outside of Scope are those comments that pertain to issues that are not evaluated during the environmental review of license renewal and include, but are not limited to, issues such as need for power, emergency preparedness, safety, security, and terrorism_

Table 3. Comment Response Location Comment Category Page Alternative Energy Sources 8 Geology 8 License Renewal NEPA 9 Process Opposition to License Renewal 9 Outside of Scope 9 Postulated Accidents 12 Radiological Waste 12 Support of License Renewal 12 The comments and suggestions received as part of the seeping process are documented in this section, and the disposition of each comment is discussed. The meeting transcripts and written comments are included in their original form at the end of this report. In those cases where no new environmental information was provided by the commenter, a brief response has been provided to the comment, and no further evaluation will be performed.

The preparation of the SEIS will take into account all the relevant issues raised during the seeping process. The SEIS will address both Category 1 and 2 issues, along with any new information identified as a result of the seeping process. The SEIS will rely on conclusions supported by information in the GElS for Category 1 issues and will include analysis of Category 2 issues and any new and significant information. The NRC will issue a draft SEIS for public comment. The comment period will offer the next opportunity for the applicant; interested Federal, State, and local government agencies; Tribal governments; local organizations; and other members of the public to provide input to the NRC's environmental review process. The comments received on the draft SEIS will be considered in the preparation of the final SEIS.

The final SEIS, along with the staff's safety evaluation report (SER), will provide the basis for the NRC's decision on the Ameren application to renew the Callaway license.

Callaway Plant, Unit 1 Scoping Comments and Responses

1. Alternative Energy Sources (AL)

Comment: The following comment has been categorized under the resource area of Alternative Energy Sources. The comment expresses opposition to nuclear power and the need to invest in clean, renewable energy sources such as wind and solar.

Identifiers: 10-5-AL Response: The staff will evaluate all reasonable alternatives, including the no-action alternative in Chapter 8 of the SEIS. In this chapter, the staff examines the potential environmental impacts of alternatives to license renewal for Caf/away, as well as alternatives that may reduce or avoid adverse environmental impacts from license renewal, when and where these alternatives are applicable.

In evaluating alternatives to license renewal, the staff first selects energy technologies or options currently in commercial operation, as well as some technologies not currently in commercial operation but likely to be commercially available by the time the Callaway operating license expires in 2024.

Second, the staff screens the alternatives to remove those that cannot meet future system needs. Then, the remaining options are screened to remove those with costs or benefits that do not justify inclusion in the range of reasonable alternatives. Any alternatives remaining, then, constitute alternatives to the proposed action that the staff evaluates in depth throughout Chapter 8.

This comment is in scope and will be represented and responded to in Appendix A of the draft SE/S.

2. Geology (GE)

Comment: The following comment has been categorized under the resource area of Geology.

The comment addresses concerns related to Callaway being located in a flood plain, the New Madrid fault line, and Tornado Alley. This comment is also addressed within the Postulated Accidents section (Identifier 10-4-PA).

Identifiers: 10-3-GE Response: The staff will address the current geologic environment for Callaway in Chapter 2 of the SEIS. This comment is in scope and will be represented and responded to in Appendix A of the draft SEIS.

3. License Renewal and NEPA Process (LR)

Comment: The following comment has been categorized under the resource area of License Renewal and NEPA Process. The comment expressed opposition to the deadline for submitting seeping comments and opposition to reliance on the 1996 GElS.

Identifiers: 1*1-LR Response: This comment refers to the license renewal process. A summary of the license renewal process is provided in Chapter 1 of the SEJS. This comment will be represented and responded to in Appendix A of the drafl SEIS.

Comment: The following comments are general in nature and relate to the license renewal process.

Identifiers: 4-1-LR, 11-1-LR Response: These comments provide no new and significant information and will not be evaluated further in the development of the draft SEIS.

4. Opposition to License Renewal {OR)

Comment: The following comment has been categorized under the area of Opposition to License Renewal. The comment is general in nature and expresses opposition to nuclear power.

Identifiers: 3-1-0R Response: The comment provides no new and significant information and will not be evaluated furlher in the development of the SEIS.

5. Outside of Scope (OS)

Comment: 1-2-05; The Coalition demands that the Supplemental GElS address the environmental applications of the Fukushima Daiichi Nuclear Reactor accident, including the environmental risks posed by the NRC's apparent decision to postpone implementation of a number of the Fukushima Task Force recommendations for safety and environmental protection upgrades until some undetermined future time. The Supplemental GElS should address all the Fukushima Task Force recommendations that are relevant to Callaway by (A) identifying which recommendations have been implemented and explaining how they have been implemented.

And (B) identifying all recommendations whose implementation has been postponed or explaining how that postponement will affect the safety and environmental risks posed by the reactor.

Comment: 10-1-0S; Considering the history of nuclear disasters and what happened last year to the Fukushima Daiichi nuclear plant, I believe it unwise for the United States to continue to license nuclear reactors generally. Not only is there no permanent solution to the storage of the dangerous waste which results from energy generation, but it is also a very unsafe form of

energy production. Parts of this comment are also addressed within the Radioactive Waste sec1ion (lden1ifier 10-2-RW).

Response: These comments discuss safety concerns and implications for Callaway as related to the events surrounding the accident at the Fukushima Da-ichi nuclear power plant in Japan.

The NRC continues to evaluate and act on the lessons learned from the March 2011 nuclear accident in Japan to ensure that appropriate safety enhancements are implemented at nuclear power plants here in the U.S. In accordance with Commission direction, the NRC's activities are being led by a steering committee comprised of senior NRC management. Additionally, the NRC established the Japan Lessons Learned Project Directorate, a group of over 20 full-time employees focused exclusively on implementing the lessons learned. The public can access addt1ional infonnation regarding the NRC response to the Japan nuclear acctdent on the NRC's public website.

On March 12, 2012, the NRC issued the first regulatory requirements for the nation's operating reactors based on the lessons-learned at Fukushima Daiichi. The NRC issued three orders requiring safety enhancements of operating reactors, construction permit holders, and combined license holders. These orders require nuclear power plants to implement safety enhancements related to (1) mitigation strategies to respond to extreme natural events resulting in the loss of power at plants, (2) ensuring reliable hardened containment vents, and (3) enhancing spent fuel pool instrumentation. The plants were required to promptly begin implementation of the safety enhancements and complete implementation within two refueling outages or by December 31, 2016, whichever comes first. In addition, the NRC issued a request for information, requesting each reactor reevaluate the seismic and flooding hazards at their site using present-day methods and information, conduct walk-downs of their facilities to ensure protection against the hazards in their current design basis, and reevaluate their emergency communications systems and staffing levels.

The NRC's environmental review is confined to environmental matters relevant to the extended period of operation requested by the applicant. The regulations governing the environmental review are contained in Title 10 of the Code of Federal Regulation (10 CFR) Parl51, and the regulations for the safety review are contained in 10 CFR Parl54. Because the two reviews are separate, operational safety issues and safety issues related to aging are outside the scope for the environmental review.

The principal safety concerns associated with license renewal are related to the aging of structures, systems, and components imporlant to the continued safe operation of the facility.

When the plants were designed, cerlain assumptions were made about the length of time each plant would be operated. During the safety review for license renewal, the NRC must determine whether aging effects will be adequately managed so the original design assumptions will continue to be valid throughout the period of extended operation, or venfy that any aging effects will be adequately managed. For all aspects of operation, there are existing regulatory requirements governing a plant that offer reasonable assurance of adequate protection if its license were renewed.

The NRC assesses plant performance continuously and communicates its assessment of plant performance in letters to the licensees. These assessment letters are available on a plant performance page for each plant, and are posted on the web site as they become available.

The NRC assessment report for Callaway can be accessed at http./lwww. nrc. qov/NRR/OVERSIGHT!ASSESS/CALUca/1 chart.html.

Therefore, these comments are not within the scope of the environmental review and will not be evaluated further in the development of the SEtS.

Comment: 10-6-0S; By the time the current license expires in 2024, the market for these alternative energy sources will be established, making the continued operation of a nuclear reactor inordinately expensive in comparison. No, there is no guarantee the price of solar and wind generated power will go down in the next twelve years, but history and economics tell us that as technology advances and supply and demand increase, prices go down.

Response: This comment address concerns regarding the cost of energy. The regulatory authority over licensee economics (including the need for power) falls within the jurisdiction of the States and to some extent within the jurisdiction of the Federal Energy Regulatory Commission. The proposed rule for license renewal had included a cost-benefit analysis and consideration of licensee economics as pari of the NEPA review. However, during the comment period, State, Federal, and licensee representatives expressed concern about the use of economic costs and cost-benefit balancing in the proposed rule and the GElS. They noted that the President's Council on Environmental Quality (CEQ) regulations interpret NEPA to require only an assessment of the cumulative effects of a proposed Federal action on the natural and man-made environment and that the determination of the need for generating capacity has always been the States' responsibility. For this reason, the purpose and need for the proposed action (i.e., license renewal) is defined in the GElS as follows:

The purpose and need for the proposed action (issuance of a renewed license) is to provide an option that affows for baseload power generation capability beyond the term of the current nuclear power plant operating license to meet future system generating needs. Such needs may be determined by other energy-planning decision-makers, such as State, utility, and, where authorized, Federal agencies (other than the NRC).

Section 51. 95(c)(2) of 10 CFR states that:

The supplemental environmental impact statement for license renewal is not required to include discussion of need for power or the economic costs and economic benefits of the proposed action except insofar as such benefits and costs are either essential for a determination regarding the inclusion of an alternative in the range of alternatives considered or relevant to mitigation.

The comment is outside the scope of the license renewal review and will not be evaluated further in the development of the draft SEIS.

6. Postulated Accidents (PA)

Comment: The following comment has been categorized under the area of Postulated Accidents. The comment expresses concern related to the potential for natural hazards such as flooding, tornadoes, and earthquakes to affect Callaway. This comment also addresses the implications for Callaway as related to the events surrounding the accident at the Fukushima Dai-ichi nuclear power plant in Japan. This comment is also addressed within the Geology section (Identifier 10-3-GE).

Identifiers: 10-4-PA Response: The staff will address postulated accidents and the potential for new and significant information related to severe accident mitigation alternatives in Chapter 5 of the draft SEJS.

This comment is in scope and wiff be represented and responded to in Appendix A of the draft SEIS.

7. Radiological Waste (RW)

Comment: The following comments have been categorized under the resource area of Radiological Waste. The comments express concern related to the generation and storage of radioactive waste and the impact to the environment.

Identifiers: 6-1-RW, 10-2-RW Response: The staff will address radioactive waste management in Section 2.1.2 of the SEtS.

These comments are in scope and wiff be represented and responded to in Appendix A of the draff SEIS.

8. Support for License Renewal (SR)

Comment: The following comments have been categorized under the area of Support for License Renewal. These comments are general in nature and express support for nuclear power, Ameren, or license renewal of Callaway.

Identifiers: 2-1-SR, 5-1-SR, 7-1-SR, 8-1-SR, 9-1-SR Response: These comments provide no new and significant information and will not be evaluated furlher in the development of the SEIS.

References 10 CFR 51. Code of Federal Regulations, Title 10, Energy, Part 51, "Environmental Protection Regulations for Domestic Licensing and Related Regulatory Functions."

[Ameren] Ameren Missouri. 2011. "License Renewal Application, Callaway Plant Unit 1, Facility Operating License No. NPF-30." December 15, 2011. Agencywide Documents Access and Management System (ADAMS) Accession No. ML1135303720.

National Environmental Policy Act of 1969 (NEPA). 42 U.S. C. 4321, et seq.

[NRC] U.S. Nuclear Regulatory Commission. 1996. Generic Environmental Impact Statement for License Renewal of Nuclear Plants, NUREG-1437, Volumes 1 and 2, Washington, D.C.,

ADAMS Accession Nos. ML040690705 and ML040690738.

[NRC] U.S. Nuclear Regulatory Commission. 1999. Generic Environmental Impact Statement for License Renewal of Nuclear Plants, Main Report, "Section 6.3- Transportation, Table 9.1, Summary of Findings on NEPA Issues for License Renewal of Nuclear Power Plants, Final Report," NUREG-1437, Volume 1, Addendum 1, Washington, D.C., ADAMS Accession No. ML040690720.

[NRC] U.S. Nuclear Regulatory Commission. 2012. Summary of Public Seeping Meetings Conducted Related to the Review of the Callaway Plant, Unit 1, License Renewal Application.

April11, 2012. ADAMS Accession No. ML12089A099

[NRC] U.S. Nuclear Regulatory Commission. 2013. Generic Environmental Impact Statement for License Renewal of Nuclear Plants, NUREG-1437, Revision 1, Volumes 1, 2, and 3, Washington, D.C., June 2013. ADAMS Accession Nos. ML13106A241, ML13106A242, and ML13106A244.

Comment Letters and Meeting Transcripts The comment letters and public seeping meeting transcripts are attached to this report.

29 1 to thank the Nuclear Regulatory Commission for having 2 this public meeting today.

3 So the Missouri Coalition I should have 4 started reading my document first. The Missouri 5 Coalition for the Environment appreciates the 6 opportunity to submit comments to the Nuclear Regulatory Commission regarding the scope of the 8 Supplement to the Generic Environmental Impact 9 Statement of the license renewal for the Callaway 10 Nuclear Reactor.

11 The Missouri Coalition for the Environment 12 is a 42-year old independent statewide environmental 13 non-profit. It includes members living near the 14 Callaway Nuclear Reactor. The Coalition has a long 15 history of legal intervention with the Callaway 16 Reactor that goes back four decades. Our long-17 standing concern has been one of public safety and 18 protection of our environment.

19 The Coalition plans to intervene in the 20 upcoming license proceedings regarding the Union 21 Electric Company's license for renewal application.

22 As a prellmlnary matter, we request that the NRC 23 extend the deadline for submitting written scoping 1-1-LR I 24 comments until 30 days after the deadline for 25 submitting hearing requests and contentions. That NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE . N W (202) 234-4433 WASHINGTON, DC. 20005-3701 WNW.nealrgross com

30 1 date is April 24th.

2 So while we believe it is appropriate for 3 the NRC to hold public meetings now in order to 4 explain a license renewal process to the public, it is 5 ~nreasonable and unfair to require the public to 6 comment on the scope of the Supplemental GEIS at this stage of the proceeding. When the Missouri Coalition 1-1-LR Continued 8 for the Environment and other members of the public 9 are reviewing the license renewal application that's 10 four hundred and -- excuse me -- the 1,200 page highly 11 technical license renewal application and the 400 page 12 highly technical environmental report.

13 With respect to the scope of the 14 Supplemental Generic Environmental Impact Statement, 15 the Missouri Coalition for the Environment has two 16 overarching concerns. First, we believe it is 17 ~nacceptable for the NRC to rely on the 1996 GEIS for 18 the renewal of the Callaway license because it's 19 severely out of date. The NRC should postpone 20 rreparation of the Supplemental GElS for the Callaway 21 pnit until it is finalized and revised GEIS that it 22 issued for comment in July of 2009. In the 23 alternative it should prepare an EIS, Environmental 24 Impact Statement, for Callaway that addresses all 25 environmental issues and does not rely at all on a 16-NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE.. N.W.

(202) 234-4433 WASHINGTON, DC_ 20005--3701 www nealrgross.com

11 1 year-old document.

2 Given that the draft version of the 1-1-LR Continued 3 revised GEIS was issued fully two and a half years 4 ago, continued reliance on this old document is 5 utterly unjustified.

6 Second the Coalition demands that the 7 Supplemental GEIS address the environmental 8 applications of the Fukushima Daiichi Nuclear Reactor accident, including the environmental risks posed by 10 the NRC's apparent decision to postpone implementation 11 of a number of the Fukushima Task Force 12 recommendations for safety and .

envJ.ronmental 1-2-0SJ 13 protection upgrades until some undetermined future 14 time.

15 The Supplemental GEIS should -- excuse me 16 -- the Supplemental GEIS should recommendations --

17 excuse me -- I'll just start over.

18 The Supplemental GEIS should address all 19 the Fukushima -- should address all the Fukushima Task 20 Force recommendations that are relevant to Callaway.

21 By {A) identifying which recommendations 22 have been implemented and explaining how they have 23 been implemented.

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32 1 how that postponement will affect the safety and I

1-2-0S Continued 2 environmental risks posed by the reactor.

3 Thank you for your time.

4 MS. SALTER: Thank you, Mr. Smith.

5 I would now invite Pamela Murray to come 6 up to the podium. Ms. Murray lS an Alderman with the 7 city of Holts Summit.

8 MS. MURRAY: Thank you for this 9 opportunity to address everyone. I am a local elected 10 official. I'm not an environmentalist. But I do have 11 some experience being a Callaway County resident. And 12 that is that Ameren Missouri has had a history of 2-1-SR I 13 being very responsive whenever an issue has been raised. And I'm sure that when the final regulations 15 are implemented that that will continue. I certainly 16 hope it will. And certainly I feel that past behavior 17 and this case responsiveness lS a good predictor of 18 future behavior. So I do not have any specific 1 concerns regarding that.

20 Being active in my community, I ~ave been 21 involved with Ameren Missouri and found them to be a 22 good corporate citizen. I'd like to speak briefly 23 about two projects Ameren Missouri has been involved 24 with. One of those is a tree planting in Holts 25 Summit. And they were a financial contributor. They NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISlAND AVE., N.W (202) 234-4433 WASHINGTON. 0 C_ 20005-3701 IWffl.nealrgross com

33 1 also provided a great deal of labor when it came time"'~0Cc--,

2-1-SR 2 to plant hundreds of trees and shrubs in Holts Summit. Continued 3 They provided expertise for our environmental project.

4 They also throughout the state of Missouri are 5 involved in the Missouri Relief Program. They are a 6 maJor benefactor for this program which provides free 7 trees to cities and non-profit corporations. And I 8 just think that that demonstration for the respect for 9 the environment should also be taken into 10 consideration. And I'd like to thank the NRC and the 11 City of Fulton for providing this facility.

12 Thank you.

13 MS. SALTER: Thank you, Ms. Murray.

14 I'd like to invite Kay Drey up to the 15 podium. Ms. Drey is with Beyond Nuclear.

16 MS. DREY: Hi, thank you for this, having this meeting today. My name is Kay Drey. I live in 18 St. Louis. And I've been a member of the Missouri lS Coalition for the Environment since its creation. And 20 I'm also a member of the Board of Directors at Beyond 21 Nuclear, an organization located in Tacoma Park, 22 Maryland.

23 And all I'm here today is just to submitr-1'-"'=

3-1-0RI 24 for the record of today's scoping meeting three 25 documents. One is a brand new copy of the Economist.

"O"L ~.

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34 1 And its cover is called, "Nuclear Energy, t:'1e Dream 2 That Failed." And I really like the cover. Jl.nd there 3-1-0R 3 are some long reports ln here. so I think this is Continued 4 something that may be of interest to some of you.

5 And then two pamphlets that I helped 6 write. One lS called, "Dirty, Dangerous, and 7 Expensive: The Verdict Is in on Nuclear Power."

8 These are not in favor of nuclear power. And the 9 other one is called "The Lethal Legacy of the Atomic 10 Age: 1942 to the Year 2012," which is now to 11 infinity. And it says, "A mountain of waste 70 years 12 high, it's time to stop making it."

13 And I have more copies if anyone would 14 like a copy.

15 And so again, I do thank you for the 16 opportunity to have this meeting here.

17 MS. SALTER: With that, I'd like to invite 18 Ruth Schaefer.

19 MS. SCHAEFER: I'd like to defer my 4-1-LR I 20 comments. I think the gentleman from the Coalition 21 has said it.

22 MS. SALTER: Okay, you are our last 23 speaker.

24 Oh, we have another card. All right. I 25 invite Bill Johnson to the podium. Please introduce NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE, N_W.

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35 1 yourself and, if you're affiliated with an 2 organization, you can mention that too.

3 MR. JOHNSON: Good afternoon. My name is 4 Bill Johnson. I'm the City Administrator of Fulton, 5 Missouri, and I have been for the past 16 and a half, 6 17 years. I'm here actually speaking as a citizen 7 because the City Council has not of yet taken an 8 official position on this. But I am 100 percent 9 confident the City Council would be behind every word 10 that I am about to say.

11 The citizens of Fulton like the Ameren 12 plant where it is. We like the operation. We like 5-1-SR 1 13 the staffing. We like the safety levels. We are 14 incredibly involved in the safety review of the 15 facilities out there. If anyone is concerned about 16 the safety record, our records are available online if 17 you want to take the time to look. The inspections 18 are online. You can even ask for the NRC to mail you 19 -- email you, put you on a list and get an email to 20 you if you'd like.

21 We've had a great positive relationship 22 with the nuclear plant for the 27 years it's been in 23 operation and for the 10 years or so before that when 24 it was under construction. We hope to be able to 25 maintain that strong relationship for a long time.

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36 1 What's good for Fulton, what's good for 2 Callaway County, what's good for the State of 5-1-SR Missouri, is Continued 3 good for the Callaway Plant and vice 4 versa. What is good for us is good for them. It's a 5 great working relationship.

6 As I kind of said, having been here for 17 years, I have been involved in dozens and dozens of 8 drills associated with the safety performance of the 9 plant. The city is actively involved when it comes to 10 the drills. The City Administrator, myself, is there.

11 The Mayor is there, the Police Chief, Fire Chief, 12 planning officials, city engineers, city utilities.

13 We through our actions support and endorse the Ameren 14 plant.

15 And many times throughout the year, Ameren 16 comes to us and says, "Is there anything we can do for 17 you?" Sometimes we take them up on it; sometimes we 18 don't. But they are an incredible corporate citizen 19 to the community of Fulton.

20 And like I said, we would like to 21 encourage the NRC to agree with this extension.

22 Thank you.

23 MS. SALTER: Thank you, very much. I do 24 believe unless there's another yellow card back there 25 that we don't have anyone else signed up to make a NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE .. N W (202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com

24 1 So if you have a question, you can raise 2 your hand and I'll bring the microphone to you.

3 All right, a gentleman in the back.

4 Please start by introducing yourself.

5 MR. WISE: My name is Frank Wise of the 6 city of Jefferson. I'm just curious if the waste 6-1-RWI 7 storage situation will have any effect on the license 8 renewal. I hear that the federal government has not 9 yet achieved a permanent waste storage. How will that 10 affect the renewal?

11 MS. SALTER: Brian, you going to talk 12 about that?

13 MR. HARRIS: The waste storage, that's a 14 separate regulatory process in another office within 15 the NRC. So we focus specifically on the license 16 renewal process. We are aware that's managed another 17 office within the agency.

18 MS. SALTER: Is that something you will 19 take into consideration in the license renewal or 20 there's another process?

21 MR. HARRIS: That's another process in 22 which they'll handle your question.

23 MS. SALTER: Dennis.

24 MR. MOREY: I just want to clarify on 25 that, the waste storage issue. That what we're doing NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE, N W_

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29 1 I'm sure that the endorsement will happen in the very 2 near future.

3 Ameren's safety record has been an 4 excellent one. And I know that safety is of the 5

7 the community. I endorse their request for license 8 renewal of the current facility and encourage a positive response to their request.

10 Ameren's energy campus is a vital part of 11 Callaway County's and the state of Missouri's economy.

12 As the Environmental Protection Agency regulations to 13 continue to make coal fired plants cost prohibitive to 14 operate, nuclear plants such as the one here at 15 Callaway will be of vital importance to the 16 availability and reliability of electricity to the 17 Midwest of the state of Missouri. And of course 18 without adequate economical supply of electric energy, 19 our national and regional economies will be extremely 20 negatively impacted.

21 Again, thank you for your time. And again 22 I endorse the Ameren's request for a license renewal.

23 Thank you.

24 MS. SALTER: Thank you, Mr. Benton.

25 We now invite Doc Kritzer to come up.

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30 1 He's a County Commissioner for Callaway County.

2 MR. FRITZER: Good evening. It's Fritzer, 3 but I've been called a lot worse. I hadn't really 4 intended or planned to address the group tonight.

5 I've been out of town today and our Presiding 6 Commissioner came over this afternoon's meeting. And 7 I made a few notes when I found out he had already 8 addressed it. I understand you all had good 9 attendance, so that was good.

10 On behalf of the County Commission, our 11 structure in Missouri I don't know if some of 12 different states are all different on it. But we have 13 three County Commissioners in each one of our 1 counties. And Missouri has 114 counties. I also 15 happen to be the President of the County 16 Commissioner's Association for the state of Missouri.

17 I was in South Missouri earlier today for 18 a meeting down there with a regional group of the 19 commissioners. And one of the questions they asked 20 about was the status of the current Ameren plant and 21 what's going to happen with Unit 2. And I know this 22 isn't a discussion for Unit 2. But everyone is very 23 supportive of that, too, for the record.

24 Ameren has been a very good partner in the IS-1-SR I 25 community as LeRoy identified as a resident of lcontinuedl NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISlAND AVE .. N W (202} 234-4433 WASHINGTON. 0 C 20005-3701 www nealrgross.com

31 1 Callaway County since a few years ago. Back in the 2 ~50s, I moved here was to and ever since theyB-1-SR Continued started buying up the property to build the original 4 plant with a lot of speculation on what's going to 5 happen. But the fact that it's been in operation for 6 over 25 years, we haven't turned green yet. I think 7 everybody has finally accepted the fact we do have a 8 good base load facility here.

9 What's impressed me the most with the 10 operation down there is that they set high standards 1 for themselves for safety and operations. And it's 12 not just standards for this facility, but they want to 13 be the industry standard. And that's always impressed 14 me with the management down there.

15 And as we go through our emergency 16 planning drills, we meet on a regular basis. Every 17 other year we have a greater drill with the :-JRC. In 18 the off year, we still have the drill. And from those 19 exercises we have a chance to improve upon what we've 20 learned from the previous exercise. Anything that's 21 changed during the course of the year that's involved 22 in the rollover in the personnel down there. So to 23 keep everybody informed on what's going on and keep in 24 touch on it. But I think those have been very 25 beneficial.

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32 1 One of the best benefits I think we've 2 seen from Callaway County lS that an Emergency 3 Preparedness that has made this county so much further 8-1-SR Continued 4 ahead of other counties for natural disasters. And 5 the advantage we've seen is that although most of our 6 drills for probably 20 years were all focused on what 7 would happen if there was an emergency at the Ameren 8 plant, we've got the same partners and players with 9 the ambulance, with the law enforcement, with the 10 Sheriff's Department, with the ambulances. And it's 11 given us an opportunity to be ready for tornados, 12 other storms, any type of natural disaster.

13 And over the last couple of years, other 14 counties have started trying to prepare for disasters.

15 Joplin is a perfect example. Even at Branson in the 16 past year. We are so much further ahead in this 17 county than some of the other counties because of 18 Ameren being located in Callaway County. So we're 19 proud of that fact.

20 That's a big factor that we have, that 21 Fulton and Callaway County have over a lot of other 2 counties. So for that, I think that's another plus 23 for Ameren being here.

24 I think I've pretty well covered all the 25 facts. I've been sitting there trying to scribble a NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE .. N.W (202} 234-4433 WASHINGTON, D.C 20005-3701 WI/>IW.nealrgross com

33 1 few notes. But we would be very supportive of the 2 extension of this facility. A few years ago when they 8- 1-SR 3 replaced the turbines in there, we knew they were c ontinued 4 going to be asking for an extension of another 20 5 years. So we're very supportive of that and hope that 6 takes place.

7 Thank you.

8 MS. SALTER: Thank you.

9 I have one final person that's signed up 10 to speak. So if you're on the fence, now would be the 11 time to give Dawn your card.

12 And with that, I'd like to invite our 13 final commenter at least as of right now. Courtney 14 Johnson.

15 MS . JOHNSON: Hi, good evening. My name 16 is Courtney Johnson. And I'm 19 years old. I have 17 lived in Fulton my entire life. So, you know, I grew 18 up with a nuclear plant. It's always been right 19 outside of town and that's just how it's always been 20 since the time I grew up.

21 My generation sees the nuclear plant as 22 jobs and opportunity as well as a provider of cost-23 effective, safe base load energy for our community.

9-1-SR I 24 Many of my friends' parents work for the plant. And 25 through the years I've heard a lot of very positive NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE N W (202) 234-4433 WASHINGTON, DC. 20005-3701 loWIW.nealrgross_com

34 1 comments about it from them.

2 Based on growing up here and seeing the 3 professional career opportunities that Ameren 4 provides, I decided many years ago that I would pursue 5 a college degree that would make myself marketable to 6 Ameren. I'm a student at Iowa State University r;';--:!--0.';----,

9-1-SR 7 studying chemical engineering and considering a minor Continued 8 in nuclear engineering. I can think of no better 9 career than to be a chemical or nuclear engineer at 10 the Callaway Nuclear Plant.

11 The extension being proposed at this 12 hearing would provide me and those that came before me 13 and those that will come after me job opportunities 14 and clean, safe, reliable energy for many years to 15 come. And I'd like to encourage the NRC to approve 16 this license extension.

17 MS. SALTER: Thank you.

18 So with that, that was the last. person 19 that signed up. And I don't see Dawn with any other 20 yellow cards. I'll give you one final chance before 21 we move to close the meeting.

22 Okay, well, with that I'd like to thank 23 everyone for coming and before I turn it over to 24 Dennis for some final comments, a couple of quick 25 things. We do have the evaluation forms in the back.

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Page 1 of I As of: February 29,2012 Received: February 29,2012 Status: Pending_ Post PUBLIC SUBMISSION Tracking No. 80fc899f Comments Due: April 24,2012 Submission Type: Web Docket: ~RC-2012-0001 &1jc?-/jj 02.?/.:V Receipt and Availability of Application for License Renewal Comment On: NRC-2012-0001-0003

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Prepare Environmental Impact Statement Document: NRC-2012-0001-DRAFT-0001

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License Renewal Application for Callaway Plant, Unit 1, Union Electric Company; Intent to

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Comment on FR Doc# 2012-04315 -1 v:

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Address: Missouri General Comment Considering the history of nuclear disasters and what happened last year to the Fukushima Daiichi 10-1-0SI nuclear plant, I believe it unwise for the United States to continue to license nuclear reactors generally. Not only is there no pennanent solution to the stor~ge of the dangerous waste whtc 10-2 RW I r It f om ener n r I I I lso ave unsafe fo of ener roduction. T e Callaway reactor is located in a tlood plain, Torando Alley, ana near the New Maana raun Ime, making this nuclear reactor suspectible to a variety of natural disasters, which was what ultimatly 10-3-GE, did in Fukushima. We know that as buildings age they weaken, and nuclear reactors are no 10-4-PA different.

Ameren Missouri needs to focus on making Missouri more energy efficient (the last I heard we were ranked 42/50 states in efficiency) and invest in clean, renewable energy sources. Ameren's 10-5-ALI own report in 2011 said there was no need for new generation and an old coal plant could be closed if they just invested in efficiency. Instead of doing this. they sought to charge ratepayers to build a new reactor, and have cut aU but about $1 million from their renewable energy programs.

By the time the current license expires in 2024, the market for these alternative energy sources will be established, making the continued operation of a nuclear reactor inordinately expensive in comparison. No, there is no guarantee the price of solar and wind generated power will go down 11 0-6 OS I in the next twelve years, but history and economics tell us that as teclmology advances and supply and demand increase, prices go do*wn.

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Page I of I As of: March 14,2012 Received: March 14, 2012 Status: Pending_Post PUBLIC SUBMISSION Tracking No. 80fd6fa6 Comments Due: April24, 2012 Submission Type: Web Docket: NRC-2012-0001 Receipt and Availability of Application for License Renewal Comment On: NRC-2012-0001-0003 License Renewal Application for Callaway Plant, Unit 1, Union Electric Company; Intent to Prepare Environmental Impact Statement Document: NRC-2012-0001-DRAFT-0002 oflp-;L J,w /.V Comment on FR Doc# 2012M04315 77;:"~ /IIJ'/

Submitter Information ~-.

_u 1*-J Name: Kurt Wadzinski Address:

626 E. Wisconsin Ave. -

Suite 200 Milwaukee, WI, 53202 Organization: Northeastern States Field Office 9

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in Government Agency Type: Federal '::J N w Government Agency: BLM "'

General Comment The Bureau of Land Management appreciates the opportunity to review and provide comments -LR I 1

regarding Docket No. 50M483, NRC-2012M0001 (Callaway Plant Operating License Renewal). 111 y'-*.:..:=

However, the BLM has no jurisdiction or authority with respect to this project, the agency does not have expertise or information relevant to this project, nor does the agency intend to submit comments regarding this project.

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