ML15113A187
| ML15113A187 | |
| Person / Time | |
|---|---|
| Site: | Davis Besse  |
| Issue date: | 04/30/2015 |
| From: | Keegan E Office of Nuclear Reactor Regulation |
| To: | |
| Blount B | |
| References | |
| NUREG-1437 S52 V2 | |
| Download: ML15113A187 (575) | |
Text
NUREG-1437 Supplement 52 Volume 2 Generic Environmental Impact Statement for License Renewal of Nuclear Plants Supplement 52 Regarding Davis-Besse Nuclear Power Station Final Report Appendices Office of Nuclear Reactor Regulation
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NUREG-1437 Supplement 52 Volume 2 Generic Environmental Impact Statement for License Renewal of Nuclear Plants Supplement 52 Regarding Davis-Besse Nuclear Power Station Final Report Appendices Manuscript Completed: March 2015 Date Published: April 2015 Office of Nuclear Reactor Regulation
COVER SHEET Responsible Agency: U.S. Nuclear Regulatory Commission, Office of Nuclear Reactor Regulation. There are no cooperating agencies involved in the preparation of this document.
Title: Generic Environmental Impact Statement for License Renewal of Nuclear Plants, Supplement 52, Regarding Davis-Besse Nuclear Power Station, Unit 1, Final Report, (NUREG-1437).
Davis-Besse Nuclear Power Station, Unit 1, is located in Carroll Township, Ottawa County, Ohio.
For additional information or copies of this document contact:
Division of License Renewal U.S. Nuclear Regulatory Commission Office of Nuclear Reactor Regulation Mail Stop O-11F1 11555 Rockville Pike Rockville, Maryland 20852 Phone: 1-800-368-5642, extension 8517 Email: elaine.keegan@nrc.gov ABSTRACT This supplemental environmental impact statement (SEIS) has been prepared in response to an application submitted by FirstEnergy Nuclear Operating Company (FENOC) to renew the operating license for Davis-Besse Nuclear Power Station, Unit No. 1, (Davis-Besse) for an additional 20 years.
This SEIS includes the analysis that evaluates the environmental impacts of the proposed action and alternatives to the proposed action. Alternatives considered include replacement power from a new, natural-gas-fired combined-cycle (NGCC) power plant; combination alternative of NGCC, solar, wind, and compressed air energy storage; a coal-fired power plant; and not renewing the license (the no-action alternative).
The U.S. Nuclear Regulatory Commissions (NRCs) recommendation is that the adverse environmental impacts of license renewal for Davis-Besse are not great enough to deny the option of license renewal for energy-planning decisionmakers. This recommendation is based on the following:
analysis and findings in the generic environmental impact statement, the Environmental Report submitted by FENOC, consultation with Federal, state, Tribal, and local agencies, NRC staffs own independent review, NRC staffs consideration of public comments received during the scoping process, and NRC staffs consideration of public comments received during the draft SEIS comment period.
iii
TABLE OF CONTENTS ABSTRACT .............................................................................................................................. iii FIGURES .................................................................................................................................. xi TABLES ................................................................................................................................. xiii EXECUTIVE
SUMMARY
....................................................................................................... xvii ABBREVIATIONS AND ACRONYMS ................................................................................... xxv 1.0 PURPOSE AND NEED FOR ACTION ........................................................................ 1-1 1.1 Proposed Federal Action.................................................................................. 1-1 1.2 Purpose and Need for Proposed Federal Action .............................................. 1-1 1.3 Major Environmental Review Milestones .......................................................... 1-1 1.4 Generic Environmental Impact Statement ........................................................ 1-3 1.5 Supplemental Environmental Impact Statement ............................................... 1-6 1.6 Cooperating Agencies ...................................................................................... 1-7 1.7 Consultations ................................................................................................... 1-7 1.8 Correspondence .............................................................................................. 1-8 1.9 Status of Compliance ....................................................................................... 1-8 1.10 References ...................................................................................................... 1-8 2.0 AFFECTED ENVIRONMENT ...................................................................................... 2-1 2.1 Facility Description ........................................................................................... 2-1 2.1.1 Reactor and Containment Systems ................................................... 2-6 2.1.2 Radioactive Waste ............................................................................ 2-7 2.1.3 Nonradioactive Waste Management ................................................ 2-10 2.1.4 Plant Operation and Maintenance ................................................... 2-12 2.1.5 Power Transmission System ........................................................... 2-12 2.1.6 Cooling and Auxiliary Water Systems .............................................. 2-14 2.1.7 Facility Water Use and Quality ........................................................ 2-16 2.2 Affected Environment ..................................................................................... 2-18 2.2.1 Land Use ......................................................................................... 2-18 2.2.2 Air and Meteorology ........................................................................ 2-18 2.2.3 Geologic Environment ..................................................................... 2-24 2.2.4 Surface Water Resources ............................................................... 2-28 2.2.5 Groundwater Resources.................................................................. 2-30 2.2.6 Aquatic Resources .......................................................................... 2-34 2.2.7 Terrestrial Resources ...................................................................... 2-41 2.2.8 Protected Species and Habitats ...................................................... 2-45 2.2.9 Socioeconomic Factors ................................................................... 2-62 2.2.10 Historic and Archaeological Resources ........................................... 2-75 v
Table of Contents 2.3 Related Federal and State Activities .............................................................. 2-79 2.3.1 Coastal Zone Management Act ....................................................... 2-79 2.4 References .................................................................................................... 2-80 3.0 ENVIRONMENTAL IMPACTS OF REFURBISHMENT ............................................... 3-1 3.1 Refurbishment Activities at Davis-Besse .......................................................... 3-3 3.2 Environmental Impacts of Refurbishment ......................................................... 3-3 3.2.1 Terrestrial ResourcesRefurbishment Impacts ................................ 3-3 3.2.2 Threatened and Endangered Species ............................................... 3-6 3.2.3 Housing ImpactsRefurbishment ..................................................... 3-6 3.2.4 Public Services: Public UtilitiesRefurbishment .............................. 3-7 3.2.5 Public Services: EducationRefurbishment ..................................... 3-7 3.2.6 Offsite Land UseRefurbishment ..................................................... 3-7 3.2.7 Public Services: TransportationRefurbishment.............................. 3-8 3.2.8 Historic and Archaeological Resources ............................................. 3-8 3.2.9 Environmental JusticeRefurbishment ............................................. 3-9 3.2.10 Air Quality........................................................................................ 3-10 3.3 Evaluation of New and Potentially Significant Information on Impacts of Refurbishment ............................................................................................... 3-12 3.4 Summary Impacts of Refurbishment .............................................................. 3-12 3.5 References .................................................................................................... 3-13 4.0 ENVIRONMENTAL IMPACTS OF OPERATION ........................................................ 4-1 4.1 Land Use ......................................................................................................... 4-1 4.2 Air Quality ........................................................................................................ 4-2 4.3 Geologic Environment ...................................................................................... 4-3 4.3.1 Geology and Soils ............................................................................. 4-3 4.4 Surface Water Resources ................................................................................ 4-4 4.4.1 Generic Surface Water Issues ........................................................... 4-4 4.4.2 Surface Water Use Conflicts.............................................................. 4-4 4.5 Groundwater Resources .................................................................................. 4-4 4.5.1 Groundwater Use Conflicts ................................................................ 4-5 4.5.2 Radionuclides Released to Groundwater........................................... 4-5 4.6 Aquatic Resources ........................................................................................... 4-5 4.6.1 Exposure of Aquatic Organisms to Radionuclides ............................. 4-6 4.7 Terrestrial Resources ....................................................................................... 4-7 4.7.1 Generic Terrestrial Resources Issues................................................ 4-7 4.7.2 Exposure of Terrestrial Organisms to Radionuclides ......................... 4-7 4.7.3 Effects on Terrestrial Resources (Non-cooling System Impacts) ....... 4-8 4.8 Protected Species and Habitats ....................................................................... 4-9 4.8.1 Species Protected Under the Endangered Species Act ..................... 4-9 4.8.2 Species Protected Under the Bald and Golden Eagles Protection Act ................................................................................................... 4-23 vi
Table of Contents 4.8.3 Species Protected Under the Migratory Bird Treaty Act ................... 4-23 4.8.4 Species Protected by the State of Ohio ........................................... 4-24 4.8.5 Conclusion ...................................................................................... 4-24 4.9 Human Health ................................................................................................ 4-25 4.9.1 Generic Human Health Issues ......................................................... 4-25 4.9.2 Radiological Impacts of Normal Operations ..................................... 4-26 4.9.3 Electromagnetic FieldsAcute Effects ............................................ 4-29 4.9.4 Electromagnetic FieldsChronic Effects ......................................... 4-30 4.10 Socioeconomics ............................................................................................. 4-30 4.10.1 Generic Socioeconomic Issues ....................................................... 4-31 4.10.2 Housing Impacts.............................................................................. 4-31 4.10.3 Public ServicesPublic Utilities ...................................................... 4-32 4.10.4 Public ServicesTransportation ..................................................... 4-32 4.11 Environmental Justice .................................................................................... 4-33 4.11.1 Minority Population .......................................................................... 4-34 4.11.2 Low-Income Population ................................................................... 4-36 4.11.3 Analysis of Impacts ......................................................................... 4-38 4.11.4 Subsistence Consumption of Fish and Wildlife ................................ 4-38 4.12 Offsite Land Use ............................................................................................ 4-39 4.12.1 Population-Related Impacts............................................................. 4-40 4.12.2 Tax Revenue-Related Impacts ........................................................ 4-40 4.13 Historic and Archaeological Resources .......................................................... 4-41 4.14 Evaluation of New and Potentially Significant Information .............................. 4-42 4.15 Cumulative Impacts ....................................................................................... 4-43 4.15.1 Cumulative Impacts on Air Quality ................................................... 4-46 4.15.2 Cumulative Impacts on Water Resources ........................................ 4-48 4.15.3 Cumulative Impacts on Aquatic Resources ..................................... 4-50 4.15.4 Cumulative Impacts on Terrestrial Resources ................................. 4-52 4.15.5 Cumulative Human Health Impacts ................................................. 4-54 4.15.6 Cumulative Socioeconomic Impacts ................................................ 4-56 4.15.7 Cumulative Historic and Archaeological Impacts ............................. 4-57 4.15.8 Cumulative Impacts of Environmental Justice ................................. 4-57 4.15.9 Summary of Cumulative Impacts ..................................................... 4-58 4.16 References .................................................................................................... 4-60 5.0 ENVIRONMENTAL IMPACTS OF POSTULATED ACCIDENTS ................................ 5-1 5.1 Design-Basis Accidents ................................................................................... 5-1 5.2 Severe Accidents ............................................................................................. 5-2 5.3 Severe Accident Mitigation Alternatives ........................................................... 5-3 5.3.1 Overview of SAMA Process............................................................... 5-3 5.3.2 Estimate of Risk ................................................................................ 5-4 5.3.3 Potential Plant Improvements ............................................................ 5-6 vii
Table of Contents 5.3.4 Evaluation of Risk Reduction and Costs of Improvements ................. 5-6 5.3.5 Cost-Benefit Comparison .................................................................. 5-7 5.3.6 Conclusions ....................................................................................... 5-8 5.4 References ...................................................................................................... 5-8 6.0 ENVIRONMENTAL IMPACTS OF THE URANIUM FUEL CYCLE AND SOLID WASTE MANAGEMENT............................................................................................. 6-1 6.1 The Uranium Fuel Cycle .................................................................................. 6-1 6.2 Greenhouse Gas Emissions .......................................................................... 6-11 6.2.1 Existing Studies ............................................................................... 6-11 6.2.2
Conclusions:
Relative Greenhouse Gas Emissions ........................ 6-15 6.3 References .................................................................................................... 6-17 7.0 ENVIRONMENTAL IMPACTS OF DECOMMISSIONING ........................................... 7-1 7.1 References ...................................................................................................... 7-3 8.0 ENVIRONMENTAL IMPACTS OF ALTERNATIVES .................................................. 8-1 8.1 Natural Gas-Fired Combined-Cycle (NGCC) Alternative .................................. 8-5 8.1.1 Air Quality.......................................................................................... 8-7 8.1.2 Groundwater Use and Quality ......................................................... 8-10 8.1.3 Surface Water Use and Quality ....................................................... 8-10 8.1.4 Aquatic Ecology............................................................................... 8-11 8.1.5 Terrestrial Ecology .......................................................................... 8-11 8.1.6 Human Health ................................................................................. 8-12 8.1.7 Land Use ......................................................................................... 8-13 8.1.8 Socioeconomics .............................................................................. 8-13 8.1.9 Transportation ................................................................................. 8-14 8.1.10 Aesthetics........................................................................................ 8-15 8.1.11 Noise ............................................................................................... 8-15 8.1.12 Historic and Archaeological Resources ........................................... 8-15 8.1.13 Environmental Justice ..................................................................... 8-16 8.1.14 Waste Management ........................................................................ 8-17 8.1.15 Climate Change-Related Impacts of a Natural Gas-Fired Combined Cycle Alternative ............................................................ 8-17 8.2 Combination Alternative ................................................................................. 8-18 8.2.1 Air Quality........................................................................................ 8-21 8.2.2 Groundwater Use and Quality ......................................................... 8-24 8.2.3 Surface Water Use and Quality ....................................................... 8-25 8.2.4 Aquatic Ecology............................................................................... 8-26 8.2.5 Terrestrial Ecology .......................................................................... 8-27 8.2.6 Human Health ................................................................................. 8-28 8.2.7 Land Use ......................................................................................... 8-29 8.2.8 Socioeconomics .............................................................................. 8-30 viii
Table of Contents 8.2.9 Transportation ................................................................................. 8-32 8.2.10 Aesthetics........................................................................................ 8-33 8.2.11 Noise ............................................................................................... 8-34 8.2.12 Historic and Archaeological Resources ........................................... 8-34 8.2.13 Environmental Justice ..................................................................... 8-35 8.2.14 Waste Management ........................................................................ 8-36 8.2.15 Climate Change-Related Impacts of the Combination Alternative .... 8-37 8.3 Coal-Fired Alternative .................................................................................... 8-38 8.3.1 Air Quality........................................................................................ 8-41 8.3.2 Groundwater Use and Quality ......................................................... 8-44 8.3.3 Surface Water Use and Quality ....................................................... 8-45 8.3.4 Aquatic Ecology............................................................................... 8-45 8.3.5 Terrestrial Ecology .......................................................................... 8-46 8.3.6 Human Health ................................................................................. 8-47 8.3.7 Land Use ......................................................................................... 8-48 8.3.8 Socioeconomics .............................................................................. 8-48 8.3.9 Transportation ................................................................................. 8-49 8.3.10 Aesthetics........................................................................................ 8-49 8.3.11 Noise ............................................................................................... 8-50 8.3.12 Historic and Archeological Resources ............................................. 8-50 8.3.13 Environmental Justice ..................................................................... 8-50 8.3.14 Waste Management ........................................................................ 8-51 8.3.15 Climate Change-Related Impacts of a Coal-Fired Alternative .......... 8-52 8.4 Alternatives Considered but Dismissed .......................................................... 8-53 8.4.1 New Nuclear .................................................................................... 8-53 8.4.2 Wind ................................................................................................ 8-53 8.4.3 Solar Power ..................................................................................... 8-61 8.4.4 Wood Waste.................................................................................... 8-65 8.4.5 Conventional Hydroelectric Power ................................................... 8-65 8.4.6 Ocean Wave and Current Energy .................................................... 8-66 8.4.7 Geothermal Power .......................................................................... 8-67 8.4.8 Municipal Solid Waste ..................................................................... 8-67 8.4.9 Biomass Fuels ................................................................................. 8-68 8.4.10 Oil-Fired Power ............................................................................... 8-69 8.4.11 Fuel Cells ........................................................................................ 8-69 8.4.12 Coal-Fired Integrated Gasification Combined Cycle ........................ 8-69 8.4.13 Energy Conservation/Energy Efficiency ........................................... 8-70 8.4.14 Purchased Power ............................................................................ 8-71 8.5 No-Action Alternative ..................................................................................... 8-72 8.5.1 Air Quality........................................................................................ 8-73 8.5.2 Groundwater Use and Quality ......................................................... 8-73 ix
Table of Contents 8.5.3 Surface Water Use and Quality ....................................................... 8-73 8.5.4 Aquatic Resources .......................................................................... 8-73 8.5.5 Terrestrial Resources ...................................................................... 8-73 8.5.6 Human Health ................................................................................. 8-73 8.5.7 Land Use ......................................................................................... 8-74 8.5.8 Socioeconomics .............................................................................. 8-74 8.5.9 Waste Management ........................................................................ 8-75 8.6 Alternatives Summary .................................................................................... 8-75 8.7 References .................................................................................................... 8-77
9.0 CONCLUSION
............................................................................................................ 9-1 9.1 Environmental Impacts of License Renewal ..................................................... 9-1 9.2 Comparison of the Environmental Impacts of License Renewal and Alternatives ...................................................................................................... 9-1 9.3 Resource Commitments................................................................................... 9-1 9.3.1 Unavoidable Adverse Environmental Impacts ................................... 9-1 9.3.2 Relationship Between Local Short-Term Uses of the Environment and the Maintenance and Enhancement of Long-Term Productivity ..................................................................... 9-2 9.3.3 Irreversible and Irretrievable Commitments of Resources ................. 9-3 9.4 Recommendation ............................................................................................. 9-4 10.0 LIST OF PREPARERS ............................................................................................. 10-1 11.0 LIST OF AGENCIES, ORGANIZATIONS, AND PERSONS TO WHOM COPIES OF THIS SUPPLEMENTAL ENVIRONMENTAL IMPACT STATEMENT WERE SENT......................................................................................................................... 11-1 12.0 INDEX ....................................................................................................................... 12-1 APPENDIX A COMMENTS RECEIVED ON THE ENVIRONMENTAL REVIEW .................. A-1 APPENDIX B NATIONAL ENVIRONMENTAL POLICY ACT ISSUES FOR LICENSE RENEWAL OF NUCLEAR POWER PLANTS ................................................ B-1 APPENDIX C APPLICABLE REGULATIONS, LAWS, AND AGREEMENTS ...................... C-1 APPENDIX D CONSULTATION CORRESPONDENCE ....................................................... D-1 APPENDIX E CHRONOLOGY OF ENVIRONMENTAL REVIEW CORRESPONDENCE ..... E-1 APPENDIX F U.S. NUCLEAR REGULATORY COMMISSION STAFF EVALUATION OF SEVERE ACCIDENT MITIGATION ALTERNATIVES FOR DAVIS-BESSE NUCLEAR POWER STATION IN SUPPORT OF LICENSE RENEWAL APPLICATION REVIEW.............................................. F-1 x
Table of Contents FIGURES Figure 1-1. Environmental Review Process ........................................................................ 1-3 Figure 1-2. Environmental Issues Evaluated During License Renewal ............................... 1-6 Figure 2-1. Location of Davis-Besse, 50 mi (80 km) Region ............................................... 2-2 Figure 2-2. Location of Davis-Besse, 6 mi (10 km) Region ................................................. 2-3 Figure 2-3. Davis-Besse Site Boundary and Facility Layout ................................................ 2-4 Figure 2-4. Davis-Besse Site Boundary and Facility Layout ................................................ 2-5 Figure 2-5. Typical Pressurized-Water Reactor .................................................................. 2-7 Figure 2-6. Davis-Besse Transmission System................................................................. 2-13 Figure 2-7. Davis-Besse Cooling Water System ............................................................... 2-15 Figure 2-8. Seismic Hazard Map....................................................................................... 2-26 Figure 2-9. Earthquake Epicenters near Davis-Besse....................................................... 2-27 Figure 2-10. Groundwater Monitoring Well Locations ......................................................... 2-31 Figure 2-11. 2007-2011 Groundwater Monitoring Tritium Concentrations .......................... 2-32 Figure 2-12. May 2010-December 2010 Groundwater Monitoring Tritium Concentrations ............................................................................................... 2-33 Figure 4-1. Census 2010 Minority Block Groups Within a 50-mi Radius of Davis-Besse ................................................................................................... 4-35 Figure 4-2. Census 2010 Low-Income Block Groups Within a 50-mi Radius of Davis-Besse ................................................................................................... 4-37 Figure 4-3. Observed Changes in Great Lakes Ice Cover 1963-2013 .............................. 4-49 xi
Table of Contents TABLES Table ES-1. Summary of NRC Conclusions Relating to Site-Specific Impact of License Renewal ............................................................................................... xxi Table 2-1. Davis-Besse Transmission Lines .................................................................... 2-14 Table 2-2. Annual Emissions Inventory Summaries for Sources at Davis-Besse, 2006-2010 ..................................................................................................... 2-22 Table 2-3. National Ambient Air Quality Standards and Ohio State Ambient Air Quality Standards ........................................................................................... 2-23 Table 2-4. Positive and Negative Trends in the Lake Erie Ecosystem Since the 1990s ............................................................................................................. 2-36 Table 2-5. Sport and Commercial Harvests of Major Species in Ohio Waters of Lake Erie and its Tributaries, 2008 ................................................................. 2-38 Table 2-6. Relative Abundance of Species in Impingement Sampling, 1980 ................... 2-39 Table 2-7. Entrainment Densities in Entrainment Sampling, 1980 ................................... 2-40 Table 2-8. Most Common Migrating Bird Species Near the Davis-Besse Site.................. 2-43 Table 2-9. ESA Species Under FWSs Jurisdiction That Occur in Ottawa County ........... 2-48 Table 2-10. Red Knots Present in Lake Erie Shorebird Migration Surveys, 2003-2010 ..................................................................................................... 2-49 Table 2-11. Piping Plovers Observed During BSBOs Lake Erie Marsh Migration Survey, 2003-2010 ........................................................................................ 2-50 Table 2-12. State-Listed Species That Occur in Ottawa County ........................................ 2-55 Table 2-13. Songbird Bandings During Annual Migration Surveys, 2003-2009 ................. 2-59 Table 2-14. Spring Raptor Survey Counts in the Lake Erie Marsh Region, 2006-2009 ..................................................................................................... 2-59 Table 2-15. Ducks, Swans, and Shorebirds Observed in Annual Spring Surveys at Navarre Marsh, 2006-2010 ............................................................................ 2-60 Table 2-16. Davis-Besse, Employee Residence by County ............................................... 2-63 Table 2-17. Housing in Lucas, Ottawa, Sandusky, and Wood Counties in Ohio in 2010 ............................................................................................................... 2-63 Table 2-18. Major Public Water Supply Systems (Million Gallons Per Day) ....................... 2-64 Table 2-19. Major Commuting Routes in the Vicinity of Davis-Besse, 2009 Average Annual Daily Traffic Count .............................................................................. 2-65 Table 2-20. Population and Percent Growth in Lucas, Ottawa, Sandusky, and Wood Counties from 1970-2010 and Projected for 2020-2050 ................................ 2-67 Table 2-21. Demographic Profile of the Population in the Davis-Besse Four-County Socioeconomic Region of Influence in 2010 ................................................... 2-68 Table 2-22. Seasonal Housing in Counties Located Within 50 Miles of Davis-Besse ......... 2-69 Table 2-23. Migrant Farm Workers and Temporary Hired Farm Labor in Counties Located Within 50 Miles of Davis-Besse ......................................................... 2-70 Table 2-24. Major Employers in Ottawa County, 2009 ....................................................... 2-71 Table 2-25. Employment by Industry in ROI, 2008-2010 3-Year Estimate ......................... 2-72 Table 2-26. Estimated Income Information for the Davis-Besse Four-County Socioeconomic Region of Influence, 2008-2010 3-Year Estimate .................. 2-73 xiii
Table of Contents Table 2-27. 2005-2009 3-Year Phase-In Rates Percentage Result of the July 2005 Ohio Tax Reform Act and the Fully Phased-In 0.26 Percent Commercial Activity Tax ..................................................................................................... 2-73 Table 2-28. Davis-Besse Property Tax Distribution and Jurisdictional Operating Budgets, 2004-2008....................................................................................... 2-74 Table 3-1. Category 1 Issues Related to Refurbishment .................................................... 3-1 Table 3-2. Category 2 Issues Related to Refurbishment .................................................... 3-2 Table 4-1. Land Use Issues ............................................................................................... 4-1 Table 4-2. Air Quality Issues.............................................................................................. 4-2 Table 4-3. Geologic Environment Issue ............................................................................. 4-3 Table 4-4. Surface Water Use and Quality Issues ............................................................. 4-4 Table 4-5. Groundwater Use and Quality Issues ............................................................... 4-5 Table 4-6. Aquatic Resources Issues ................................................................................ 4-6 Table 4-7. Terrestrial Resources Issues ............................................................................ 4-7 Table 4-8. Protected Species Issue ................................................................................... 4-9 Table 4-9. Summary of Impacts to Federally Listed Species ........................................... 4-11 Table 4-10. Davis-Besse Bird Mortality Survey Results During Three Consecutive Fall Seasons, 1972-1974 ................................................................................ 4-14 Table 4-11. Human Health Issues ..................................................................................... 4-25 Table 4-12. Socioeconomics During the Renewal Term .................................................... 4-30 Table 4-13. Other Projects and Actions Considered in the Cumulative Analysis for Davis-Besse ................................................................................................... 4-45 Table 4-14. Summary of Cumulative Impacts on Resource Areas ..................................... 4-59 Table 5-1. Issues Related to Postulated Accidents ............................................................ 5-1 Table 5-2. Davis-Besse Internal Events Core Damage Frequency .................................... 5-5 Table 5-3. Breakdown of Population Dose by Containment Release Mode ....................... 5-5 Table 6-1. Issues Related to the Uranium Fuel Cycle and Solid Waste Management ........ 6-1 Table 6-2. Nuclear GHG Emissions Compared to Coal ................................................... 6-13 Table 6-3. Nuclear GHG Emissions Compared to Natural Gas ........................................ 6-14 Table 6-4. Nuclear GHG Emissions Compared to Renewable Energy Sources ............... 6-15 Table 7-1. Issues Related to Decommissioning ................................................................. 7-2 Table 8-1. Summary of Alternatives Considered in Depth.................................................. 8-3 Table 8-2. Summary of Environmental Impacts of the NGCC Alternative Compared to Continued Operation of the Existing Davis-Besse ......................................... 8-6 Table 8-3. Summary of Environmental Impacts of the Combination Alternative Compared to Continued Operation of the Existing Davis-Besse ..................... 8-21 Table 8-4. Summary of Environmental Impacts of the Supercritical Coal-Fired Alternative Compared to Continued Operation of Davis-Besse ....................... 8-41 Table 8-5. Environmental Impacts of No-Action Alternative ............................................. 8-72 Table 8-6. Summary of Environmental Impacts of Proposed Action and Alternatives ...... 8-76 Table 10-1. List of Preparers ............................................................................................. 10-1 Table A-1. Commenters on the Scope of the Environmental Review ................................. A-2 Table A-2. Technical Issue Categories............................................................................... A-6 xiv
Table of Contents Table A-3. Comment Response Location in Order of Resource Area ................................ A-7 Table A-4. Commenters on the Draft Supplemental Environmental Impact Statement ..................................................................................................... A-222 Table A-5. Technical Issue Categories........................................................................... A-225 Table B-1. Generic Summary Findings on NEPA Issues for License Renewal of Nuclear Power Plants ....................................................................................... B-2 Table C-1. Federal and State Environmental Requirements............................................... C-2 Table C-2. Federal, State, and Local Permits and Other Requirements ............................. C-7 Table D-1. Consultation Correspondence ..........................................................................D-2 Table F-1. Davis-Besse Core Damage Frequency for Internal Events ............................... F-4 Table F-2. Breakdown of Population Dose by Containment Release Mode ....................... F-5 Table F-3. Davis-Besse Probabilistic Risk Assessment Historical Summary ...................... F-7 Table F-4. Davis-Besse Fire Zones and Their Contribution to Fire Core Damage Frequency ...................................................................................................... F-11 Table F-5. Impact on Population Dose Risk and Offsite Economic Cost Risk for Selected Sensitivity Cases.............................................................................. F-16 Table F-6. SAMA Cost-Benefit Screening Analysis for Davis-Besse ................................ F-25 xv
EXECUTIVE
SUMMARY
BACKGROUND By letter dated August 27, 2010, FirstEnergy Nuclear Operating Company (FENOC) submitted an application to the U.S. Nuclear Regulatory Commission (NRC) to issue a renewed operating license for Davis-Besse Nuclear Power Station, Unit No. 1, (Davis-Besse), for an additional 20-year period.
Pursuant to Title 10, Part 51.20(b)(2) of the Code of Federal Regulations (10 CFR 51.20(b)(2)),
the renewal of a power reactor operating license requires preparation of an environmental impact statement (EIS) or a supplement to an existing EIS. In addition, 10 CFR 51.95(c) states that the NRC shall prepare an EIS, which is a supplement to the NRCs NUREG-1437, Generic Environmental Impact Statement (GEIS) for License Renewal of Nuclear Plants.
The GEIS was originally published in 1996, and amended in 1999. Subsequently, on June 20, 2013, the NRC published a final rule (78 FR 37282) revising 10 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. A revised GEIS, which updates the 1996 GEIS, provides the technical basis for the final rule. The revised GEIS specifically supports the revised list of National Environmental Policy Act (NEPA) issues and associated environmental impact findings for license renewal contained in Table B-1 in Appendix B to Subpart A of the revised 10 CFR Part 51. The 2013 rule revised the previous rule to consolidate similar Category 1 and 2 issues, change some Category 2 issues into Category 1 issues, consolidate some of those issues with existing Category 1 issues, and adds new Category 1 and 2 issues.
The final rule became effective July 22, 2013, after publication in the Federal Register.
Compliance by license renewal applicants is not required until June 20, 2014, (i.e., license renewal applications submitted later than 1 year after publication must be compliant with the new rule). Nevertheless, under NEPA, the NRC must now consider and analyze, in its license renewal Supplemental Environmental Impact Statement (SEIS), the potential significant impacts described by the final rules new Category 2 issues, and to the extent there is any new and significant information, the potential significant impacts described by the final rules new Category 1 issues.
In addition, on September 19, 2014, the NRC published a revised rule at 10 CFR 51.23 (Continued Storage Rule) and associated generic environmental impact statement for continued storage of spent nuclear fuel. The NRC staff has also separately addressed in this SEIS, under the uranium fuel cycle, the impacts from the Continued Storage Rule.
Upon acceptance of FENOCs application, the NRC staff began the environmental review process described in 10 CFR Part 51 by publishing a Notice of Intent, in the Federal Register, to prepare a supplemental environmental impact statement (SEIS) and conduct scoping. In preparation of this SEIS for Davis-Besse, the NRC staff performed the following:
conducted public scoping meetings on November 4, 2010, in Port Clinton, Ohio; conducted a site audit at the plant in March 8-10, 2011; reviewed FENOCs Environmental Report (ER) and compared it to the GEIS; xvii
Executive Summary consulted with Federal, state, and local agencies; conducted a review of the issues following the guidance set forth in NUREG-1555, Standard Review Plans for Environmental Reviews for Nuclear Power Plants, Supplement 1: Operating License Renewal; considered public comments received during the scoping process; issued the draft SEIS for comment; conducted public meetings to receive comments on the draft SEIS on March 25, 2014; and considered the public comments received during the draft SEIS comment period.
PROPOSED ACTION FENOC initiated the proposed Federal actionissuing a renewed power reactor operating licenseby submitting an application for the license renewal of Davis-Besse, for which the existing license (NPF-003) will expire on April 22, 2017. The NRCs Federal action is the decision whether or not to renew the license for an additional 20 years (April 22, 2037).
PURPOSE AND NEED FOR ACTION The purpose and need for the proposed action (issuance of a renewed license) is to provide an option that allows for 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 decisionmakers, such as state, utility, and, where authorized, Federal (other than NRC). This definition of purpose and need reflects the NRCs recognition that, unless there are findings in the safety review required by the Atomic Energy Act (AEA) or findings in the National Environmental Policy Act (NEPA) environmental analysis that would lead the NRC to reject a license renewal application (LRA), the NRC does not have a role in the energy-planning decisions of whether a particular nuclear power plant should continue to operate.
If the renewed license is issued, the appropriate energy-planning decisionmakers, along with FENOC, will ultimately decide if the plant will continue to operate based on factors such as the need for power. If the operating license is not renewed, then the facility must be shut down on or before the expiration date of the current operating licenseApril 22, 2017.
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Executive Summary ENVIRONMENTAL IMPACTS OF LICENSE RENEWAL The SEIS evaluates the potential environmental impacts of the proposed action. The environmental impacts from the proposed action are designated as SMALL, MODERATE, or LARGE. As set forth in the GEIS, Category 1 issues are those that meet all of the following criteria:
The environmental impacts associated with the issue SMALL: Environmental are determined to apply either to all plants or, for some effects are not detectable or issues, to plants having a specific type of cooling are so minor that they will neither destabilize nor system or other specified plant or site characteristics. noticeably alter any important A single significance level (i.e., SMALL, MODERATE, attribute of the resource.
or LARGE) has been assigned to the impacts, except MODERATE: Environmental for collective offsite radiological impacts from the fuel effects are sufficient to alter noticeably, but not to cycle and from high-level waste and spent fuel destabilize, important disposal. attributes of the resource.
Mitigation of adverse impacts associated with the LARGE: Environmental issue is considered in the analysis, and it has been effects are clearly noticeable and are sufficient to determined that additional plant-specific mitigation destabilize important attributes measures are likely not to be sufficiently beneficial to of the resource.
warrant implementation.
For Category 1 issues, no additional site-specific analysis is required in this SEIS unless new and significant information is identified. Chapter 4 of this report presents the process for identifying new and significant information. Site-specific issues (Category 2) are those that do not meet one or more of the criterion for Category 1 issues; therefore, an additional site-specific review for these non-generic issues is required, and the results are documented in this SEIS.
FENOC submitted its ER under NRCs 1996 rule governing license renewal environmental reviews (61 FR 28467, June 5, 1996, as amended), as codified in NRCs environmental protection regulation, 10 CFR 51. The 1996 GEIS and Addendum 1 to the GEIS provided the technical basis for the list of NEPA issues and associated environmental impact findings for license renewal contained in Table B-1 in Appendix B to 40 Subpart A of 10 CFR Part 51. For Davis-Besse, the NRC staff initiated its environmental review in accordance with the 1996 rule and GEIS and documented its findings in Chapter 4 of this SEIS.
Under NEPA, the NRC must now consider and analyze in this SEIS the potential significant impacts described by the 2013 rules new Category 2 issues, and to the extent there is any new and significant information, the potential significant impacts described by the 2013 rules new Category 1 issues.
The new Category 1 issues include geology and soils, exposure of terrestrial organisms to radionuclides, exposure of aquatic organisms to radionuclides, human health impact from chemicals, and physical occupational hazards. Radionuclides released to groundwater, effects on terrestrial resources (non-cooling system impacts), minority and low-income populations (i.e., environmental justice), and cumulative impacts were added as new Category 2 issues.
These issues are described in Chapter 4 of this SEIS.
The NRC staff did not identify any new issues applicable to Davis-Besse that have a significant environmental impact. The NRC staff, therefore, relies upon the conclusions of the 1996 and 2013 GEIS for all Category 1 issues applicable to Davis-Besse.
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Executive Summary Table ES-1 summarizes the Category 2 issues applicable to Davis-Besse, as well as the NRC staffs findings related to those issues. If the NRC staff determined that there were no Category 2 issues applicable for a particular resource area, the findings of the GEIS, as documented in Appendix B to Subpart A of 10 CFR Part 51, stand. Hereafter in this SEIS, general references to the GEIS, without stipulation, are inclusive of the 1996 GEIS. Information and findings specific to the June 2013, final rule and GEIS, are identified as such.
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Executive Summary Table ES-1. Summary of NRC Conclusions Relating to Site-Specific Impact of License Renewal Resource Area Relevant Category 2 Issues Impacts Land use NONE SMALL Air quality NONE SMALL (a)
Geology and soils NONE SMALL Surface water resources NONE SMALL Radionuclides released to Groundwater resources (a) SMALL groundwater Aquatic resources NONE SMALL Effects on terrestrial resources (non-Terrestrial resources (a) SMALL cooling system impacts)
No effect/ may affect, but is not Protected species Threatened or endangered species likely to adversely (b) affect Electromagnetic fields-acute effects Human health SMALL (electric shock)
Housing Impacts SMALL Public services (public utilities) SMALL Offsite land use SMALL Socioeconomics Public services (public transportation) SMALL Historic and archaeological resources SMALL to MODERATE (a)
Surface water resources SMALL to Cumulative Impacts MODERATE (a)
Aquatic resources LARGE (a)
Terrestrial resources MODERATE Human health-microbiological (a) MODERATE organisms (a)
All other evaluated resources SMALL (a)
These issues are new Category 2 issues identified in the 2013 GEIS and Rule (78 FR 37282). U.S. Nuclear Regulatory Commission. Revisions to Environmental Review for Renewal of Nuclear Power Plant Operating Licenses. June 2013.
(b)
For Federally protected species, the 2013 GEIS and rule state that, in complying with the Endangered Species Act (ESA), the NRC will report the effects of continued operations and refurbishment in terms of its ESA findings, which varies by species for Davis-Besse.
Source: Table B-1 in Appendix B, Subpart A, to 10 CFR Part 51 (NRC 1996, 61 FR 28467), unless otherwise specified xxi
Executive Summary With respect to environmental justice, the NRC staff determined that there would be no disproportionately high and adverse impacts to these populations from the continued operation of Davis-Besse during the license renewal period. Additionally, the NRC staff determined that no disproportionately high and adverse human health impacts would be expected in special pathway receptor populations in the region as a result of subsistence consumption of water, local food, fish, and wildlife.
SEVERE ACCIDENT MITIGATION ALTERNATIVES Since FENOC had not previously considered alternatives to reduce the likelihood or potential consequences of a variety of highly uncommon, but potentially serious, accidents at Davis-Besse, NRC regulation 10 CFR 51.53(c)(3)(ii)(L) requires that FENOC evaluate severe accident mitigation alternatives (SAMAs) in the course of the license renewal review. SAMAs are potential ways to reduce the risk or potential impacts of uncommon, but potentially severe, accidents and may include changes to plant components, systems, procedures, and training.
The NRC staff reviewed the ERs evaluation of potential SAMAs. Based on the staffs review, the NRC staff concluded that none of the potentially cost-beneficial SAMAs relate to adequately managing the effects of aging during the period of extended operation. Therefore, they need not be implemented as part of the license renewal, pursuant to 10 CFR Part 54.
ALTERNATIVES The NRC staff considered the environmental impacts associated with alternatives to license renewal. These alternatives include other methods of power generation and not renewing the Davis-Besse operating license (the no-action alternative). Replacement power options considered were as follows:
natural-gas-fired combined-cycle (NGCC),
combination alternative (wind, solar, NGCC, and compressed air energy storage), and coal-fired power.
The NRC staff initially considered a number of additional alternatives for analysis as alternatives to license renewal of Davis-Besse; however, these were later dismissed due to technical, resource availability, or commercial limitations that currently exist and that the NRC staff believes are likely to continue to exist when the existing Davis-Besse license expires in 2017.
The no-action alternative by the NRC staff, and the effects it would have, were also considered.
Where possible, the NRC staff evaluated potential environmental impacts for these alternatives located both at the Davis-Besse site and at some other unspecified alternate location.
Alternatives considered but dismissed were as follows:
wind power, wind power with compressed air energy storage, solar power, solar power with compressed air energy storage, wood waste, conventional hydroelectric power, ocean wave and current energy, xxii
Executive Summary geothermal power, municipal solid waste (MSW),
biofuels, oil-fired power, fuel cells, energy conservation and energy efficiency, and purchased power.
The NRC staff evaluated each alternative using the same impact areas that were used in evaluating impacts from license renewal.
RECOMMENDATION The NRCs recommendation is that the adverse environmental impacts of license renewal for Davis-Besse are not so great that preserving the option of license renewal for energy-planning decisionmakers would be unreasonable. This recommendation is based on the following:
analysis and findings in the GEIS; ER submitted by FENOC; consultation with Federal, State, and local agencies; NRC staffs own independent review; consideration of public comments received during the scoping process; and consideration of public comments received during the draft SEIS comment period.
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ABBREVIATIONS AND ACRONYMS
µCi/g microcurie(s) per gram AADT annual average daily traffic AEC Atomic Energy Commission ALARA as low as is reasonably achievable AQCR Air Quality Control Region BSBO Black Swamp Bird Observatory Btu British thermal unit(s)
C Celsius CAA Clean Air Act, as amended through 1990 CDF core damage frequency CEQ Council on Environmental Quality CET containment event tree CFR Code of Federal Regulations cfs cubic foot/feet per second CO carbon monoxide CO2 carbon dioxide CO2e carbon dioxide equivalent(s)
CWA Clean Water Act CWS circulating water system DAPC Division of Air Pollution Control Davis-Besse Davis-Besse Nuclear Power Station DAW dry active waste DSM demand-side management EFH essential fish habitat EIA Energy Information Administration EPCRA Emergency Planning and Community Right-to-Know Act of 1986 EPRI Electric Power Research Institute ER Environmental Report ERM Environmental Resources Management ESA Endangered Species Act F Fahrenheit FBC fluidized-bed-combustion FE FirstEnergy Corporation xxv
Abbreviations and Acronyms FENGenCo FirstEnergy Nuclear Generation Corp.
FENOC FirstEnergy Nuclear Operating Company FERC Federal Energy Regulatory Commission FES final environmental statement fps foot/feet per second 3
ft cubic foot/feet FWS U.S. Fish and Wildlife Service gal gallon(s)
GEIS generic environmental impact statement GHG greenhouse gas GLWQA Great Lakes Water Quality Agreement gpd gallon(s) per day gpm gallon(s) per minute GWP global warming potential IGCC integrated gasification combined cycle IJC International Joint Commission IPA integrated plant assessment ISFSI independent spent fuel storage installation kV kilovolt(s) kWh kilowatt-hour(s)
LaMP lakewide management plan LAMP Lakewide Management Plan lb pound(s) lb/MMBtu pound(s) per million British thermal units LOS level(s) of service LLRWSF low-level radioactive waste storage facility 3
m cubic meter(s) mA milliampere(s)
MAAP Modular Accident Analysis Program MACCS2 MELCOR Accident Consequence Code System MBTA Migratory Bird Treaty Act MDC minimum detection concentration mg/l milligram(s) per liter mgd million gallons per day MM million xxvi
Abbreviations and Acronyms MMBtu million British thermal units MSW municipal solid waste MW megawatt(s)
MWd/MTU megawatt-day(s) per metric ton uranium MWe megawatt(s)-electric MWh megawatt-hour(s)
MWt megawatt(s)-thermal NAAQS national ambient air quality standards NCDC National Climatic Data Center NEI Nuclear Energy Institute NEPA National Environmental Policy Act NESC National Electrical Safety Code NGCC natural gas-fired combined cycle NMFS National Marine Fisheries Service NOAA National Oceanic and Atmospheric Administration NOx nitrogen oxide(s)
NO2 nitrogen dioxide NPDES national pollutant discharge elimination system NRC Nuclear Regulatory Commission NRCS Natural Resources Conservation Service NRHP National Register of Historic Places NRR Office of Nuclear Reactor Regulation O3 ozone OAC Ohio Administrative Code OCMP Ohio Coastal Management Program ODCM offsite dose calculation manual ODNR Ohio Department of Natural Resources OEPA Ohio Environmental Protection Agency OHPO Ohio Historic Preservation Office ONWR Ottawa National Wildlife Refuge OPSB Ohio Power Siting Board Pb lead PCBs polychlorinated biphenyls PCDD polychlorinated dibenzo-p-dioxin PCDF polychlorinated dibenzofuran xxvii
Abbreviations and Acronyms pCi/L picocurie(s) per liter PDS plant damage state PEIS programmatic environment impact statement PM particulate matter PM10 particulates with diameters less than 10 microns PM2.5 particulates with diameters less than 2.5 microns ppb part(s) per billion ppm part(s) per million ppt part(s) per thousand PRA probabilistic risk assessment PSD prevention of significant deterioration psig pound(s) per square inch, gauge PWR pressurized water reactor RC release category RCRA Resource Conservation and Recovery Act of 1976, as amended RCS reactor coolant system REC renewable energy credits rms root mean square ROW right of way RPS renewable portfolio standards SAMA severe accident mitigation alternative scf standard cubic foot/feet SEIS supplemental environmental impact statement SHPO State Historic Preservation Officer SO2 sulfur dioxide SOx sulfur oxide(s)
S.U. standard unit(s)
SWS service water system TRC total residual chlorine TRO total residual oxidant USACE U.S. Army Corps of Engineers USAR updated safety analysis report USCB U.S. Census Bureau USDOD U.S. Department of Defense USDOE U.S. Department of Energy xxviii
Abbreviations and Acronyms USEPA U.S. Environmental Protection Agency USGCRP U.S. Global Change Research Program USGS U.S. Geological Survey USOSHA U.S. Occupational Safety and Health Administration wt% percent by weight yr year xxix
APPENDIX A COMMENTS RECEIVED ON THE ENVIRONMENTAL REVIEW
A.COMMENTS RECEIVED ON THE ENVIRONMENTAL REVIEW A.1 Comments Received During Scoping The scoping process began on October 28, 2010, with the publication of the U.S. Nuclear Regulatory Commissions (NRC) notice of intent to conduct scoping in the Federal Register (75 FR 66399). As part of the scoping process, NRC held two public meetings at Camp Perry Lodging and Conference Center, Port Clinton, OH, on November 4, 2010. Approximately 40 members of the public attended the meetings. After the NRC staff presented prepared statements pertaining to the license renewal and the scoping process, the meetings were opened to the for public for their comments. Attendees provided oral statements that were recorded and transcribed by a certified court reporter. Transcripts of the entire meeting are attached at the end of this appendix. In addition to the comments received during the public meetings, comments were received through the mail and e-mail.
Each commenter was given a unique identifier so that every comment could be traced back to its author. Table A-1 identifies the individuals who provided comments applicable to the environmental review and the commenter ID associated with each persons set of comments.
The individuals are listed in the order in which they spoke at the public meeting, then at the peoples hearing, then at the Sierra Club meeting, and in random order for the comments received by letter or e-mail. The submitter of the two videos provided the NRC with a transcribed version of one of their meetings. In order to respond to comments, the other meeting was transcribed by the Environmental Project Manager. The video transcribed by the Project Manger remains the submitted comments. To maintain consistency with the scoping summary report, the unique identifier used in that report for each set of comments is retained in this appendix.
Specific comments were categorized and consolidated by topic. Comments with similar specific objectives were combined to capture the common essential issues raised by participants.
Comments fall into one of the following general groups:
Specific comments that address environmental issues within the purview of the NRC environmental regulations related to license renewal. These comments address the Category 1 (generic) or Category 2 (site-specific) issues identified in NUREG-1437, Generic Environmental Impact Statement for License Renewal of Nuclear Plants (GEIS), or issues not addressed in the GEIS. The comments also address alternatives to license renewal and related Federal actions. There are also comments that do not identify new information for the NRC to analyze as part of its environmental review.
There are comments that address issues that do not to fall within or are specifically excluded from the purview of NRC environmental regulations related to license renewal. These comments typically address issues such as the need for power, emergency preparedness, security, current operational safety issues, and safety issues related to operation during the renewal period.
A-1
Appendix A Table A-1. Commenters on the Scope of the Environmental Review Each commenter is identified along with their affiliation and how their comment was submitted.
ADAMS Accession Commenter Affiliation (If Stated) ID Comment Source Number Afternoon scoping ML110140231 President of the Ottawa meeting Mark Stahl 1 County Commissioners Evening scoping ML110140232 meeting Afternoon scoping ML110140231 County Administrator Ottawa meeting Jere Witt 2 County Evening scoping ML110140232 meeting Director of the Emergency Afternoon scoping Fred Petersen Management Agency Ottawa 3 ML110140231 meeting County Afternoon scoping Director, United Way Ottawa ML110140231 Chris Galvin 4 meeting County Meeting notes ML110680510 Office and Professional Afternoon scoping Jackie VanTress Employees International 5 ML110140231 meeting Union (OPEIU) Local 19 Executive Director, Black Afternoon scoping Kimberly Kaufman 6 ML110140231 Swamp Bird Observatory meeting Representative Afternoon scoping Steve Inchak 7 ML110140231 Congressman Kucinich meeting Director, American Red Afternoon scoping Beth Leggett 8 ML110140231 Cross Ottawa County meeting International Brotherhood of Afternoon scoping Brad Goetz Electrical Workers Local 9 ML110140231 meeting 1413 Food Coordinator, Afternoon scoping Ann Heckerd St. Vincent DePaul Food 10 ML110140231 meeting Pantry Afternoon scoping ML110140231 meeting Brian Boles Plant Manager, Davis-Besse 11 Evening scoping ML110140232 meeting International Brotherhood of Afternoon scoping Larry Tscherne 12 ML110140231 Electrical Workers meeting Deputy Director, Ottawa Evening scoping Mike Drusbacky 13 ML110140232 County meeting Evening scoping ML110140232 meeting Joseph DeMare Ohio Green Party 14 Peoples hearing ML11348A017 Meeting notes ML110680517 A-2
Appendix A ADAMS Accession Commenter Affiliation (If Stated) ID Comment Source Number Evening scoping President, OPEIU Local 19 ML110140232 Jane Ridenour 15 meeting Meeting notes ML110680512 Evening scoping ML110140232 meeting Chair, Nuclear Issues Sierra Club meeting ML11348A013 Patricia Marida 16 Committee Sierra Club Letter ML103370043 Letter ML110680515 Evening scoping Matthew Heyrman 17 ML110140232 meeting Anita Rios Ohio Green Party 18 Peoples hearing ML11348A017 Kevin Kamps Beyond Nuclear 19 Peoples hearing ML11348A017 Professor, University of Al Compaan 20 Peoples hearing ML11348A017 Toledo Katie Hoepfl Student, University of Toledo 21 Peoples hearing ML11348A017 Tony Szilagye 22 Peoples hearing ML11348A017 Ed McArdle Sierra Club of Michigan 23 Peoples hearing ML11348A017 Phyllis Oster 24 Peoples hearing ML11348A017 Dave Ellison 25 Peoples hearing ML11348A017 Coalition for a Nuclear Free ML11348A017 Michael Keegan Great Lakes 26 Peoples hearing Dont Waste Michigan Ralph Semrock Associate Professor, Owens 27 Peoples hearing ML11348A017 Mike Leonardi 28 Peoples hearing ML11348A017 Unidentifiable Woman 29 Peoples hearing ML11348A017 Peoples hearing ML11348A017 Eric Britton 30 E-mail ML110680350 Suzanne Patser 31 Sierra Club meeting ML11348A013 James Whitaker 32 Sierra Club meeting ML11348A013 Scott Robinson 33 Sierra Club meeting ML11348A013 Sierra Club meeting Simone Morgan Sierra Club 34 E-mail ML110680350 Emily Journey 35 Sierra Club meeting ML11348A013 Bob Patraicus 36 Sierra Club meeting ML11348A013 Kevin Malcolm 37 Sierra Club meeting ML11348A013 Doug Todd 38 Sierra Club meeting ML11348A013 A-3
Appendix A ADAMS Accession Commenter Affiliation (If Stated) ID Comment Source Number Sierra Club meeting ML11348A013 Connie Hammond Sierra Club 39 E-mail ML110680350 Bernadine Kent 40 Sierra Club meeting ML11348A013 Unknown 41 Sierra Club meeting ML11348A013 Pete Johnson 42 Sierra Club meeting ML11348A013 Connie Gadwell- Sierra Club meeting ML11348A013 Ohio Green Party 43 Newton E-mail ML110680350 E-mail ML103430609 Lee Blackburn Sierra Club 44 E-mail ML110680350 Field Supervisor, U.S. Fish Mary Knapp 45 Letter ML110060289 and Wildlife Service Chief, Peoria Tribe of Indians John P. Froman 46 Letter ML103570365 of Oklahoma Member of Congress, 10th Dennis Kucinich District Ohio House of 47 Letter ML110680518 Representatives Marilyn & Paul 48 E-mail ML110680519 Nesser Jessica Lillian 49 E-mail ML110680520 Weinberg Erika Agner Sierra Club 50 E-mail ML110680350 Christian George Sierra Club 51 E-mail ML110680350 Amanda Baldino Sierra Club 52 E-mail ML110680451 Inez George Sierra Club 53 E-mail ML110680530 Leeza Perry Sierra Club 54 E-mail ML110680350 Jeremy Bantz Sierra Club 55 E-mail ML110680350 David Greene Sierra Club 56 E-mail ML110680537 Jean Puchstein Sierra Club 57 E-mail ML110680350 Sandy Bihn Sierra Club 58 E-mail ML110680350 Bob Greenbaum Sierra Club 59 E-mail ML110680350 Carol Rainey Sierra Club 60 E-mail ML110680350 Leonard Bildstein Sierra Club 61 E-mail ML110680455 Cate Renner Sierra Club 62 E-mail ML11116A124 Karen Hansen Sierra Club 63 E-mail ML110680529 Natalie Schafrath Sierra Club 64 E-mail ML110680532 Kathleen Bodnar Sierra Club 65 E-mail ML110680350 Margaret Holfinger Sierra Club 66 E-mail ML110680350 A-4
Appendix A ADAMS Accession Commenter Affiliation (If Stated) ID Comment Source Number Ben Shapiro Sierra Club 67 E-mail ML110680350 Susan Jones Sierra Club 68 E-mail ML110680453 Leslie Stansbery Sierra Club 69 E-mail ML110680528 Stephen & Connie Sierra Club 70 E-mail ML110680525 Caruso Robert Kyle Sierra Club 71 E-mail ML110680350 Andy Trokan Sierra Club 72 E-mail ML110680350 Joan DeLauro Sierra Club 73 E-mail ML110680350 Joan Lang Sierra Club 74 E-mail ML110680452 Jim Wagner Sierra Club 75 E-mail ML110680350 June Douglas Sierra Club 76 E-mail ML110680350 Tekla Lewin Sierra Club 77 E-mail ML110680539 Tim Wagner Sierra Club 78 E-mail ML110680350 Virginia Douglas Sierra Club 79 E-mail ML110680350 Mary Beth Lohse Sierra Club 80 E-mail ML110680350 E-mail ML110680449 George M. Williams Sierra Club 81 E-mail ML110680454 Donna Emig Sierra Club 82 E-mail ML110680350 Liz Loring Sierra Club 83 E-mail ML110680350 Lance Wilson Sierra Club 84 E-mail ML110680350 Mike Fremont Sierra Club 85 E-mail ML110680523 Nick Mellis Sierra Club 86 E-mail ML110680350 Paul Wojoski Sierra Club 87 E-mail ML110680350 Linda Milligan Sierra Club 88 E-mail ML110680350 Elisa Young Sierra Club 89 E-mail ML110680350 Matt Trokan Sierra Club 90 E-mail ML110680350 In order to evaluate the comments, the NRC staff gave each comment a unique identification code that categorizes the comment by technical issue and allows each comment or set of comments to be traced back to the commenter and original source (transcript, video recording, letter, or e-mail) from which the comments were submitted.
Comments were placed into one of 17 technical issue categories, which are based on the topics that will be contained within the staffs supplemental environmental impact statement (SEIS) for Davis-Besse, as outlined by the GEIS. These technical issue categories and their abbreviation codes are presented in Table A-2.
A-5
Appendix A Table A-2. Technical Issue Categories Comments were divided into one of the 17 categories below, each of which has a unique abbreviation code.
Code Technical Issue AL Alternative energy sources AM Air & meteorology AQ Aquatic resources (a)
CI Cumulative impacts CR Cultural resources HH Human health HY Hydrology LR License renewal & its process (a)
LU Land use (a)
NO Noise OL Opposition to license renewal (b)
OS Outside of scope PA Postulated accidents & SAMA RW Radioactive & non-radioactive waste SE Socioeconomics SL Support of license renewal TR Terrestrial resources (a)
No comments specific to the categories of cumulative impacts, land use, or noise were submitted during the Davis-Besse scoping period.
(b)
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; terrorism; and spent nuclear fuel storage and disposal.
Comments received during scoping applicable to this environmental review are presented in this section along with the NRC response. They are presented in the order shown in Table A-3.
The comments that are outside the scope of the environmental review for Davis-Besse are not included here but can be found in the scoping summary report, which can be accessed through the Agencywide Documents Access and Management System (ADAMS), Accession No. ML11168A197.
A-6
Appendix A Table A-3. Comment Response Location in Order of Resource Area Comment Category Page Alternative Energy Sources (AL) 7 Air & Meteorology (AM) 19 Aquatic Resources (AQ) 20 Cultural Resources (CR) 23 Human Health (HH) 23 Hydrology (HY) 29 License Renewal and its Process (LR) 32 Opposition to License Renewal (OL) 37 Postulated Accidents & SAMA (PA) 42 Radioactive & Non-Radioactive Waste (RW) 43 Socioeconomics (SE) 47 Support of License Renewal (SL) 50 Terrestrial Resources (TR) 51 A.1.1 Alternative Energy Sources (AL)
Comment: 5-2-AL; Research has shown that nuclear power is clean, is efficient and produces more energy at a lower cost than any other means of generation. So, it is important that we keep this plant in operation.
Comment: 11-1-AL; Its a priority for us as a company because Davis-Besse is a significant asset to our company. It provides a large source of safe, reliable, environmental friendly electricity to the surrounding area.
Comment: 12-3-AL; By extending the license here at Davis-Besse, it would continue to provide good clean power thats critical.
Comment: 15-3-AL, 15-7-AL; Research has shown that nuclear power is clean, it is efficient and it produces more energy at a lower cost than any other means of generation. So, it is important that we keep this plant in operation.
Response: These comments are generally supportive of nuclear power, citing the cleanliness, efficiency and the cost of electricity. The discussion of alternatives, including license renewal, are presented in Chapter 8. No new and significant information was found as a result of these scoping comments and further evaluation was not considered in the development of the SEIS.
Comment: 16-6-AL; In Ohio, the use of electricity has been increasing for a number of years.
Now, with progressive legislation and Ohio Senate Bill 221, energy efficiency and conservation combined with the renewable sources of solar, wind and geothermal, these are providing so much additional and conserve energy to all plants and new coal plants in our state have been cancelled, and theres a strong movement to shut down the old polluting coal-fired plants.
A-7
Appendix A Comment: 16-27-AL; In Ohio, the use of electricity has been decreasing for a number of years.
Now with progressive legislation like Ohios SB 221, energy efficiency and conservation, combined with the renewable sources of solar, wind, and geothermal, are providing so much additional and conserved energy that all plans for new coal plants in our state have been cancelled and there is a strong movement to shut down the old polluting coal-fired plants. The argument of US rising energy needs is irrational at best and at worst the resulting global warming would threaten our life-support system, and yes, our way of life.
Comment: 20-1-AL; One of the things that I think is important to keep in mind is that First Energy and Davis-Besse provides about 8.3% of First Energys baseload power generation, so thats important to recognize in terms of the alternatives. Now, in Ohio, Senate bill 221, which was passed in the spring of 2008, mandates for the investor-owned utilities that they should, achieve a higher efficiency by reducing demand by 2025 by 22%, a much larger number than the 8.3%, generation thats provided by Davis-Besse. And in addition, achieve 12 1/2% generation from renewals by 2025 and another 12 1/2% generation from so-called advanced energy, which may include new, new advanced nuclear, but continuation of Davis-Besse would not qualify for that additional gen..., for that 12 1/2%. Distributed generation will also qualify for a, a credit under the Senate bill 221. And alternative sources are very attractive for...wind, as Kevin mentioned, and also solar.
Comment: 20-7-AL; It may be done by advanced nuclear, and thats requiring NRC Generation III. Davis-Besse, I believe, is Generation II technology, but Generation III incorporates a passive safety systems. So even if the power goes out, such as when the tornado came through and disconnected the power plant from its emergency diesel generators, there would be passive safety equipment in the Gen-II, Gen-III design. And the Gen-III design would be for 60 years of operation instead of 40 years.
Comment: 22-9-AL; Here are a few suggestions. In the year 2021, Senate bill 221 will eliminate or generate as much power as Davis-Besse produces. If First Energy takes seriously the opportunities available for generating power through energy efficiency and making agreements for a better payoff for exceeding the energy efficiency targets the Senate bill 221 mandates, they can be more profitable without Davis-Besse. If they take an aggressive look at the potential of combined heat and power, wind, compressed air storage, solar, they can generate either through efficiency or through greater uses of existing resources, the needed capacity that the loss of Davis-Besse will create. There are solution for generating capacity.
For every one cent invested in elec...in energy efficiency, three cents profit is gained. the solutions and incentives...alternative to the continuation of nuclear power to the elimination of nuclear power are already out there.
Response: The comments are in general support of alternative energy production sources and reference The Ohio Senate Bill 221 as legislative support for renewable energy sources. The comments also represent a general opposition to nuclear energy.
The Ohio Senate Bill (Am. Sub. S. B. No. 221) passed through the Ohio House of Representatives on Tuesday, April 22, 2008, and it passed through the Ohio Senate on Wednesday April 23, 2008, the effective date of the bill was July 31, 2008.
The bill focuses on energy pricing and sources. The pricing of electricity is outside the scope of the environmental review and is not discussed further in the SEIS. According to the bill analysis published by the Ohio Legislative Service Commission, the primary points of the bill, as it relates to energy sources, are as follows:
requires an electric distribution utility and an electric services company to provide a portion of their electricity supplies from alternative energy resources A-8
Appendix A defines alternative energy resources as consisting of specified advanced energy resources and renewable energy resources with a placed-in-service date of January 1, 1998, or later, and as consisting of existing or new mercantile customer-sited resources specifies that the requisite portion of the electric supply derived from alternative energy sources must equal 25 percent of the total number of kilowatt hours of electricity sold by the utility or company to any and all retail electric consumers whose electric load centers are served by the utility and are located within the utilitys certified territory or, in the case of an electric services company, are served by the company and are located within Ohio provides that half of the alternative energy can be generated from advanced energy resources, but at least half must be generated from renewable energy resources, including 0.5 percent from solar energy resources, subject to yearly, minimum, renewable and solar benchmarks that increase as a percentage of electric supply through 2024 authorizes the Public Utilities Commission of Ohio (PUCO) to enforce the renewable energy and solar energy resource benchmarks through the assessment of compliance payments prescribes energy savings and peak demand reduction requirements for electric distribution utilities through 2025, sets yearly benchmarks, and authorizes PUCO enforcement of compliance through the assessment of forfeitures authorizes the PUCO to approve a revenue decoupling mechanism for an electric distribution utility if it reasonably aligns the interests of the utility and of its customers in favor of energy efficiency or energy conservation programs requires the PUCO, to the extent permitted by Federal law, to adopt rules establishing greenhouse gas (GHG) emissions reporting and carbon dioxide control planning requirements for each electric generating facility located in Ohio that is owned or operated by a public utility that is subject to PUCO jurisdiction and that emits GHGs, including facilities in operation on the acts effective date The NRC staff is aware of Senate Bill 221 and incorporated information about the legislation into its own alternatives analysis. State regulatory agencies and FirstEnergy Nuclear Operating Company (FENOC) will ultimately decide whether the plant will continue to operate based on factors such as the need for power or other matters within the States jurisdiction or the purview of the owners. Alternatives are discussed in Chapter 8, Alternatives, of this SEIS; they include conservation (demand-side management) and renewable energy sources such as wind and solar energy.
Comment: 16-8-AL; There is good reason why there are no nuclear power plants coming on line to replace the old ones. Wall Street will not support them. The normal up-front cost and a 12- to 20-year length of time for completion makes it financially uncompetitive with wind and solar. On the latter, decentralize, meaning that jobs are being created all over the state. As compared to Davis Besses extended shut-downs, if the wind stops blowing or the sun is behind a cloud, somewhere, it is likely not too serious or a long-term power shortage problem.
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Appendix A Comment: 16-20-AL; We are closing down Coal plants now because Ohio is actually using less electricity than they used to. Weve got efficiency weve got solar we have wind we have geothermal we have all kinds of sustainable ways.
Comment: 19-11-AL; And, there was another, license extension, that I wanted to mention, thats being challenged. I brought some things to look at over here, some old posters from Seabrook New Hampshire, in the mid-1970s. you know, fifteen hundred people got arrested on a single day in 1977 trying to block the construction of Seabrook. Well, Seabrook has gone for a 20-year license extension and theyve gone for it 20 years early, incredibly. Theyre only 20 years old. They have 20 more years on their license, and theyve asked for a 20-year license extension. So Paul Gunter, my coworker, has challenged this 20-year early application, and his main challenge is the wind power potential off the gulf of Maine, which is tremendous.
So showing that wind power is a great alternative. And, Ill just close now, by saying that the wind power potential of the Great Lakes is there. That will be one of our contentions against Davis-Besse for 20 more years. And add to that solar potential, with the biggest solar panel manufacturing factory in the country right here in Toledo. Add to that the efficiency potential, and theres no need for 20 more years of radioactive Russian roulette on the Lake Erie shoreline. Thank you Very much.
Comment: 20-6-AL; But we, should also know that there are some very good alternatives for, generating electricity, and one of those normally not thought about as generation, but its energy conservation. And that is now widely accepted as the cheapest way to get more effectively, to get more energy, its to use our energy more, more wisely. And then theres a very strong wind resources and solar resources. So, the important thing that, we need to recognize is that, is that these components, energy conservation, wind and solar, are already mandated by Senate bill 221 in the state of Ohio. And, windmills are, used by the, the publicly-owned, utilities, they are allowed by Ohio law to pass through, to pass those costs on to the customers, so, on to the consumers of the electricity. That, that might not have been my favorite way of doing it, but thats the way, the legislators have decided in the Public Utility Commission of Ohio.
Comment: 20-9-AL; So, lets take a little bit closer look at the resources that are available for wind. Lake Erie and the Lake Erie shore, as well as all of the Great Lakes, are great resources for, for wind energy. So, I, Im showing here this, wind energy map. This is for the average wind power across the United States. And it may be hard to see from there, but, we hear a lot about the, the wind corridor in the Great Midwest, from Texas through to North Dakota. Thats this, region of the Great Plains. But now, the wind, resources in...increase, the average wind power increases as you go from white, actually the key is down here, from white to the light blue to the darker blue and still darker, and you can see that, Ohio, for the most part, has a lot of wind resources that are similar to Texas. We hear about Texas because it has the most wind power of any of the any of the states. And Ohio has similar resources. But if you look at, in Lake Erie and on the near shore and, up to the border with Canada, you can see its a very dark blue, and thats similar to some of these mountain passes here. So wind, resource availability in Lake Erie is really, really prime. much higher than almost any of the places in, in Texas, for example. So thats an indication that there really are tremendous resources out there and wind power is very competitive in terms of, rates for electricity generated by wind power. The big, let me just back up...One of the big issues with Texas, which is now struggling with getting the power, of course they have some major cities, but they can generate more than what can be used in their cities, is how you are going to get the power out to the big metropolitan areas like Chicago and Cleveland and Toledo and so on, and Detroit. That is not a problem when you generate the power in Lake Erie, we have a lot of major metropolitan areas that are very nearby.
Comment: 20-10-AL; For solar, Ohio has, actually very good solar isolation as well. and I want to point out that in this, in this Environmental Report, thats part of the First Energy petition A-10
Appendix A for the renewal, there are some errors in that, in that report. For example, they, they say that the amount of sunlight in Ohio is less than half of what it is in some of the best areas in the country. thats a bit of a, an error and Ill point out why in just a moment. And then, they also used some data for the costs, which came from back in 1988, and the costs for solar photo-voltaic electricity has come down dramatically since 1988. One of the mistakes that is commonly, made when you think about solar, is you think about being able to see a sun, the sun in a clear day. And you think, you think, that, well, its only on those clear days that photo-voltaics will generate usable power. And this is the kind of map that you would use if you were really worried only about direct sunlight, being able to have a clear sky, and being able to see a clear sun out there. And then when you take and you compare Toledo or, or Lake Erie with some areas in the Southwest, and I did the numbers here. actually, for the...for the South.
when you compare Toledo with Orlando, even when you consider only direct sunshine, Toledo gets 75% of what Orlando does, down here in Florida. But its not as good as San Diego, its almost 60% of San Diego, >>>. and if you go out to the Mojave Desert, Toledo gets about 45%.
So thats a number thats consistent with what, First Energy claimed in that report. However, the real data that you need to look at are the, us, the full sky radiation. The point of...Most solar panels are flat panels and they will accept light which is indirect, that is, as it comes scattered in hazy days or light cloudy days and light is scattered from those clouds and still make it to those panels. And so this is the appropriate math that needs to be looked for, the amount of electricity that can be produced by solar panels over the years. So, in that case, if you compared Toledo with Orlando, or Toledo with San Diego, Toledo gets 86% of what, Orlando gets, 79% of what Sand Diego gets. So the argument that the solar resources in Ohio, in Northern Ohio, are not very good, and actually you can see that the best resources here are Western Ohio and in certain...thats an argument that doesnt, work when you address solar. And that last point that Id like to make about solar is that there are huge changes that have been happening in the last several years in terms of the costs of solar panels. And the cost driver on this is actually FirstEnergy, First Solar, sorry, First Solar, which is, started here in Toledo, by Toledo industrialists such as Harold, Harold McMaster, and our only US generating, US manufacturing facility is in Perrysburg.
Comment: 20-12-AL; Energy conservation, retro-fitting of homes and businesses and so with the more energy-efficient lights, and motors, and thermal efficiency saves, saves, save energy for everyone. It reduces the need for, generating capacity. Ohio has a lot of manufactures that supply components for wind turbines. The maintenance of wind turbines generates many jobs.
Ive already mentioned, First Solar is the largest manufacturer in the world. So manufacturing creates jobs. And there are several other PV manufacturers that are beginning, in Ohio, most of them actually in northwest Ohio, in the Toledo area. PV design and insulation creates a num...a large set of jobs.
Comment: 21-2-AL; So what I have done is done some statistical modeling using systems that are already in place here in northwest Ohio. I used one of the wind turbines in Bowling Green, owned by Bowling Green municipalities, and a solar array mounted on the home of Professor Compaan. This model is a little bit confusing. What it is here is on the X axis we have the volatility or the intermittency of the system that FirstEnergy mentioned. So what that means is that at some points throughout the day it can be high, it can be low. Its unexpected, the power production that would be produced. On here [indicating the Y axis] its the actual output of the system. So along our curve here we have an entire wind, only wind system, and at the other end we have only solar. And, along the middle is a combination of the two. what Im going to show you today is that its not a matter of using one or the other. The combination of these different forms of renewable energy thats really going to help us offset the loss of nuclear power by closing Davis-Besse. So over here on the end of the curve is where we have the least volatility in the system. For this specific northwest Ohio that turned out to be about half wind A-11
Appendix A and half solar thats going to produce the best outcome for us. Just an example here of what I mean by this. So in a 100% wind system has a volatility something like this. This is the power production over the course of the week by the Bowling Green wind turbine. you can see its pretty unexpected what its going to produce throughout the day. And on the opposite end, a 100% solar system, follows a pattern, you only get power production during the day, but even throughout the day you not sure if youre going to get a sunny day, cloudy day things like that re unexpected...So, by optimizing the system, using similar rating, say one megawatt wind turbine farm and one megawatt solar array, you get something thats quite a bit more predictable. Now put this here against a demand curve. This is from EBCOT its in Texas, but the demand curve for any big city is gonna look about the same. A lot of high peaks during the afternoon, evening hours and lower at night time when were sleeping. Its quite a bit more predictable, it follows the demand curve. What I want to point out here, though is that my graph is still quite a bit volatile here, but its only taking into consideration two specific sites. We only have one wind turbine and one solar array. But, if FirstEnergy were to take their resources and erect, um sorry, use the wind and solar throughout their entire area that they service. Solar, its not going to be cloudy in all the areas that they service. Thats exactly what the (Go to my summary slide, here)
European Wind Energy Association in their annual report in 2009. They said exactly that. That as wind and solar is developed across the entire area, the volatility in one specific area does not infect the overall baseload that its generating. Thats another thing Id like to point out in FirstEnergys application for Renewal, they kept mentioning that solar and wind are not a good replacement because they cant satisfy a baseload. But, as Dr. Compaan mentioned in his speech, Davis-Besse only produces 8.3% of FirstEnergys baseload. So, were not trying to make these curves fit identical. It just has to back up the coal and everything else thats already being produced. So were using a combination of wind, solar and all the other technologies that are out there. Theyll be able to easily offset the production lost by Davis-Besse.
Comment: 23-4-AL; The second article I refer is the November, 2009 cover story in Scientific American. I bought this issue and bring it with me to almost everything I go to. This article is entitled A Plan for Sustainable Future. How to Get All Energy from Wind, Solar and Water by 2030 using Present Technology. The article by Mark Z. Jacobsen of Stanford University and Mark A. Delucchi of University of California, Davis it is describe by the editors of Scientific American as a pragmatic hard headed study. Supply 100% clean energy by 2030 at the same or lower cost of traditional fossil and nuclear resources. Frankly, Im amazed by this article. This is something, I think, weve been waiting for, and something we should push.
Comment: 25-4-AL; We should come up with energy conservation and efficiency measures that replace that 8.3%. Forget creating any alternative fuels or advanced nuclear. Just energy in energy conservation efficiency alone, we make up for this. The system that requires that we maintain the amount of consumption that we currently have as part of the licensure relicensure application is absurd because so much of the future depends on our reduction of and our conservation and our efficient use of energy. Its absurd to perpetuate the existing system.
Comment: 31-3-AL; There are so many other clean ways to provide energy. Wind Solar geothermal there is no reason to bring a nuclear plant online. There would have to be some other agenda involved we hope that is not military agenda. But we know that we dont the electricity from that plant in this state.
Comment: 35-2-AL; I believe we should be going in different directions when it comes to supplying energy to our communities. Direction that is not destructive that can provide new green jobs. Thank you.
Comment: 36-2-AL; It is located there on the great lakes, the largest clean water source in the world and it seems extremely dangerous and unnecessary A-12
Appendix A Comment: 39-3-AL; We need to invest our money into green technologies that would create job and also help our economy which is leaving the toxic legacy for our children as well as these nuclear power plants.
Comment: 41-1-AL; I wish to join the wave of the future. Which is alternative energy sources.
Fossil fuels and nuclear energy are part of the past.
Comment: 30-4-AL, 34-6-AL, 39-9-AL, 43-7-AL, 44-5-AL, 50-4-AL, 51-4-AL, 53-4-AL, 54-4-AL, 57-4-AL, 58-4-AL, 59-4-AL, 60-4-AL, 62-4-AL, 65-4-AL, 66-4-AL, 67-4-AL, 69-4-AL, 70-4-AL, 71-A-AL, 72-4-AL, 73-4-AL, 74-4-AL, 75-4-AL, 76-4-AL, 77-4-AL, 78-4-AL, 79-4-AL, 80-4-AL, 81-4-AL, 81-9-AL, 82-4-AL, 83-4-AL, 84-4-AL, 85-4-AL, 86-4-AL, 87-4-AL, 88-4-AL, 89-4-AL, 90-4-AL; I do not want Davis-Besse to continue generating electricity and want the Nuclear Regulatory Commission to end the operating license for the plant. I care about the environment and support clean energy solutions such as energy efficiency and renewable power, and I know that Davis-Besse compromises my safety and the safety of my loved ones.
Comment: 55-4-AL; I do not want Davis-Besse to continue generating electricity and want the Nuclear Regulatory Commission to end the operating license for the plant. I care about the environment and support clean energy solutions such as energy efficiency and renewable power, and I know that Davis-Besse compromises my safety and the safety of potentially everyone that lives in the entire Midwest. The risk is unacceptable.
Comment: 52-4-AL; I do not want Davis-Besse to continue generating electricity and want the Nuclear Regulatory Commission to end the operating license for the plant. I care about the environment and support clean energy solutions such as energy efficiency and renewable power, and I know that Davis-Besse compromises my safety and the safety of my loved ones.
This concerns me much.
Comment: 68-4-AL; I do not want Davis-Besse to continue generating electricity and want the Nuclear Regulatory Commission to end the operating license for the plant. I care about the environment and support clean energy solutions such as energy efficiency and renewable power, and I know that Davis-Besse compromises my safety and the safety of my loved ones.
So Please stop the relicense of this very dangerous power plant it is not worth risking the lives of millions of people for energy when there are safer and cheaper options out there.
Comment: 61-4-AL; I do not want Davis-Besse to continue generating electricity and want the Nuclear Regulatory Commission to end the operating license for the plant. I care about the environment and support clean energy solutions such as energy efficiency and renewable power, and I know that Davis-Besse compromises my safety and the safety of my loved ones.
This plant has the worst safety record in the U.S.A. and should be closed! You have no right to continue operating this unsafe plant. We have two coal plants in the area that produce more than enough electricity for this area and are safe!
Comment: 63-4-AL; There have been too many near-disasters at this plant. This, because of its proximity to the Great lakes, is unconscionable! To continue to put resources into this risky plant and to continue to endure the toxic side effects is insane! We should be putting all our energy investments into clean, safe, green alternatives, and that does NOT include nuclear power!
Comment: 64-4-AL; Its high time we step up our efforts to help protect the future generations by doing what we can to ensure a safe environment for species diversity. We cannot live in this world without being connected to the web of life that exists in every ecosystem. The nuclear waste generated from this plant would not only effect ourselves, and our children, but every species that struggles to survive as well. As someone who is SUPPOSE to represent the A-13
Appendix A demands on their constituents I hope it is clear to you that Ohioans DONT AGREE with this form of energy!
Comment: 56-4-AL; The Davis-Besse power plant must stop generating electricity and the Nuclear Regulatory Commission must end the operating license for the plant. In 2002, the Davis-Besse plant nearly melted down almost causing a nuclear disaster. Neither First Energy nor the Nuclear Regulatory Commission discovered an enormous rust hole in the reactor head until it was almost too late! According to the Nuclear Regulatory Commission, 2 of the top 5 most dangerous nuclear incidences since 1979 have happened at Davis-Besse. Nuclear power has too many problems from waste to extreme expense to oversight. This is not an environmentally sound solution. I support clean energy solutions such as energy efficiency and renewable power, and I know that Davis-Besse compromises my safety and the safety of my loved ones. Nuclear power uses and pollutes significant amounts of water, while the mining, transportation, and enriching of uranium is carbon intensive which contributes to global warming.
Comment: 85-4-AL; I do not want Davis Besse to continue generating electricity and want the Nuclear Regulatory Commission to end the operating license for the plant. I care about the environment and support clean energy solutions such as energy efficiency and renewable power, and I know that Davis Besse compromises my safety and the safety of my loved ones.
In the early 80s Cincinnatis Zimmer Nuclear Plant was adjudged, according to the Wall Street Journal, to be the worst-built nuke plant in the U.S., for a number of reasons, one being that much of the crucial reactor steel was bought from a local scrap dealer. It could have ruined the Ohio River downstream from Cincinnati all the way to New Orleans. Davis-Besse could wreck Lake Erie and quite a land area around Toledo. Save us from that! We can do it cheaper, safer and cleaner with windmills in the lake.
Response: These comments relate to the use of renewal sources of energy as an alternative to nuclear power. The NRC staff evaluated reasonable alternatives in Chapter 8, Alternatives.
In this chapter, the staff examines the potential environmental impacts of alternatives to license renewal for Davis-Besse, as well as alternatives that may reduce or avoid adverse environmental impacts from license renewal and when and where these alternatives are applicable.
In evaluating alternatives to license renewal, the NRC staff first selected 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 current Davis-Besse operating license expires in 2017. Second, the NRC staff screened the alternatives to remove those that cannot meet future system needs. Then, the NRC staff screened the remaining options to remove those whose costs or benefits do not justify inclusion in the range of reasonable alternatives. The remaining alternatives, constituted comprise the alternatives to the proposed action that the NRC staff evaluated in-depth in this Chapter 8 of the SEIS. The NRC staff considered 17 energy technology options and alternatives to the proposed action and then narrowed to the three alternatives considered.
The alternatives evaluated in-depth include the following:
natural-gas-fired combined-cycle (NGCC);
combination alternative (wind, solar, NGCC, and compressed air energy storage); and coal-fired power.
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Appendix A Other alternatives considered, but not evaluated further, are listed below:
wind power, wind power with compressed air energy storage, solar power, solar power with compressed air energy storage, wood waste, conventional hydroelectric power, ocean wave and current energy, geothermal power, municipal solid waste (MSW),
biofuels, oil-fired power, fuel cells, energy conservation and energy efficiency, and purchased power.
The NRC staffs alternatives analysis also involved consideration of combinations of alternatives including renewable technologies and conventional baseload technologies, as well as options not involving new generation capacity such as purchased power and conservation measures.
Comment: 20-11-AL; Theyve been, leading the cost reductions. So if you look here, this is a study that was done by Deutsch Bank and updated in 2009. It doesnt go back, to 1998, which is when, when First Energy pulled their numbers, but, you can, you can extrapolate back further if you want. There, it was something on the order of 40 cents/kilowatt-hour for the levelized cost of electricity, as its called. but in 2010, the cost is about 20 centers/kilowatt-hour for cadmium telluride. This is, this is the type of material in the panels that are made by First Solar. Some of the other kinds of solar panels are shown here, a little bit higher in cost. But what Deutsch Bank projected is that theres going to be a crossover, a convergence between the cost of solar-generated electricity, as you go out here to, what is the number, its like 2017 or so, so, 2017, at about the time when, when FirstEnergy wants to extend the license on the plant, solar is going to be, completely competitive, if not lower cost than, the electricity, than the conventional electricity. Notice that Deutsch Bank is using an average over the United States.
Now the cost of electricity in the FirstEnergy territory is actually higher, those of you who live in FirstEnergy territory, your home costs, your home electricity costs are something like 12 or 12 1/2 cents/kilowatt-hour, so the curve for us should really start a little bit higher, and that convergence will happen even sooner. So First Energy has the option of extending, a nuclear generating plant with all of its associated dangers and also its costs. The cost of nuclear generated power is high, higher than most of the baseload, generating capacity of FirstEnergy.
And its costs is continuing to increase. The alternative is to jump on some of the new technology, jump on those bandwagons, and those costs are decreasing. So thats the kind of options that FirstEnergy has, and youd think that if they really look at it seriously and look at the options that they ought to conclude, that some of these alternative forms of electricity are the ones that ought to be, the ones, that are developed for the long-term future of their, of their company. So, just to make one final point, and that is alternative, alternative energy resources generate lots of jobs. They actually generate, many more jobs than what nuclear power does.
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Appendix A Comment: 16-28-AL; There is good reason why there are no new nuclear power plants coming online to replace the old ones. Wall Street will not support them. The enormous up-front costs and 12-20 year length of time for completion makes them financially uncompetitive with wind and solar. And the latter are decentralized, meaning that jobs are being created all over the state. As compared to Davis Besses extended shutdowns, if the wind stops blowing or the sun is behind a cloud somewhere, there is likely not to be a serious or long-term power shortage problem.
Response: These comments oppose nuclear power based on the costs associated with construction and operation when compared to other alternative sources of power. The regulatory authority over licensee economics falls within the jurisdiction of the states and, to some extent, the Federal Energy Regulatory Commission (FERC). The proposed rule for license renewal included a cost-benefit analysis and consideration of licensee economics as part of the National Environmental Policy Act (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 GEIS. They noted that the Presidents 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 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 GEIS as follows:
The purpose and need for the proposed action (renewal of an operating license) is to provide an option that allows for power generation capability beyond the term of a current nuclear power plant operating license to meet future system generating needs, as such needs may be determined by state, licensee, and, where authorized, Federal (other than NRC) decisionmakers.
Title 10 of the Code of Federal Regulations, Section 51.95(c)(2) (10 CFR 51.95(c)(2)) states the following:
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 NRC staff identified feasible technologies in the GElS, and the staff will use information in the GEIS, updating it as necessary to reflect recent technological advancements, as the basis for its alternative analysis. Since 1996, many energy technologies have evolved significantly in capability and cost, while regulatory structures have changed to either promote or impede development of particular alternatives, of this SEIS.
As a result, the analyses include updated information from the following sources:
Energy Information Administration (EIA),
other offices within the Department of Energy (DOE),
U.S. Environmental Protection Agency (EPA),
industry sources and publications, and information submitted by the applicant in the FENOC Environmental Report (ER).
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Appendix A The result of this analysis provided for three in-depth alternativesNatural-gas-fired combined-cycle (NGCC), combination alternative (wind, solar, NGCC, and compressed air energy storage), coal-fired power. The details of this analysis can be viewed in Chapter 8, Alternatives.
Comment: 21-1-AL; Hello everybody, my name is Katie Hopeful, student of Professor Compaans at the University of Toledo. Im a major in physics. My research is in this renewable energy area. So, what Im going to be talking about today is alternatives to nuclear power. In FirstEnergys license renewal application, they dismissed the possibility of almost any form of renewable energy to replace the power production that would be lost by the closing of Davis-Besse.
Response: This comment questions FENOCs evaluation of alternatives to relicensing Davis-Besse contained in the ER. The requirements associated with the analysis of alternatives for FENOCs ER are based on NRC regulations.
Section 51.43(c) of 10 CFR states the following: Analysis. The Environmental Report must include an analysis that considers and balances the environmental effects of the proposed action, the environmental impacts of alternatives to the proposed action, and alternatives available for reducing or avoiding adverse environmental effects The acceptance review determines whether the application contains sufficient information to allow the NRC staff to proceed with the environmental review. On October 18, 2010, the NRC staff determined that the application was complete and acceptable for docketing, in accordance with 10 CFR 51.43. The acceptance of the application shows that the applicant met the regulatory requirements, but it does not reflect the opinion of the NRC in the selection of alternatives. The NRC conducts an independent review of alternatives, selected based on the technical experience of the agency, in accordance with NEPA. This review is documented in Chapter 8 of this SEIS. In contrast to the Davis-Besse ER, Chapter 8 reflects analysis in depth of a combination alternative that includes renewable energies.
Comment: 21-3-AL; the only other thing that I was wanting to mention is the jobs that are going to be created. As he had already mentioned, the maintenance of the wind turbines; the installation of the protects; and also the forecasting that can be done. This was also mentioned in the European Wind Energy Associations annual report. The new technologies. They are able to forecast four hours ahead exactly what the wind speeds are going to be. So that they can predict if they need to have boost up the coal or other forms of production. It makes it really a lot more stable. So, this argument of volatility doesnt quite hold.
Response: This comment relates to the benefit of creating jobs by supporting alternative energy sources. The NRC regulations at 10 CFR 51.71(d) require that a SEIS consider the environmental, economic, and technical impacts, and other benefits and costs of the proposed action and alternatives.
The evaluation of each alternative considers the environmental impacts across seven impact categories: (1) air quality, (2) groundwater use and quality, (3) surface water use and quality, (4) ecology, (5) human health, (6) socioeconomics, and (7) waste management.
Socioeconomic impacts are defined in terms of changes to the demographic and economic characteristics and social conditions of a region. For example, the number of jobs created by the construction and operation of an alternative could affect regional employment, income, and expenditures. The NRC acknowledges that job creation would result from alternatives.
Two types of job creation would likely result construction-related jobs (transient, short in duration, and less likely to have a long-term socioeconomic impact) and operation-related jobs in support of operations (greater potential for permanent, long-term socioeconomic impacts).
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Appendix A Workforce requirements for the construction and operation of each in-depth alternative were evaluated in order to measure their possible effects on current socioeconomic conditions. The results of each analysis are documented in Chapter 8, Alternatives.
Comment: 23-2-AL; I would first like to quote excerpts from an article in The Nation magazine dated February 15, 2010, The Case for Grade Power. This is generally referred to as using waste heat or cogeneration from large facilities of which Ohio has plenty. The article uses Ohio as an example for this opportunity. The article states that according to an analysis by Recycled Energy Development, the Libbey Glass Plant in Toledo, the Arselor (unintelligible) Middle School in Cleveland and the (unintelligible) Chemical Plant in Cincinnati together produces enough waste heat to produce between 145 and 185 megawatts of additional electricity. The study also indicates that Ohio has enough cogeneration potential to retire up to 8 nuclear power plants. According to Oak Ridge National Laboratory this strategy will cost less than half of a coal plant.
Comment: 23-3-AL; A recent report by Policy Matters of Ohio estimates that recycling 7.7 GigaWatts would require a $10.5 billion investment with a three year payback. This would have the further effect of making Ohio industries more competitive, more profit, saving both jobs and the environment.
Response: These comments request the NRC staff to consider cogeneration and energy recycling as alternatives to license renewal. Cogeneration, also known as combined heat and power (CHP) is the simultaneous production of both heat and power. Davis-Besse produces electricity but dispels the waste heat through the cooling water system, as described in Chapter 2. In cogeneration plants, the waste heat (typically in the form of steam) is captured for other uses such as industrial process requiring steam or district heating or both. District heating systems that transfer waste heat, in the form of steam, for residential and commercial heating, are currently in operation in cities such as New York, NY, Detroit, MI, and Boston, MA.
Currently no district heating systems in the U.S. are supplied with nuclear reactors as the steam source; however, countries such as Russia, the Czech Republic, Slovakia, Hungary, Bulgaria, and Switzerland have nuclear powered district heating from cogeneration plants.
The NRC recognizes that cogeneration plants have the potential to offset power demand. In July 2008, the Ohio legislature passed Senate Bill 221, which established an energy-efficiency resource standard that requires electric utilities to implement an Energy-Efficiency and Peak Demand Reduction Program that will yield a cumulative electricity savings of 22 percent by the end of 2025, with specific annual benchmarks. Cogeneration can be retrofitted to existing power plants, and represents an option that states and utilities may use to reduce their need for power generation capability. The need for power may be determined by state, licensee, and, where authorized, Federal (other than NRC) decisionmakers. If the renewed license is issued, state regulatory agencies and FENOC will ultimately decide whether the plant will continue to operate based on factors such as the need for power or other matters within the states jurisdiction or the purview of the owners.
The NRC did not consider cogeneration specifically as an alternative but did evaluate energy efficiency and conservation. Further information can be found in Chapter 8, Alternatives.
A.1.2 Air & Meteorology (AM)
Comment: 16-5-AM; Added together, the disposal to support the industrys nuclear power also comes with a heavy carbon price, which means that nuclear power will not address the pollution, global warming.
A-18
Appendix A Comment: 16-7-AM; The argument of rising energy is irrational at best, and at worst, the resulting global warming would threaten our life support system and, yes, our way of life.
Comment: 16-26-AM; Enormous amounts of energy go into this process. Added together along with disposal, these supporting industries cause nuclear power to also come with a heavy carbon price, which means that nuclear power will not address but will worsen global warming.
Comment: 23-6-AM; It is not carbon free as claimed, and not sustainable.
Comment: 39-2-AM; The process of production of nuclear energy from mining through disposal of waste is very carbon intensive and would contribute heavily to global warming.
Response: These comments represent concerns about greenhouse gases (GHGs), not specifically for the operation of the nuclear power plant but generally from impacts from the entire nuclear fuel cycle. A large number of technical studies, including calculations and estimates of the amount of GHGs emitted by nuclear and other power generation options, are available in literature. These studies, however, are inconsistent in their application of full lifecycle analyses, including plant construction, decommissioning, and resource extraction (uranium ore, fossil fuel). Almost every existing study has been critiqued, and its assumptions challenged by later authors. Therefore, no single study has been selected to represent definitive results in this SEIS. Instead, the results from a variety of the studies are presented in SEIS Tables 6.2-1, 6.2-2, and 6.2-3 to provide a weight-of-evidence argument comparing the relative GHG emissions resulting from the proposed Davis-Besse relicensing compared to the potential alternative use of coal-fired plants, natural gas-fired plants, and renewable energy sources. The NRC staff provides a more detailed discussion on GHGs in Chapter 6, where comparisons of GHG emissions are presented from a variety of energy generation technologies.
The NRC staffs analysis of alternatives in Chapter 8 also addresses relative levels of GHG emissions for alternatives.
Comment: 14-21-AM; Transformer fires cause unique pollutions such as dioxin. Since the cause of the 2009 Davis-Besse transformer fire has not been determined, the possibility of another fire must be considered. The EIS must include the impact of missions created by transformer fires.
Response: This comment expresses concerns regarding the air pollution created by a transformer fire and the potential release of toxins as a result of postulated future failures of the transformer. A polychlorinated biphenyls (PCB) transformer is a transformer that contains PCBs at concentrations greater than 500 parts per million (ppm). From 1929 through 1979, these transformers were installed in apartments, residential and commercial buildings, industrial facilities, campuses, and shopping centers. PCBs are used in electrical transformers because of their useful quality as being a fire retardant.
The EPA regulates the use, storage and disposal of PCB transformers in accordance with the Toxic Substances Control Act (15 USC 2605) promulgated under 40 CFR Part 761.
PCB-contaminated transformers containing between 50 and 499 ppm PCBs are also subject to EPAs regulations. Davis-Besse, at the time of construction, had PCB transformers; however, in 1992, FENOC completed a program to eliminate PCB transformers onsite. Information relating to the transformer fire and air emissions can be found in Chapter 2 of this SEIS. Further information on the regulation of PCB transformers can be found at http://www.epa.gov/epawaste/hazard/tsd/pcbs/index.htm.
A-19
Appendix A A.1.3 Aquatic Resources (AQ)
Comment: 14-3-AQ; Another is the possible effect on the seven-billion-dollar fishery in Lake Erie. Specifically, I think you should look at how the wastewater and how the temperature effluent from this plant would affect and possibly affect indicia species such is the Asian carp. In other words, does the operation of Davis-Besse make it more or less likely that indicia species could come in here and ruin our fishing.
Comment: 22-2-AQ; We need to protect our water resources first from the effects of nuclear forms of pollution. Lake Erie provides drinking water and other consumptive uses to millions of people and many different industries in northern Ohio. We rely on Lake Erie for recreation, and we are entrusted to care for and protect the Lake for future generations as well. They have as much a right to the use and enjoyment of Lake Erie as our present generation, even if the comments do not agree. Davis-Besse is one of the greatest threats to the health of our Lake.
Davis-Besse was strategically located on Lake Erie to meet the tremendous needs of Davis-Besse for water as a coolant. This is great for Davis-Besse but not so good for the Lake.
Davis-Besse uses water from the Lake and spews it back as thermal pollution. Over the years, this has had consequences for Lake Erie. We have once again had increasing algae problems for Lake Erie. the growth of lyngbya wollei, a toxic algae, has accelerated over the past few years along with microcystis. These toxic algae have numerous conditions which contribute to their growth. One, of course, is the presence of ample amount of phosphorous and nitrogen.
Another ingredient is an abundance of warm water. We have billions of gallons of thermal pollution from the power plants surrounding Lake Erie.
Comment: 22-3-AQ; studies on water use, fish kills, and the thermal impacts at the bay shore park land are over 30 years old. The intake for Davis-Besse is in less than 30 feet of water in the Great Lakesshould have beenin the Great Lakes, in Lake Eries shallowest most biologically productive waters. Davis-Besse uses an estimated 50 million gallons of water a day which causes fish kills and thermal impacts. While cooling towers at Davis-Besse limit water use and fish kills with the best available technology, there should be an assessment of water use and fish kills. This request is made as the number of walleye are declining from an ODNRS estimate of 80 million about 5 years ago to less than 20 million in 2010.
Comment: 22-5-AQ; If Davis-Besse were to close on schedule, there would be fewer fish killed and no more warm water discharge. The estimated number of fish that would not be killed is unknown because there are no counts of fish impingement, that is, fish caught against screens, and entrainments, fish that go through screens. In assessing whether Davis-Besse should remain open or closed, an updated, independent analysis of the Davis-Besse water impacts, to fish impingement and entrainment and thermal impacts using Clean Water Act 316 A and B protocol needs to be conducted. If the incremental increase in fish kills and added temperature to the water in aiding algae growth and in decreasing walleye numbers, the environmental and economic impact of the fish kills and algae growth should be considered in the requested re-licensing of Davis-Besse. Furthermore, should the licensing go forward, the license needs to require periodic impingement and entrainment fish counts and thermal mixing zone plume impacts on algae growth and water quality.
Comment: 26-9-AQ; In addition, a scoping comment I have is the thermal pollution coming off the nuclear power plant. Its about a thousand nine hundred, about nine hundred megawatt facility. Thats close to three thousand megawatts of thermal heat coming off of that. And, as weve seen, Lake Erie is beyond the tipping point when it comes to algal blooms. We are beyond that point. We have several facilities in the western basin of Lake Erie; several coal plants, and several nuke plants and the Lake cannot take the load. So I am requesting that the algal blooms that are occurring on Lake Erie, the lyngbya wollei, which is a toxic algae - - its A-20
Appendix A leading to the eutrophication of Lake Erie, the death of Lake Erie, I am requesting that this concept of algal blooms be investigated, and thermal pollution from the nuclear power plant be considered.
Comment: 16-17-AQ; We are also concerned about fish and Lake Erie and the heat coming out of the plant.
Comment: 19-10-AQ; So, just to conclude, Id like to leave you all with some hope that now license extensions are being seriously challenged, almost the minute that theyre brought up.
Another one to mention is Indian Point, New York, River Keeper, Hudson River Keeper headed by Bobby Kennedy Junior, has seriously challenged the Indian Point license extension. The State of New York has joined that proceeding. The Attorney General of New York, the Environmental Department of New York, they are also requiring now Indian Point to install cooling towers, to lessen the thermal damage to the Hudson River, just like the thermal damage, the catastrophic destruction of marine organisms going on at these plants that lack cooling towers. Thats not an issue at Davis-Besse because they have a cooling tower. But as we raised Fermi III, we add up all the thermal impacts, of all power plants in this neck of the woods, and all the toxic chemicals theyre releasing, Im talking nuclear and coal and others.
You got to look at even the thermal impacts going on now, the destruction of the eco-system in Lake Erie, especially when Fermi III is being proposed.
Comment: 29-1-AQ; Resource Center and talk about the rise in microcystine levels due to the thermal pollution. And how that. I mean are they aware that did anyone comment on that Comment: 29-2-AQ; Are they aware! That did anyone comment on that for them.
Comment: 29-4-AQ; No they dont. I just wanted to make sure that someone said that to them. And realize that the microcystine levels are rising.
Response: These comments express concern over the health of Lake Erie. The concerns cite the presence of nuisance species and thermal pollution in the lake.
The heated effluents of nuclear power plants can cause mortality among fish and other aquatic organisms from either thermal discharge effects or cold shock. Temperatures high enough to kill organisms are found in the cooling water systems, often in the area nearest the effluent discharge structure. Because thermal effects were among the earliest potential impacts identified for power plant operation, a great deal of research and regulatory effort has been aimed at understanding and controlling thermal discharges. Upper lethal temperatures (and various other expressions of temperature tolerance) have been determined for many important species and life stages. As a result, conditions that can lead to thermal discharge effects are relatively predictable.
A variety of nuisance organisms or nonnative species may become established or proliferate as a result of power plant operations, including fouling organisms such as the recently introduced zebra mussel, Dreissena polymorpha.
Mitigative measures have been employed at Davis-Besse to reduce the potential for thermal discharge effects. Davis-Besse is equipped with a cooling tower, offshore intake, closed intake canal, bottom intake, and a high-velocity discharge nozzle. The high-velocity discharge nozzle enhances the rapid mixing and heat dissipation of the heated effluent at the outfall.
Colonization of Lake Erie by zebra mussels resulted in several years of improved water clarity and dramatic food web changes, especially a shift in algal production from phytoplankton to bottom-dwelling algae and plants; however, recently, the zebra mussels have been linked to the blue-green alga (cyanobacteria) Microcystis aeruginosa. Microcystis had been a common species in Lake Erie for at least a century but recently has grown into nuisance bloom A-21
Appendix A proportions. Research performed by the Great Lakes Environmental Research Laboratory (GLERL) showed video evidence of zebra mussels selective eating habits. GLERL was able to capture the zebra mussels filtering the water, regardless of the presence of microcystis, and releasing the microcystis aeruginosa back into the lake. The zebra mussels however continued to eat the other algae. Zebra mussels, in response to the consumption of the algae, release phosphorous that, in turn, feeds the microcystis, further facilitating their growth.
The concentrations of phosphorous, despite years of decline, have recently been showing a gradual increase. Phosphorous has been linked to microcystis; however, it has also been theorized, coupled with thermal pollution, to encourage the growth of lyngbya wollei, a toxic algae. In Maumee Bay, large populations of lyngbya wollei have recently emerged. Research indicates the concern was initially detected in 2006, and the population has since been growing.
The Ohio EPA, Division of Surface Water, has the authority over the Maumee Bay. According to the Ohio EPA:
[L]ittle scientific information exists to determine the complicated biological processes that encourage the spread of Lyngbya wollei. In order to investigate this issue further, Ohio EPA has formed a Phosphorus Task Force to more formally review the phosphorus loading data from Ohio tributaries to Lake Erie; to consider possible relationships between trends in dissolved reactive phosphorus loading and in-lake conditions; to determine possible causes for increased soluble phosphorus loading; and, to evaluate possible management options for reducing soluble phosphorus loading.
Regarding studies under Sections 316(a) and 316(b) of the Clean Water Act, the Ohio EPA, and not the NRC, is responsible for regulating Davis-Besses intake and discharge through the National Pollutant Discharge Elimination System (NPDES) permitting process and for implementing the requirements of Sections 316(a) and 316(b). Modifications to the NPDES permit are outside the regulatory authority of the NRC. The Ohio EPA will ultimately decide if modification to the permit is necessary in response to the presence of microcytosis aeruginosa and lyngbya wollei.
The Davis-Besse discharge, however, is not a major contributor of phosphorous to Lake Erie.
The source of nuisance populations of microcystis aeruginosa or lyngbya wollei or both have not been observed near the discharge location of Davis-Besse or the immediate surrounding area.
The NRC staff acknowledges that Lake Erie is experiencing cumulative impacts to its water resources as a result of these species. These impacts have been included in Chapter 4 under cumulative impacts.
Comment: 45-2-AQ; There are no Federal wilderness areas or designated critical habitat within the vicinity of the proposed site. Davis-Besse consists of 954 acres, of which approximately 733 acres are marshland that is leased to the U.S. Government as part of the Ottawa National Wildlife Refuge. In a letter dated December 16, 2009, we provided comments to FENOC on the proposed 20-year renewal of the operating license for Davis-Besse. At this time we have no additional comments.
Response: This comment was provided by the USFWS. The NRC staff incorporated the USFWSs information provided in this comment into the draft SEIS, including the information in the referenced December 16, 2009, letter to FENOC, which was provided in Appendix C of FENOCs ER.
A-22
Appendix A A.1.4 Cultural Resources (CR)
Comment: 46-1-AR; The Peoria Tribe has no objection to the proposed construction.
However, if any human skeletal remains and/or any objects falling under NAGPRA are uncovered during construction, the construction should stop immediately, and the appropriate persons, including state and tribal NAGPRA representatives contacted.
Response: The staff addresses the potential impacts to Cultural Resources associated with renewing the Davis-Besse operating license in Chapter 2. Programs associated with new ground disturbance related to refurbishment and/or the inadvertent discovery of Cultural Resources is described and/or sited in Chapter 3 and Chapter 4 of this SEIS. Finally, the environmental impacts of alternatives evaluated in depth is discussed in Chapter 8 of the SEIS, including cultural resource impacts.
A.1.5 Human Health (HH)
Comment: 14-4-HH; There are several safety issues that impact on the environmental questions. First of all, I personally know a first responder. Weve had conversations about Davis-Besse. He told me that they have been told that in the event of some sort of accident, the only thing they have to worry about is radioactive iodine, and since they will be given pills for radioactive iodine, they dont even have to worry about that.
Comment: 14-10-HH; Also, downwind from Davis-Besse in the local communities here, there is a cancer cluster. The state studied this cluster and it was woefully inadequate. It consisted of dosimeters, given to about a fifth of the families. They went out in the yards and ran the dosimeters themselves looking at the sky. They didnt find anything, but Im not sure they -- believe this happened when Davis-Besse wasnt actually running, and it doesnt address the fact that there may have been emissions in the past, and there could be emissions in the future. So, I think that any federal environmental impact statement would have to look at known emissions from Davis-Besse which are routine, such as I have, and correlate those with the cancer cluster in these local counties and look for cancers that are specifically known to correlate with the nucleates that we know of at least, such as thyroid cancer. I know I only have about five minutes here. I want to say that I know - - as an environmentalist, I know that the NRC is given an impossible task here. Any process that generates radioactive pollution that will be able to cause cancer, birth defects and hurt people for the next - - for millions of years in some cases, by definition, it cant be done safely.
Comment: 26-5-HH; And in fact there is a cancer cluster near Clyde, Ohio which is about 15 to 18 miles as the crow flies from Davis-Besse. So, the comment that I have on Scoping is that I am requesting that baseline epidemiological studies be done. And that we explore what is coming out of that nuclear power plant. They are allowed by licensing to release gaseous, liquid from the plant. Below permissible levels. But there are cancers over in Clyde, and families are decimated. And I would request that baseline epidemiological studies be done in the entire region.
Comment: 28-1-HH; I would go farther than to say the Nuclear Regulatory Commission is a rogue organization. I would call it a terrorist organization. And I would say that the cancer that people are suffering from in Clyde, Ohio, I know that Lucas County, when I left 10 years ago had the highest cancer rates of the State of Ohio. Were all facing cancer as our future.
And this cancer, I would say is on the most part, is on the hands of...Its a legacy of industrial capitalism, but this cancer is on the Nuclear Regulatory Commissions hands because they A-23
Appendix A have done nothing to police or regulate or control this industry. Its disgusting, it makes me sick to my stomach.
Comment: 28-2-HH; I was listening to public radio the other day and they were talking about how they felt like the Rust Belt was kind of offensive terminology to use for this area of the country. And the thought crossed my mind well why not The Cancer Belt instead? Because thats the number one killer in this area. So, if the rust belt is too niccy-nice. You know, they want to consider it the water belt but the water belt is contaminated.
Comment: 14-19-HH; Something else I just wanted to mention that Tony Mangano, Anthony Mangno has pointed out that thyroid cancers in Ottawa County, right around the plant, went from below the national average before the plant started operating to above the national average now. And, in fact, research says that cancer rates, thyroid cancer rates particularly, just about double when you put a nuclear power plant in. So, iodine, radioactive iodine is very rare. Thyroid cancer is very rare. Pretty much you can count on the fact that those people who are dying from thyroid cancer are dying because of radioactive releases from the plant.
Radioactive releases that are casual, that are average, that are normal, part of their normal operations. So, people are dying. Theyre in the hundreds now. If we keep doing this plant and radioactive thyroid. Iodine, radioactive isotopes of Iodine stay radioactive for 20 million years.
So the more we generate the more well be. People will die from the cancers caused by this radioactive Iodine. Theyre in the hundreds now. Another 20 years theyll be in the thousands.
So what we are trying to do here is prevent thousands of people from being killed by an unnecessary form of energy. Weve heard testimony here today about just exactly why thats so unnecessary.
Comment: 43-3-HH; Yeah I want to make a statement on behalf of kids whose environment is being destroyed. There used to be a lot more nature to go to and tromp around in and now kids dont have that we have urban environments that are polluted kids getting cancer because of this kind of stuff and its really not ok. So this is Connie Gadwell Newton urging you to not renew the licensing for Davis-Besse. Thank you.
Response: The NRCs primary mission is to protect the public health and safety and the environment from the effects of radiation from nuclear reactors, materials, and waste facilities.
The NRCs regulatory limits for radiological protection are set to protect workers and the public from the harmful health effects (i.e., cancer and other biological impacts) of radiation on humans. Radiation standards reflect extensive scientific study by national and international organizations. The NRC actively participates and monitors the work of these organizations to keep current on the latest trends in radiation protection.
Recently, the NRC asked the National Academy of Sciences (NAS) to perform a state-of-the-art study on cancer risk for populations surrounding nuclear power facilities. The NAS study will update the 1990 U.S. National Institutes of HealthNCI report, Cancer in Populations Living near Nuclear Facilities.
The study will be carried out in two consecutive phases. A Phase 1 scoping study will identify scientifically sound approaches for carrying out an epidemiological study of cancer risks. This scoping study began on September 1, 2010, and will last for 15 months. The result of this Phase 1 study will be used to inform the design of the cancer risk assessment, which will be carried out in a future Phase 2 study.
The Sandusky County Health Department (SCHD) and the Ohio Department of Health (ODH) conducted a study of childhood cancer incidence, from the years 1996 through 2006, in the city of Clyde and Green Creek Township, both located within 50 miles of Davis-Besse. The studys objective was to identify factors that may have contributed to the higher-than-expected A-24
Appendix A childhood cancer rates found in that area. The families of 21 childhood cancer patients participated in the study, responding to questionnaires administered by SCHD staff. The questionnaires addressed a variety of topics, including possible exposure to ionizing radiation.
The report concluded that there were no exposures or variables that were common to the 21 children with cancer who participated in this profile. The report can be viewed online at:
http://www.sanduskycohd.org/Template/
Childhood%20Cancer%20in%20Eastern%20Sandusky%20County%20a%20Profile%205
%2026%2011.pdf Although radiation may cause cancers at high doses, currently there are no data to unequivocally establish the occurrence of cancer following exposure to low doses, below about 10 rem (0.1 Sv). However, radiation protection experts conservatively assume that any amount of radiation may pose some risk of causing cancer or a severe hereditary effect and that the risk is higher for larger radiation exposures. Therefore, a linear, no-threshold dose response relationship is used to describe the relationship between radiation dose and detriments such as cancer induction; simply stated, any increase in dose, no matter how small, is assumed to result in an incremental increase in health risk. This theory is accepted by the NRC as a conservative model for estimating health risks from radiation exposure, recognizing that the model probably over-estimates those risks. Based on this theory, the NRC conservatively establishes limits for radioactive effluents and radiation exposures for workers and members of the public. While the public dose limit is 100 mrem (1 mSv) for all facilities licensed by the NRC (10 CFR Part 20), the NRC has imposed additional constraints on nuclear power reactors. Each nuclear power reactor, including Davis Besse, has license conditions that limit the total annual whole body dose to a member of the public outside the facility to 25 mrem (0.25 mSv). In addition, there are license conditions to limit the dose to a member of the public from radioactive material in gaseous effluents to an annual dose of 15 mrem (0.15 mSv) to any organ; for radioactive liquid effluents, a dose limit of 3 mrem (0.03 mSv) to the whole body, and 10 mrem (0.1 mSv) to any organ.
The amount of radioactive material released from nuclear power facilities is well measured, well monitored, and known to be very small. The doses of radiation that are received by members of the public as a result of exposure to nuclear power facilities are so low (i.e., less than a few millirem) that resulting cancers attributed to the radiation have not been observed and would not be expected.
A number of studies have been performed to examine the health effects around nuclear power facilities. The following is a list of some of the studies that have been conducted:
In 1990, at the request of Congress, the National Cancer Institute (NCI) conducted a study of cancer mortality rates around 52 nuclear power plants and 10 other nuclear facilities. The study covered the period from 1950 through 1984 and evaluated the change in mortality rates before and during facility operations. The study concluded there was no evidence that nuclear facilities may be casually linked to excess deaths from leukemia or from other cancers in populations living nearby.
Investigators from the University of Pittsburgh found no link between radiation released during the 1979 accident at the Three Mile Island Nuclear Station and cancer deaths among nearby residents. This study followed more than 32,000 people who lived within 5 miles (mi) (8 kilometers (km)) of the facility at the time of the accident.
In January 2001, the Connecticut Academy of Sciences and Engineering issued a report on a study around the Haddam Neck Nuclear Power Plant in A-25
Appendix A Connecticut and concluded that exposures to radionuclides were so low as to be negligible and found no meaningful associations to the cancers studied.
In 2001, the American Cancer Society concluded that, although reports about cancer clusters in some communities have raised public concern, studies show that clusters do not occur more often near nuclear plants than they do by chance elsewhere in the population. Likewise, there is no evidence linking the isotope strontium-90 with increases in breast cancer, prostate cancer, or childhood cancer rates.
In 2001, the Florida Bureau of Environmental Epidemiology reviewed claims that there are striking increases in cancer rates in southeastern Florida counties caused by increased radiation exposures from nuclear power plants.
However, using the same data to reconstruct the calculations on which the claims were based, Florida officials did not identify unusually high rates of cancers in these counties compared with the rest of the state of Florida and the nation.
In 2000, the Illinois Public Health Department compared childhood cancer statistics for counties with nuclear power plants to similar counties without nuclear plants and found no statistically-significant difference.
In summary, there are no studies to date that are accepted by the nations leading scientific authorities that indicate a causative relationship between radiation dose from nuclear power facilities and cancer in the general public. The amount of radioactive material released from nuclear power facilities is well measured, well monitored, and known to be very small.
These comments provided no new and significant information. Therefore, no changes have been made to the SEIS.
Comment: 20-4-HH; So tritium is an isotope of hydrogen, its hydrogen-3, which means one proton and two neutrons, and, it is not naturally occurring and has a half-life of 12.3 years. so it is produced in all nuclear reactors by a neutron bombardment either of lithium-6, or boron-10.
And, some of you may remember boron is the acid, well, theres boron in the cooling water that is in the pressure vessel, and it was that leaking of boric acid, that was responsible for going through 6 inches of carbon steel in the reactor head. So, the presence of that boron is, under neutron, impact, can produce the, tritium. Its radioactive, it decays, in 12.3 years half-life, and it emits a high-energy electron which is, known as a beta particle, and, and theres another particle which is an anti-neutrino, which almost interacts, so, so, so little that, neutrinos can, pass completely through the earth. So we dont worry about the neutrinos or the anti-neutrinos, but the beta particle is 5.7 kilo, uh...KEV, kilo electron volts, and, this also has a fairly, fairly low penetration. It, it barely gets into your skin, it stops almost with the dead layers of the skin.
However, if you ingest it, or you breath it, then its very dangerous because it, it has a very short, penetration distance in your lungs or, or in your intestinal tract. So, bec...its likely to be ingested either as water vapor, as, hydrogen, actually it would be an analog...isotope, one atom of hydrogen, one atom of normal hydrogen, one atom of tritium, or it, it forms, H2O, water, as, hydrogen, one atom of tritium, or it, it forms, H2O, water, as most likely a normal hydrogen isotope and a tritium isotope together with oxygen, so you will ingest it if you drink water from one of these contaminated wells. So, just a couple of things to remind us of the danger of, of these reactors. Even if there is not a catastrophic meltdown, there are ever-present dangers in these, in the operation of these nuclear reactors.
Comment: 26-7-HH; In addition, it was mentioned earlier that there were Tritium leaks in 2009.
There was also a Tritium leak in 2008. The grounds are contaminated. Im concerned about A-26
Appendix A the buried piping at the Davis-Besse plant, about the leaking of Tritium, about the potential of flooding externally, the potential of flooding internally at the Davis-Besse plant. This is an aging plant. And with that Tritium leak and as you run a nuclear power plant into the ground, which is being proposed, another 20 years there are going to be increasing leaks, increasing contamination.
Response: These comments are concerned with tritium in the groundwater. NRC regulations require licensees to control and limit radioactive releases, including tritium, to the environment (the air and water). As part of the NRC requirements for operating a nuclear power facility, licensees must comply with radiation dose limits for the public in 10 CFR Part 20 and keep releases of radioactive material into the environment during normal operations as low as is reasonably achievable (ALARA), in accordance with 10 CFR 50.36a..
Information on FENOCs groundwater monitoring program is contained in Chapters 2 and 4 of this draft SEIS.
No new and significant information is provided in these comments. Therefore, no changes have been made to the SEIS because of these comments.
Comment: 22-4-HH; In addition, the amount of toxic algae has increased over the last, 10 to 15 years, so much that the Ohio EPA reports that physical contact with the toxic algae in Lake Erie probably causes illnesses, probably caused illnesses to 10 people in the summer of 2010.
Comment: 29-3-HH; Its not a question! I just want the panel to know that inadvertently when people start dying or getting sick because the levels occur. Is there any way that they could possibly be held responsible or get sued?
Response: These comments express concerns relating to the nuisance organisms in Lake Erie as they apply to Human Health. Lyngbya wollei and Microcystis aeruginosa are two different species of cyanobacteria. Both currently exist in Lake Erie and have become a nuisance in the Maumee Bay area. When conditions are present to facilitate a rapid growth, a dense population forms, known as a bloom. Some Blooms are harmless; however, when these organisms contain toxins, other noxious chemicals, or pathogens, it is referred to as harmful algal blooms (HAB). HABs may cause health concerns dependant on the method an individual comes in contact with the toxin produced.
Thermal pollution has been referenced as a contributor to the growth of HABs. Davis-Besses thermal effluent is warmer than the receiving waters. HABs, however, require calm, low-flow water conditions in order to facilitate their growth. The Davis-Besse outflow is equipped with a high-velocity discharge nozzle. The high-velocity discharge nozzle, as part of the NPDES permit, is intended to enhance the rapid mixing and heat dissipation of the heated effluent at the outfall. As referenced in 2.2.6, Aquatic Resources, of this SEIS, the regulation of surface waters is within the regulatory authority of the Ohio EPA. In addition, the thermal discharges, regulated by the NPDES permit, are also under the authority of the Ohio EPA.
NRC staff did not discover any studies linking Davis-Besse as a direct contributor to the formation of HABs. The health impacts associated with HABs and the impairment of Lake Erie are discussed in the Cumulative Health Impacts, section of Chapter 4.
A.1.6 Hydrology (HY)
Comment: 20-3-HY; This is a study by Davis-Besse. In Appendix E, thats the Environmental Report, on this page (Page 2.3-2), I quote here, theyre, theyre required, by their operating license to have monitoring wells to monitor the quality of the groundwater in the, within the A-27
Appendix A perimeter. And one of their wells in 2..., in the spring of 2009 showed a tritium level that was rising, 4000, pico curies/liter. And, this is a quote from their study. As a result, the First Energy Nuclear Operating, Company, notice thats a separate operating company from First Energy, from the rest of First Energy, is pursuing a root cause approach to identify the source of the tritium in the wells. No tritium concentrations of...have been detected above the, US EPA drinking water limit of 20,000 picocuries. But, this to me is very troubling. Even though the, the, concentration is not that high yet, but is an increasing amount, the question is where does it come from?
Response: The comment expresses concern relating to the source of the tritium noted in FENOCs ER.
The NRC staff describes the groundwater resources at Davis-Besse and the effects of plant operations on groundwater hydrology and quality in Chapters 2 and 4 of this SEIS. Chapter 2 summarizes the results of NRCs review of Davis-Besses Groundwater Protection Program, including the placement of site groundwater monitoring wells. As part of this evaluation, the NRC staff specifically reviewed the conceptual groundwater model prepared for Davis-Besse in 2007 and 2008. All studies reviewed by the NRC staff are cited in Chapter 2 of this SEIS, including analysis of tritium information.
No new and significant information is provided in this comment. Therefore, no changes have been made to the SEIS because of this comment.
Comment: 26-6-HY; Earlier again, this week, I got several documents from Connie Klein who was one of the interveners at Davis-Besse on the first Operating. And she shared with me photos of the flooding of the Davis-Besse in 1972. This was during construction. The entire site was flooded for two to three weeks. Um I have concerns about the Davis-Besse flooding. As you all know Lake Erie is very shallow. The western basin is very very shallow, and it is subject to something called a seiches where the wind blows out the water, blows it east. Then the water comes back, like a bathtub, and floods the western shore. Im concerned about the potential flooding of that Davis-Besse Plant.
Response: This comment expresses concern regarding the potential of flooding at Davis-Besse. As part of the initial design of Davis-Besse, consideration for flooding was required to ensure the safety of structures and continued operation of the plant. The plants design basis included the determination of the probable maximum surge flood level and is documented in the final safety analysis report (FSAR).
The static water levels in the western basin of Lake Erie are subject to long term, annual cyclical variation, and short period variations. These variations are due to wind tides and seiches.
Seiches are a movement on the surface of an enclosed body of water, in this case Lake Erie, usually caused by intense storm activity.
The short period variations in the daily level from the monthly mean level are due to both a lengthwise wind tide which produces the greatest disturbance of water level and a transverse seiche in the west end of Lake Erie which can oscillate between the northern and southern shores. A traverse seiche of 0.8 ft has been recorded but for design purposes, 1.0 ft has been used in the design considerations.
Based on collected and available data since 1860, the maximum variations in the mean monthly water level are 4.2 feet above datum and 1.2 feet below datum. Not included in this range were two occurrences in 1973 and 1974, when an all-time high lake level was recorded at 4.9 ft above datum. Davis-Besse, in its design considerations, used a probable maximum variation of 4.8 feet above and 1.5 feet below datum. Although 4.8 ft is less than the recorded 4.9 ft, the 0.1 ft difference is accounted by the rounding up of the daily level variation from 0.8 ft to 1.0 ft.
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Appendix A A probable maximum meteorological event was used to determine the maximum rise in lake level due to wind tides. This meteorological event would have a maximum ENE wind at anyone location of 100 miles per hour for a 10-minute period, and the wind speed could exceed 70 miles per hour during the six-hour period both before and after the maximum wind speed.
The force or push of the wind driving the water level up, resulted in a maximum wind tide rise of 9.3 ft.
The probable maximum surge flood level that could occur at Davis-Besse would be a combination of all these occurrences, for both the cumulative high and the cumulative low. For flooding concerns, the design would relate to the cumulative high. Thus, the 4.8 high monthly mean, 1.0 ft seiche, and the 9.3 ft wind tide would result in a 15.1 ft rise in low water datum to reach a static high elevation of 583.7 ft. Davis-Besse has a finished floor elevation set above the static high and is further protected by an earthfill breakwall built up to an elevation of 591.0 ft to further protect the site from potential wave action.
As a result of the 2011 earthquake and tsunami that struck Japan, resulting in extensive damage to the nuclear power reactors at the Fukushima Dai-ichi facility, the NRC has taken significant action to enhance the safety of reactors in the United States. Operating nuclear reactors were directed to use present-day information to reevaluate the flooding hazards that could impact their site and to submit their reevaluations to the NRC for evaluation in a Hazard Reevaluation Report. Information on the NRCs actions relating to Fukushima Dai-ichi accident can be found at: http://www.nrc.gov/reactors/operating/ops-experience/japan-dashboard.html.
A.1.7 License Renewal and its Process (LR)
Comment: 14-1-LR; Good evening. Like most people in the Northwest Ohio area, I first found out about the scoping meeting earlier in the week when there was a story in the Blade. So, I had not had an opportunity to completely read the Environmental Impact Statement thats been prepared with the application for the license renewal. But, I think that is one of the issues that should be dealt with in the scoping process at either another later meeting or perhaps further announcements, and at the very least, I would like to request a hard copy also be placed in the Wood County Library in Bowling Green, Ohio.
Comment: 16-1-LR; My name is Patricia Marida. Im the Chair of the Nuclear Issues Committee of the Ohio Sierra Club. And, we had a whopping four days to know about this meeting. I had four days ahead. I learned about it this morning and have come up from Columbus here.
Comment: 14-15-LR; And thoughI felt at the time, those people should be at this hearing, but most people didnt even know it happened. It went by before people could get their thoughts together. And so we asked the NRC to hold another one here in Toledo, they refused, but we have decided to hold our own and thats what this is...thats what this is about.
Comment: 16-23-LR; First let me say that the Sierra Club is disappointed that the NRC only gave 10 days notice of these scoping meetings in the Federal Register, and that the public only had 3 days notice from an article in The Toledo Blade. The Davis-Besse Environmental Report and License Renewal Application were almost 2000 pages, not including the NRC Generic Environmental Impact Statement for Nuclear License Renewal. Therefore, we would like to request that the NRC hold at least one additional scoping meeting, and that this be held in Toledo, close to the population center with residents who are informed by The Blade. Also, setting the comment deadline during the holiday season makes it difficult for people to have A-29
Appendix A time to digest the material and comment. Therefore, we would also like to request an extension of the comment period, preferably until the end of January.
Comment: 44-1-LR; I would be very interested in a scoping meeting taking place in Toledo, Ohio where more people would be able to attend. I also think more time should be allotted for the comment period as December 27, 2010 falls in the middle of the holiday period. Perhaps an additional 30 day period would be appropriate.
Comment: 49-1-LR; The people of Northwest Ohio, Southeast Michigan, and other communities that would be the most adversely affected by an accident at Davis-Besse deserve a longer comment period and more hearings before the NRC automatically approves First Energys request to re-license. Please attend our hearing, as outlined below. PUBLIC HEARING on re-licensing of the Davis-Besse Atomic Reactor Saturday Dec. 18 from 12 noon to 3 pm St. Marks Episcopal Church 2272 Collingwood Blvd Toledo, Ohio 20 MORE Years of Radioactive Russian Roulette on the Great Lakes shore?! We are calling for input from all interested parties regarding First Energys mismanagement of Davis-Besse, and the Nuclear Regulatory Commissions lack of oversight of that facility, in particular residents of Ohio, the Toledo area, South East Michigan, or residents of any community that would be directly adversely effected by an accident at Davis-Besse. Anyone can testify, sign in will be required.
This hearing will be videotaped and presented to the NRC. FirstEnergy has applied to the U.S. Nuclear Regulatory Commission (NRC) for a 20-year operating license extension at its Davis-Besse nuclear power plant near Oak Harbor, Ohio, just over 20 miles east of Toledo.
Davis-Besse is one of the most problem-plagued atomic reactors in the entire country: it has suffered six significant accident sequence precursors, three times more than any other American nuclear plant. The original license was granted in 1977 and will expire in 2017. If the extension is approved Davis-Besse can operate until 2037. In the past 10 years NRC has rubber-stamped 60 or 60 license renewals sought by industry. The NRC Office of Inspector General has reported serious problems with NRCs license extension program: NRC staff have cut and pasted the nuclear utilitys own work, sometimes word for word, falsely presenting it as an independent safety Comment: 14-13-LR; So, Id like to welcome you all. My name is Joe DeMare and I spoke at the official NRC hearing on November 4. And I have to tell you, it was a, a rather disappointing experience, because almost everyone there was either employed by Davis-Besse or they were from an organization that received money from Davis-Besse.
Response: The environmental scoping period is an opportunity for the public, tribal governments, and local, state and Federal government entities to assist the NRC in identifying areas of concern, impacts, and alternatives as staff develops the SEIS for license renewal. The NRC announced the start of the scoping period by use of a Federal Register Notice, published on October 28, 2010. The 60-day review period for the environmental scoping period ended on December 27, 2010.
The purpose of the environmental scoping meeting was to provide a brief summary of the license renewal and scoping process and to allow the public an opportunity to provide comments. Although the NRC emphasizes the purpose for the solicitation of comments, it does not restrict the topic of those comments to those applicable to license renewal. As a result, the public, in some instances, takes this opportunity to voice their opinion in support or against the approval or denial of the renewed license.
The environmental scoping meeting was one method for providing scoping comments.
Comments were also sent to the NRC in response to this draft SEIS by the following methods:
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Appendix A Comments were submitted electronically via the Federal rulemaking Web site: http://www.regulations.gov and search for documents filed under Docket ID NRC-2010-0298.
Comments were mailed to: Chief, Rulemaking and Directives Branch (RADB), Division of Administrative Services, Office of Administration, Mail Stop: TWB-05-B01M, U.S. Nuclear Regulatory Commission, Washington, DC 20555-0001. Comments were faxed to RADB at (301) 492-3446.
Additional details relating to the license renewal can be found in Chapter 1 of this draft SEIS or at http://www.nrc.gov/reading-rm/doc-collections/nuregs/brochures/br0291/br0291-r2.pdf.
Comment: 18-3-LR; Now were looking at what the NRC is doing in, in its laughable oversight of all the nuclear power plants but Davis-Besse in particular. And it occurs to me that, thatthe NRC is a rogue agency and just as the, as the, SEC failed us, failed us, the citizens that it should be, watching out for, that is our goals, that is our tool, that is the thing that, the entity that we have put in place through our government to make sure that everybody plays by the rules.
And that is what the, Nuclear Regulatory Commission is as well. However, it is failing to do that, it has, it has absolutely failed to do that. And what it has done in reference to Davis-Besse and the numerous problems that we have seen is, at Davis-Besse, demonstrates that very clearly.
Comment: 25-2-LR; We need to broaden the idea of what environmental consequences, environmental impact means when it comes to nuclear power and something like Davis-Besse, and other people who have spoken here today have done a better job at talking about what specifically, The common definition of what environmental impacts might be. But Id like to say something about the political environment that is affected by the operation of nuclear power plants and Davis-Besse relicensing, the potential licensure of a plant down in Piketon a new power plant that our Democratic Governor invited in to this situation that Kucinich will probably go right along with and that is the credibility and the competency of something called the Nuclear Regulatory Commission. Already while the residents of this area would be most directly affected by the power plant, Cleveland is not that far away and the NRC should have solicited input from people from a broader radius around the power plant including Michigan and Indiana.
Because what weve found from the Chernobyl accident is that radioactive waste doesnt stop at municipal boundaries or national boundaries. And the environmental impact is much broader than how some fish that get caught in an intake pipe or the other kind of more immediate sort of environmental impacts that people might think of. The fact that the NRC didnt hold multiple hearings on this is a problem, but they shouldnt and Im speaking directly to the NRC at this point. The NRC shouldnt take as the expression of the people of Ohio the testimony of just those people who attended the hearing on November 6th or 4th or whenever it was right after election day. That the people are economically benefitting from the conduct of FirstEnergy by the operation of that power plant whether its through their jobs or through charitable contributions, that is not a legitimate expression. We have a political problem in this country of disengagement and alienation and generally, the government and its regulatory bodies are treated with contempt by the mass media. And a culture of contempt is built among the people for our government and for the mechanisms that we as people use collectively to monitor things like the banking industry or the nuclear industry. Its not to our benefit that that is happening, but it is. So that small group of people who testified in favor of this relicensing is not a complete or an inclusive representation of the people that are concerned with this. And I would suggest that most of the people that are concerned with this are disengaged and are not paying attention. And the credibility of the NRC is at stake.
Comment: 26-4-LR; So the lesson I take out of this was I learned that the NRC is incapable of learning lessons. As mentioned earlier, they are indeed a rogue agency. This past week, the A-31
Appendix A 61st nuclear power plant that had applied for relicensing was relicensed. They are now batting 1000%. 1000, Batting 1000. 61 for 61 on relicensing applications. So, the NRC has not a shred of credibility with the public, and they are there, running interference, keeping the people away from confronting these utilities when they run these abysmal plants.
Comment: 28-3-LR; I dont have any faith in the Nuclear Regulatory Commission to do anything about the issue, but, thanks. Thats all I have to say.
Comment: 26-10-LR; So, I do not have confidence in the NRC to force about proper equipment, maintenance. Perpetually, there are exemptions that are requested and just as a matter of rubberstamping - - the Nuclear Regulatory Commission, the Nuclear Rubberstamp Commission, allows them exemption time after time. Again. Production over safety. Profit over people.
Response: These comments express a lack of confidence relating to NRCs oversight and regulation. To ensure that U.S. nuclear power plants are operated safely, the NRC licenses the plants, licenses the plant operators, and establishes license conditions for the safe operation of each plant.
In addition, the safe operation of nuclear power plants is not limited to license renewal but is and will be dealt with on a daily basis as a part of the current operating license. The NRC, on an ongoing basis, at every nuclear power plant, addresses safety issues and concerns. The NRC conducts safety inspections throughout the operating life of the plant, whether during the original or renewed operating license. If the NRC discovers safety issues at a nuclear power plant, they are addressed immediately, and any necessary changes are incorporated under the current operating license. As such, the regulatory safety oversight of Davis-Besse is ongoing.
Comment: 18-4-LR; This is the beginning. Certainly, we dont have enough people in this room. We never do when we try to do something like this. We fit it in between all of the things that we do as, as mothers, as fathers, as, as parts of families, as parts of communities, we fit it in with our jobs, and we are determined to make a change. So as we approach that process here, in, in making comments, that the Nuclear Regulatory Commission will do their utmost to ignore, as, as we approach this process, we have to understand that this is the beginning of the process. This is the beginning of the process of us as citizens, and I believe that We the People is one of the most powerful statements that anybody can make. And We the People embodies our democracy, so We the People will be the ones who will have to challenge not only Davis-Besse but the NRC.
Comment: 23-1-LR; Hi folks. Um I prepared written comments for the NRC. Im really pleading with you all because Im not sure theyll listen or read them.
Response: These comments express a lack of confidence over the NRCs ability to address and incorporate scoping comments. To further enhance the development of the SEIS, public participation is solicited as part of the license renewal scoping process. NRC held two public meetings on November 4, 2010, to solicit comments from the public.
Two additional meetings, not sponsored by the NRC, were also conducted to obtain comments from the public. The Peoples Hearing, held by the Green Party of Ohio, represented by Anita Rios and Joseph DeMare, was held on December 17, 2010. The Sierra Club, represented by Patricia Marida, also held a separate meeting on December 11, 2010. Prior to the Davis-Besse scoping period, scoping comments in video format had never been submitted. The Peoples Hearing provided a transcript of the meeting, in addition to the video submission, to ensure the accurate capture of their comments. The NRC, to provide complete representation of the comments, developed an unofficial transcript of the Sierra Club meeting. Comments are A-32
Appendix A both welcomed and encouraged as part of the Draft SEIS comment period for incorporation into the final SEIS.
The NRC makes a conscious effort to address public concerns provided in the scoping comments. The NRC acknowledges there is public dissatisfaction when comments, are categorized as out of scope. The Scoping Summary Report and Appendix A of this SEIS, however, has included expansive responses. Where the comments were deemed in scope, a summarized response is provided and the reader is directed to the appropriate section within the SEIS to gain additional details. Where the comments are categorized as out of scope, staff responded to the comments and redirected the reader to where the comments are addressed.
Comment: 26-2-LR; Weve heard that there are several alternatives to Davis-Besse.
Replacement power is available now. Could be generated much cheaper. It is about the consecration of wealth and a cartel of the utilities that like the monopoly status that they enjoy, and they are locking out the people. It is not power, not energy for the people. It is power and political power against the people.
Comment: 16-25-LR; The environmental effects that occur in other parts of the United States should come under consideration when the NRC develops the Environmental Impact Statement.
Response: These comments request evaluation of the cumulative effects of license renewal on the United States. The cumulative effects of license renewal are evaluated in this SEIS. A detailed discussion can be found in Chapter 4.
Comment: 16-32-LR; Even the 40-year time frame for operation of a power plant does not have an engineering basis, but was based on the time needed to pay off construction bonds.
What happened to the engineering responsibility to oversee and advice an operation of this magnitude of danger?
Response: The Atomic Energy Act provides the NRC with the regulatory authority for to issue licenses for commercial power reactors to operate for up to 40 years and allows these licenses to be renewed for another 20 years. A 40-year license term was selected based on economic and antitrust considerations -- not technical limitations. The NRC has established a license renewal with clear requirements to assure safe plant operation for an additional 20 years of plant life.
The license renewal rule, 10 CFR Part 54, establishes the technical and administrative requirements for renewing a reactor operating license. Part 54 focuses the staffs review on managing the adverse effects of aging to ensure that important systems, structures and components will continue to perform their intended function during the 20-year period of extended operation. An applicant must provide the NRC with an evaluation that addresses the technical aspects of plant aging and describes the ways those effects will be managed. The NRC reviews the application and documents the conclusions in the safety evaluations.
The applicant must also prepare an evaluation of the potential impact on the environment if the plant operates for another 20 years. The NRC performs plant-specific reviews of the environmental impacts of license renewal in conformance with the National Environmental Policy Act and the requirements of 10 CFR Part 51. To facilitate the environmental review for license renewal, certain issues were evaluated generically for all plants rather than separately in each plants renewal application. The generic evaluation, NUREG-1437, Generic Environmental Impact Statement for License Renewal of Nuclear Plants, (GEIS) assesses the scope and impact of environmental effects that would be associated with license renewal at any nuclear power plant site. A plant-specific supplement to the GElS, commonly referred to as the SEIS, is prepared for each licensee that applies for license renewal.
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Appendix A Before a new license is issued, the NRC will ensure that there is a technically credible and legally sufficient basis for granting a renewed license for an extended 20 years as reflected in the NRCs safety evaluation report, final environmental impact statement supplement, and the proposed renewed license.
A.1.8 Opposition to License Renewal (OL)
Comment: 7-1-OL; FirstEnergy should not be allowed to continue to operate Davis-Besse after 2017.
Comment: 14-12-OL; In this specific case, Davis-Besse has one of the worst operating records in the industry. Thats widely known. This will actually be a very interesting test case to see if the NRC is able to deny any license. I think if any license should be denied, it would be Davis-Besse.
Comment: 16-2-OL; The Sierra Club opposes nuclear energy in its entirety, citing serious environmental health and public expense issues throughout the nuclear fuel cycle.
Comment: 14-14-OL; And I know that there are many people, thousands of people, in the Northwest Ohio area, that dont want this license renewed and think its an insane gamble with our health and safety to run this plant for another 20 years.
Comment: 14-16-OL; So, we have a lot of very educated, very well-informed speakers. And we have people that are just plain citizens that, but I think most of the people that weve scheduled to speakfeel that Davis-Besse should not be renewed. We have opened this up to the public and if anyone here wants to, to speak that hasnt been asked to already, you just need to sign up, theres a little sheet outside, Ill ask you to sign.
Comment: 18-1-OL; And Davis-Besse is about 20 miles from here. And, I have been opposed to nuclear power for a very long time. But as I was thinking about, what we are doing here today and, what I wanted to talk about today, it kept, coming back to me that I think that even if I was in favor of nuclear power, this is still a nuclear power plant that I would want shut down.
Comment: 18-7-OL; And in the face of that, in the face of that lack of responsibility and lack of planning for the future, the NRC has continued to do nothing. They just slapped them on the wrist for that, they slapped them on the wrist, they fined them. But if you look at, FirstEnergys profits, they have gone up, they have, they have never gone down, they never had to really pay for, for what they did here at Davis-Besse. They have shown, a complete lack of responsibility to the people they serve. And the NRC has failed to hold them accountable.
Comment: 18-8-OL; Now the other thing about FirstEnergy is, First Energy holds a corporate charter from here in Ohio. And I think that one of the next steps that, that we should be pushing towards is to revoke that corporate charter for FirstEnergy. They are, they are a rogue corporation. They have failed to, to provide oversight of their own facilities, and they have failed to, show any real determination to actually learn from that situation that transpired back when the, Davis-Besse almost, melted down actually. So I hope that these proceedings are the first step towards preventing, a nuclear meltdown. In the face of the failure of First Energy to be vigilant and maintain its, its facilities appropriately, and in the face of, of the failure of the Nuclear Regulatory Commission to provide adequate oversight, and I would invite each of you to be a part of that next step because certainly we must grow this movement if we are to be effective. Thank you.
Comment: 19-8-OL; And theres ongoing problems with Davis-Besse, to the present day. Id like to just share some figures for, what might happen if there were a major radioactivity release A-34
Appendix A at Davis-Besse. This comes from a 1982 NRC report entitled Calculation of Reactor Accident Consequences, or CRAC, which is a nice little acronym the NRC came up with. So, if there were a major radioactivity release from Davis-Besse, the NRC and the Sandia National Lab in New Mexico, which conducted the study, determined that there could be 1,400 peak early fatalities, they call them, 1,400 peak early fatalities, 73,000 peak early injuries, and 10,000 peak cancer deaths. And they attributed a dollar figure of 84 billion dollars for property damage. So, that study came out in 1982. NRC tried to cover it up. Congressman Ed Markey of Massachusetts, got it ousted by subpoena by holding a hearing and out came the figures. So if you increase, all those casualties due to the increase in population since 1982, if you, increase, due to inflation the, property value damages, that would go up to $185 billion dollars. And a little update to mention, just came out in, mid-September, Inside the EPA, which is a trade press, publication in Washington, DC, scooped the story that they did a freedom of information act release to the NRC, the EPA, and the Federal Emergency Management Agency, and discovered, internal e-mails between the agencies, the lawyers of the agencies, fighting with each other over a little minor detail of after a major radioactivity release who would, be in charge of the clean-up and how would it be paid for. So it turns out that the lawyers at these 3 agencies, were discussing how Price-Anderson, the national liability, coverage for major nuclear power plant accidents, will not cover the cleanup costs. It would cover other things, property damage and, and some very strictly controlled categories, but not clean up costs. So, thats a little issue.
Comment: 19-9-OL; Davis-Besse, which is deteriorated with age, has already had so many close calls, 2 major accidents. So, you can see things are pretty out of control. Anita mentioned the, NRC as a rogue agency. And we keep trying to figure out what the NRC stands for. Is it Nobody Really Cares? Is it Nuclear Rubberstamp Commission? it might be Nuclear Rubberstamp Commission, because of, the 60 license extension applications theyve considered so far, they have rubberstamped every single one of them. And, these are oldest reactors in the country with major problems.
Comment: 14-17-OL; OK, so while Als setting up, I just want to mention that, technically what these comments are going to be is part of the Environmental scoping comments for the Environmental Impact Statement, which is part of the application for the 20-year renewal. So part of that process is that if we could show that there are cheaper, safer, more environmentally friendly alternatives to doing nuclear power, to renewing this license for another 20 years, technically the NRC is supposed to say OK, youre right, nuclear power isnt that, we wont extend this, licensing application.
Comment: 22-1-OL; Water is the foundation of life. And its our most precious resource in Ohio. Nuclear energy is not needed for life here in northwest, Ohio.
Comment: 22-7-OL; Davis-Besse should not be re-licensed. The other question that has to be considered - is the safety culture within Davis-Besse changed? And if one were to assess the safety culture in personnel...Technology doesnt fail on its own, technology fails...People operate technology.
Comment: 23-2-OL; So, we urge the Commissioners to deny the 20 year relicensing. If there ever was a candidate for the first denial of a relicense, this is it. As the history of the facility proves, it is too dangerous and expensive to continue this operation, especially since it is too dangerous and expensive to continue this operation, especially since it is not needed for present or future power generation. I would like to refer the Commissioners to two articles quoting studies that support this latter statement.
Comment: 23-5-OL; Its past time to admit that we can no longer afford this complicated and dangerous technology - - not the feed-in tariff, Im referring to Davis-Besse.
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Appendix A Comment: 24-3-OL; As a very senior citizen, I would like to encourage the members of the audience who are opposing the relicensing of the plant to keep fighting. It can sometimes get discouraging, but the opposition that was mounted to the original building of nuclear plants in the 1960s and 70s did result in enough added expense for the electrical industry to put a halt to the building of new plants, although Davis-Besse was approved.
Comment: 25-1-OL;. Some people may remember me from the early 90s. I know at least Mike Leonardi was here in the room. There he is! Thats when we fought off the whole proposition to build a low level radioactive waste dump here in Ohio. Im sorry I wasnt here in the 70s to resist against the Davis-Besse, but if I lived in Ohio then, I wouldve.
Comment: 26-1-OL; We are blessed in that we live in 20% of the worlds surface freshwater here in the Great Lakes the most precious resource on the planet. Without it, life is not possible. And yet we have a nuclear power plant that has an abysmal record, Davis-Besse.
But Im here to tell you that its not about the generation of energy. Its about the concentration of wealth and power. Political economy.
Comment: 26-12-OL; Now weve got to stop the production of this material, and I say do not relicense this and the plant should be shut down immediately.
Comment: 27-2-OL; So, I just agree that they should not get relicensing whatsoever. They have done the worst job in managing this plant. They do not follow good engineering principles.
Theyre making the same mistakes all over again. They should be shut down permanently, and they should not be relicensed.
Comment: 14-18-OL; We havent done enough. We havent killed this monster yet. But, I think I had hopes that it would die a natural death. That as each plant reached the end of its operating license it would simply be pulled off the market for economic reasons. Now theyre trying to give us undead nuclear power plants. Nuclear zombie power plants.
Comment: 14-20-OL; So, I wanted to thank everyone here for keeping up the fight. And I think Kevin has one more comment about the next step would be after this comment period is over.
Well submit comments. But after this is finished then were going to have interventions. Once they grant the license. Were expecting theyll grant it. Well be able to perhaps put in one last line of defense to stop this monster. Let it die a natural death. So, heres Kevin one last time.
Comment: 31-1-OL; Hello my name is Suzanne Patser and I live in Columbus Ohio and Im very concerned about the Davis-Besse plant coming back online. I cant think of anything that would be a worse idea for our state.
Comment: 31-5-OL; So I am absolutely 100% against any nuclear plant opening anywhere. It is not the type of energy that our country needs, our State needs, that Toledo needs that anybody needs that lives or works in that area.
Comment: 33-1-OL; Hello my name is Scott Robinson from Worthington Ohio and Im opposed to the relicensing of the Davis-Besse nuclear power plant. Thank you.
Comment: 34-2-OL; It puts people in Toledo especially in danger and could possibly extend as far south as Columbus. So I really do not think that this should be renewed.
Comment: 35-1-OL; Im Emily Journey and Im from Westerville Ohio. Id like you to know that I do not support the relicensing of the Davis-Besse Atomic reactor.
Comment: 36-4-OL; So because of the ongoing contamination and the inherent nature of the radioactive contamination in the process of it being mined and transported. I would like the commission to look very closely at this and do what we all know is correct and keep Davis-Besse closed.
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Appendix A Comment: 37-1-OL; Alright. Im totally against the nuclear power. I just Im an old guy and Ive been around for many years and I know the history damages that it can cause and Im really opposed to it. Thats why Im on camera here. Thats why Im on camera and I will do whatever I can to support the cause against it. The actions, take actions against it. That what all I got to say. Thank you very much.
Comment: 38-2-OL; By all means please do not approve the relicensure of Davis-Besse.
Thank you Comment: 39-5-OL; Im very disconcerned for the future of our children and future generations in terms of the toxicity and global warming. Also we dont need this energy and it is just not a good way for our country to be going. Thank You Comment: 40-1-OL; My name is Bernadine Kent and Im from Columbus Ohio and I have been informed of the Davis-Besse power plant in Toledo. Im concerned about this plant extending their license for the next 20 years. To me that doesnt make any sense especially since they have problems.
Comment: 42-1-OL; My name is Pete Johnson Im associated with the Columbus free press and citizens alliance for secure elections and Im definitely opposed to relicensing Davis-Besse.
Comment: 43-1-OL; Basically I mean Ive heard a lot of the science about it and I cant really say a whole lot about that. But what I can say is that you its going to be relicensed supposedly for 20 more years and that would be to 2037, I believe, so Im opposed to the relicensing of Davis-Besse because I think its a youth issue and basically this is an important youth issue its important to the young people who are not allowed to vote and be politically active and children and the future generations.
Comment: 16-14-OL; Hi my name is Patricia Marida. Im the chair of the nuclear issues committee at the Ohio Sierra Club. I gave a presentation before the Nuclear Regulatory Commission on November 4, 2010, as to why the Sierra Club opposes the extension of a license at Davis-Besse.
Comment: 16-15-OL; Tonight Im going to give my personal statement. I think that its well recorded there are 10 pages of documentation of very serious violations and illegalities, and actually nuclear accidents at Davis-Besse. It is the most accident ridden power plant, nuclear power plant in the nation. It is very clear that we have a serious problem here also because the Nuclear Regulatory Commission has been very laxed in enforcing Davis-Besse. In fact allowing them to, allowing FirstEnergy and Davis-Besse Operating Company to continue operating the plant when it was supposed to be shut down for an inspection. And the reactor head came within 1/8" or metal left between containment and a nuclear holocaust. So It is very clear that the regulatory and the supervision is lacking were also would like the NRC to be sure to cover the safety issues there, there are many safety issues.
Comment: 47-1-OL; First Energy should not be allowed to continue to operate Davis-Besse after 2017. The people of Northeast Ohio are familiar with First Energys pathetic record in protecting the safety of people who live in the region.
Comment: 48-1-OL; We are area residents near the Davis-Besse plant as we live in Wood County. We would like to have this nuclear power plant eliminated. We say the article about it in our local paper, the Sentinel-Tribune. It is an old plant and has had a history of accidents/problems.
Comment: 14-14-OL, 14-16-OL, 14-17-Ol, 14-18-OL, 14-20-OL, 16-14-OL, 16-15-OL, 30-1-OL, 34-3-Ol, 34-7-OL, 39-6-OL, 39-10-OL, 43-4-OL, 44-2-OL, 50-1-OL, 51-1-OL, 52-1-OL, 53-1-OL, 54-1-OL, 55-1-OL, 56-1-OL, 57-1-OL, 58-1-OL, 59-1-OL, 60-1-OL, 61-1-OL, A-37
Appendix A 62-1-OL, 63-1-OL, 64-1-OL, 65-1-OL, 66-1-OL, 67-1-OL, 68-1-OL, 69-1-OL, 70-1-OL, 71-1-OL, 72-1-OL, 73-1-OL, 74-1-OL, 75-1-OL, 76-1-OL, 77-1-OL, 78-1-OL, 79-1-OL, 80-1-OL, 81-1-OL, 81-6-OL, 82-1-OL, 83-1-OL, 84-1-OL, 85-1-OL, 86-1-OL, 87-1-OL, 88-1-OL, 89-1-OL, 90-1-OL; Ohioans are concerned about the environment, the rising costs of energy, and the dangers associated with nuclear power! However, that has not stopped First Energy from irresponsibly pursuing to get the Davis-Besse nuclear plant on Lake Erie relicensed to continue operation until 2037.
Comment: 30-5-OL, 43-8-OL, 44-6-OL, 50-5-OL, 51-5-OL, 52-5-OL, 54-5-OL, 55-5-OL, 56-5-OL, 57-5-OL, 58-5-OL, 59-5-OL, 60-5-OL, 61-5-OL, 62-5-OL, 63-5-OL, 64-5-OL, 65-5-OL, 66-5-OL, 67-5-OL, 68-5-OL, 70-5-OL, 71-5-OL, 72-5-OL, 73-5-OL, 76-5-OL, 77-5-OL, 78-5-OL, 79-5-OL, 80-5-OL, 81-10-OL, 82-5-OL, 83-5-OL, 84-5-OL, 85-5-OL, 86-5-OL, 87-5-OL, 88-5-OL, 89-5-OL, 90-5-OL;
Dear Nuclear Regulatory Commission,
please say NO to Davis-Besse! Make them accountable for the lapses in safety and help protect Ohioans from a potential disaster at Davis-Besse.
Comment: 53-5-OL; Until nuclear power can be made safe for the environment by solving the waste problem, I do not want it to continue in operation.
Dear Nuclear Regulatory Commission,
please say NO to Davis-Besse! Make them accountable for the lapses in safety and help protect Ohioans from a potential disaster at Davis-Besse.
Comment: 69-5-OL; Now is not the time to expand nuclear energy in Ohio. Dear Nuclear Regulatory Commission, please say NO to Davis-Besse! Make them accountable for the lapses in safety and help protect Ohioans from a potential disaster at Davis-Besse.
Comment: 70-5-OL; These plants have been a financial leach on the people long enough!
Dear Nuclear Regulatory Commission,
please say NO to Davis-Besse! Make them accountable for the lapses in safety and help protect Ohioans from a potential disaster at Davis-Besse.
Comment: 74-5-OL; Davis-Besse is not safe and we seem to want to wait until something really disastrous happens before anything is donewhen it is too late! Nuclear energy is NOT clean energy and we have the perpetual problem of what to do with nuclear waste.
Dear Nuclear Regulatory Commission,
please say NO to Davis Besse! Make them accountable for the lapses in safety and help protect Ohioans from a potential disaster at Davis Besse.
Comment: 77-5-OL; Davis-Bess is far too dangerous.
Dear Nuclear Regulatory Commission,
please say NO to Davis-Besse! Make them accountable for the lapses in safety and help protect Ohioans from a potential disaster at Davis-Besse.
Comment: 81-5-OL; We are moving to Westlake, Oh. soon and dont want to have to worry about unsafe Davis-Besse blowing up near us. I have read this petition and agree with it all.
Dear Nuclear Regulatory Commission,
please say NO to Davis Besse! Make them accountable for the lapses in safety and help protect Ohioans from a potential disaster at Davis Besse.
Comment: 81-10-OL; Thank you for your prompt action on this matter for the safety and health of the People of Ohio. I have read this petition and agree with it all!!!! Dear Nuclear Regulatory Commission, please say NO to Davis-Besse! Make them accountable for the lapses in safety and help protect Ohioans from a potential disaster at Davis-Besse.
Response: These comments are general in nature and express opposition to FENOC, nuclear power, the license renewal of Davis-Besse, or all of these. The majority of these comments express opposition for reasons outside the scope of license renewal. Expanded responses to these comments are documented in the Davis-Besse Scoping Summary Report. Those comments that express opposition for in-scope reasons are documented in the applicable A-38
Appendix A technical area within this appendix. The NRC did not evaluate these comments in the development of the SEIS, as they did not provided any new and significant information.
A.1.9 Postulated Accidents & SAMA (PA)
Comment: 14-8-PA; I think an environmental review needs to look at what would happen if the concrete wall either collapsed from radiation or if the perimeter was destroyed through the attack of a plane or through the attack of some motorist or some terrorist group planting explosives. What would happen to the radioactive dust and the containment structure because of the weakening?
Comment: 16-12-PA; And, I would like to add also that the pools of radioactive waste are extremely vulnerable to terrorists attacks or to other explosions. So, that certainly should be a consideration of the NRC to look at; that is, how are we going to protect those pools of radioactive waste?
Response: These comments express concern for the potential adverse environmental impacts associated with postulated accidents. The comments also raise concerns that the GEIS and SEIS do not adequately evaluate the possible impacts of beyond-design-basis accidents initiated by terrorist attacks or sabotage. Under 10 CFR 51.53(c)(3)(ii)(L), license renewal applicants must consider alternatives to mitigate severe accidents if the staff has not previously evaluated SAMAs for the applicants plant in an environmental impact statement or related supplement or in an environmental assessment. The purpose is to ensure that potentially cost-beneficial, aging-related plant changes (i.e., hardware, procedures, and training) with the potential for improving severe accident safety performance are identified and evaluated.
An analysis was developed to support offsite consequence estimates for Level 3 probabilistic risk assessments of severe accidents at light water reactors. Such assessments have long served as the foundation for NRC regulatory decisions, which include analyses of health and safety, land contamination, and economic consequences (NRC, 2009). A description of the code that was used to perform the calculations of the offsite consequences of a severe accident for Davis-Besse can be found in NUREG/CR 6613, Code Manual for MACCS2: Volumes 1 and 2 (NRC, 1998). It is beyond the scope of the Environmental Report (ER) and the SEIS to describe in detail the codes analytical process. However, a description of the application of the MACCS2 code for the Davis-Besse analysis has been provided in the relevant portions in Appendix F of this SEIS.
The SEIS provides a site-specific evaluation of SAMAs in Chapter 5 and Appendix F. However, in the GEIS, the NRC staff did evaluate existing impact assessments performed by the NRC and by industry at 44 nuclear plants in the United States and concluded that the risk from beyond-design-basis accidents at existing nuclear power plants would be small.
With respect to spent fuel pool accidents, onsite storage of spent fuel is considered a Category 1 issue, which was evaluated in the GEIS; therefore, accidents would be encompassed by the analysis of the Category 1 issue of onsite spent fuel storage. As such, the need for mitigation alternatives within the context of renewal has been considered, and the Commission concludes that its regulatory requirements already in place provide adequate mitigation incentives for onsite storage of spent fuel. No discussion of mitigation alternatives is needed in an LRA because the Commission has generically concluded that additional site specific mitigation alternatives are unlikely to be beneficial (NRC, 1996). In addition, the NRC staff did not find any new and significant information that would call the analysis of the Category 1 issue into question.
A-39
Appendix A A detailed discussion of Postulated Accidents and SAMAs can be found in Chapter 5 and Appendix F of this SEIS.
Comment: 14-9-PA; We are in an area of the country that could be affected by the fault if there is a large earth quake, and I think this may not have been examined sufficiently in the environmental impact study.
Response: The comment expresses concern for the seismic design of Davis-Besse. The seismic design of the plant is outside the scope of the environmental review; however, structures that are in scope of license renewal are examined and the results are documented in the publication of NRCs Davis-Besse safety evaluation report (SER).
Results of prior geologic, seismologic, and subsurface investigations indicate no evidence of fault traces, offset geomorphic features, shear zones, faults, sand boils, soil flows, or any other direct or indirect physical effects of prior earthquakes. The nearest fault is the Bowling Green Fault, which is located 35 miles west of the site. Geologic, including seismic, information is presented in Chapter 2 of this SEIS.
Insofar as the comments suggest that a seismic event during the period of license renewal could result in environmental impacts, such impacts were considered as part of the SEIS discussion of severe accidents initiated by external phenomena and by the GEIS in its Review of Existing Impacts. As discussed in Chapter 5 of the draft SEIS, the NRC staff evaluated the risk of beyond-design-basis earthquakes at existing nuclear power plants, and determined that the risk from such events is SMALL; further, the NRC determined that the risks from other external events are adequately addressed by the generic consideration of internally-generated severe accidents in the GEIS, and that this issue should be considered on a site-specific basis in a plants SAMA analysis. FENOCs SAMA analysis included a search for mitigation measures for accident scenarios initiated by fire and seismic external events. A detailed discussion can be found in Chapter 5 and Appendix F of this SEIS.
Additionally, the NRC has directed operators of nuclear power plants to reaffirm their existing abilitiy to resist earthquakes and flooding as a result of the accident at the Fukushima Dai-ichi nuclear power plants in 2011. Plant-specific actions taken in reponse to lessons learned from the Fukushima Dai-ichi accident can be found at:
http://www.nrc.gov/reactors/operating/ops-experience/japan-dashboard/japan-plants.html.
A.1.10 Radioactive & Non-Radioactive Waste (RW)
Comment: 20-2-RW; Kevin already mentioned this, but, the expectation when Davis-Besse and all the other nuclear reactors were built was that would mean that there would be a federal repository for all of the high-level nuclear waste and that is not available. And as Kevin mentioned, the Yucca Mountain, facility has been, the funding for it has been discontinued, it has no operating license. That means that for 33 years, all of the high-level radioactive waste generated at Davis-Besse are still being stored on-site, initially in a cooling pool, as I understand it, and then, a few years ago, they, they constructed above-ground containers for the fuel after it cools off, in this pool. So, my, position would be that no nuclear plant license extensions should be granted until theres a long-term storage facility available for these nuclear wastes. And, one of the troubling indicators, I think, is I read through the Environmental Study that is, is mandated for this license extension.
Comment: 23-7-RW; Theres no place to put the waste and we believe that it is immoral to burden our children and generations far into the future with deadly waste.
A-40
Appendix A Comment: 24-1-RW; At that time, planning for the long term containment of the radioactive waste was to be done in the future. We now know that we still do not have any methods approved for the long term storage and isolation of the tons of spent radioactive rods and other radioactive material that is made during the mining and processing of the fuel. This material will be dangerously radioactive to humans and other living things for hundreds of thousands of years. To put that into perspective, we will be starting on the year 2011 of the common era on January 1st.
Comment: 26-11-RW; In addition there is a ISFSI. Its dry cask storage of high level nuclear waste. High level nuclear waste is currently stored outside at the Davis-Besse. This has a..there..No one wants this nuclear waste. Yucca Mountain is not going to happen. Its not geologically sound. Its not scientifically sounds. Its not going to happen. Nobody wants this stuff. Yet, the NRC runs a con game. They have confidence a waste confidence decision. It is a con game. Theyre asking the public, the folks of Toledo, of Ohio, Please accept our promise to take this waste at some point. We dont know what to do with it just yet. But, well figure it out later on. But, in the meantime just let us go and make more. Its been said that nuclear power is the gift that keeps on giving. It keeps on giving the radioactive waste, and the power is fleeting. But we are left with the deadly lethal legacy for tens of thousands of years.
Comment: 39-1-RW; My name is Connie Hammond I live in Columbus Ohio. Im a member of the Sierra Club nuclear issues committee and the Ohio Green party. My primary concern is with the toxic legacy that we are leaving for our Children and Grandchildren. Beyond the obvious radioactivity and pollution that these plants produce.
Response: These comments address concerns regarding the management of radioactive waste at the Davis-Besse site.
No new and significant information is provided in these comments. Therefore, no changes have been made to the SEIS because of these comments. The management of radiological and non-radiological waste is discussed in Chapter 2 of this SEIS. In addition, Chapter 6 of this SEIS contains information on spent nuclear fuel.
Comment: 24-4-RW; Originally nuclear power was touted as power that would be produced so cheaply that it would not even have to be metered. Now we are being told that it will solve the problem of pollution generated by using fossil fuels. We will be replacing carbon problems of pollution, generated by using fossil fuels, with problems of radioactive pollution for which there is no cleanup but time.
Comment: 36-1-RW; Hi my name is Bob Patraicus, I have a PhD in political Science. I am a JD. My concerns with Davis-Besse begin with the obvious. There has been contamination.
Radioactive contamination at that plant in the past it continues to occur. Moreover the entire process of mining transporting and allowing radioactivity as a fuel source is inherently contaminating.
Comment: 43-2-RW; A lot of the people who are working to relicense this nuclear facility are going to have died of old age by the time its finished and then when its finished we are going to need to worry about cleaning it up keeping it in repair and I dont think that people are really looking ahead to the future and considering you know the work that is going to be involved to make sure that its safe. Nuclear waste and radioactivity has a half life of gabillion years to put it in kids terminology and you know a lot of the people who are going to be effected by nuclear waste are not even born yet. And so speaking on behalf of the youth, babies, people who cannot speak for themselves. I just wanted to say that relicensing Davis-Besse and using nuclear energy is wrong. It may be expedient for the people who are only planning on living you know 10 or 20 more years then fine but they dont care if the world is going to be destroyed. But A-41
Appendix A there are people who that effects and I would just urge the people who are making this decision to think of the future generations and to be able to think about somebody other than yourselves really.
Comment: 16-4-RW; Contamination occurs throughout the milling, refining, transport and conversion of uranium to uranium hexafluoride and then enrichment in which the gaseous diffusion process took as much energy as a large city to enrich the uranium. Then additional uranium must be formulated to ground. An enormous waste - - uranium hexafluoride which is 99 percent of the original uranium but is not fissionable and, therefore, not useable for energy.
However, it is just as radioactive and must be then converted back to the more stable uranium oxide. A newly-operated plant at Piketon will take 25 years running around the clock to deconvert the 40,000, 14-ton canisters containing hexafluoride that are already on the site, and that is not counting how much more that might be generated from other conventional facilities, enormous amounts of energy due to this process.
Comment: 16-24-RW; The Sierra Club opposes nuclear energy in its entirety, citing serious environmental, health, and public expense issues throughout the nuclear fuel cycle. The time frames needed to guard the radioactive nuclear waste generated from this process are geologic in nature. Isolating the radioactive nuclear waste will consume public time and money for generations to come. The only viable solution for radioactive waste is to stop generating it.
Radioactive contamination and waste are a major reason to discontinue the use of nuclear power. The risk and reality is that radioactive contamination has occurred, is occurring and will continue to occur throughout the nuclear power cycle. Mining is leaving radioactive tailings exposed to the air and water on First Nations land in the US, Canada, and Australia.
Contamination occurs throughout the milling, refining, transport, conversion of uranium to uranium hexafluoride (UF6), and then enrichment - which in the gaseous diffusion process at Piketon, Ohio, took as much energy as a large city. Then the fissionable uranium must be formulated into rods. An enormous waste stream is the depleted uranium hexafluoride (DUF6),
which is 99% of the original uranium but is not fissionable and therefore not usable for energy.
However, it is just as radioactive and must be deconverted back to the more stable uranium oxide. A newly operating plant at Piketon will take 25 years running round-the-clock to deconvert the 40,000 14-ton canisters of DUF6 already on the site, not counting how much more will be generated from other enrichment facilities.
Comment: 32-1-RW; Hi my name is James Whitaker and Im from in Columbus Ohio and as far as the creation of more radioactive waste here in the state of Ohio I dont think we need to do that I think that the any of the fuels that we have as far as fossil fuels is adequate if its done properly. But I certainly dont want to create more nuclear waste.
Comment: 16-18-RW; So the fleeting use of electricity in the past has left us with a legacy of nuclear waste. But however we understand that the Nuclear Regulatory Commission does not have to even consider that when they are deciding whether or not to license Davis-Besse because in the past the Nuclear Regulatory Commission has made a decision that they are not going to, that this doesnt have anything to do with a new license despite the fact that much more of this dangerous radioactivity is going to be stored at the plant there is no solution for it there is no magic solution that will turn lead into gold it will remain radioactive for millions of years and will gradually spread itself around. It is so important for the Nuclear Regulatory Commission to look at issues of the onsite storage and to look at containing at least in the near future making this waste safe. The new waste is going to be generated there really does need to be a plan for isolating it onsite. We are not asking for a plan to isolate it for a hundred million years because we all know thats an impossibility. We are asking for some sort of a plan working with Doctor Arjun Makhijani of the Institute for Environmental and Economic Research in Washington DC, we are asking for you the NRC to work with him and look at some serious A-42
Appendix A ways of isolating this waste in canister that are hidden in bunkers where they are safe from terrorist attack.
Comment: 30-3-RW, 34-5-RW, 39-8-RW, 43-6-RW, 44-4-RW, 50-3-RW, 51-3-RW, 52-3-RW, 53-3-RW, 54-3-RW, 55-3-RW, 56-3-RW, 57-3-RW, 58-3-RW, 59-3-RW, 60-3-RW, 61-3-RW, 62-3-RW, 63-3-RW, 64-3-RW, 65-3-RW, 66-3-RW, 67-3-RW, 68-3-RW, 69-3-RW, 70-3-RW, 71-3-RW, 72-3-RW, 73-3-RW, 74-3-RW, 75-3-RW, 76-3-RW, 77-3-RW, 78-3-RW, 79-3-RW, 80-3-RW, 81-3-RW, 81-8-RW, 82-3-RW, 83-3-RW, 84-3-RW, 85-3-RW, 86-3-RW, 87-3-RW, 88-3-RW, 89-3-RW, 90-3-RW; NUCLEAR ENERGY IS NOT CLEAN OR GREEN ENERGY!
Every nuclear reactor generates about 20 tons of highly radioactive waste per year, and after 40 years of nuclear power, the U.S. still has not found an acceptable solution for the waste. The waste can cause cancer, birth defects, and even death. Nuclear power uses and pollutes significant amounts of water, while the mining, transportation, and enriching of uranium is carbon intensive which contributes to global warming.
Response: These comments express concern over the uranium fuel cycle and of the management of nuclear waste. The environmental impacts of the uranium fuel cycle and solid waste management are contained in Chapter 6 of this SEIS.
No new and significant information is provided in these comments. Therefore, no changes have been made to the SEIS because of these comments.
A.1.11 Socioeconomics (SE)
Comment: 1-1-SE; Good afternoon. My name is Mark Stahl, and Im the President of Ottawa County Commissioners. Ottawa County is successful because we surround ourselves with successful community partners, and Davis-Besse is one of those community partners, who we look very favorably upon. You will hear from some other agencies, the nonprofits, the contributions that you make back to our community helps us tremendously, and we greatly appreciate that. We also as Commissioners appreciate our NRC partnership. We have had conversations with you, I know, through the years, and we appreciate those unbiased conversations that weve had in regard to Davis-Besse.
Comment: 2-3-SE; Many of the Davis-Besse employees live in the community and are important assets to Ottawa County. I think its very important that the corporate structure thats been put in place to oversee the operations of Davis-Besse continue, and I think its a good structure.
Comment: 4-1-SE; Im Chris Galvin, Director of the United Way in Ottawa County. The Davis-Besse Nuclear Power Station and on a larger scale the First Energy Corporation are a tremendous community partner to the local United Way. Since 1993, First Energy has contributed more than 13.5 million dollars to United Way of Greater Toledo which serves Ottawa, Wood and Lucas Counties. 3.1 million came from corporate gifts, 10.4 million from its incredibly generous employees. First Energy has also earned United Ways Pillar Award each year since at least 1992. Our data doesnt go back any further than that. It seems they consistently give more than a hundred thousand dollars each year to the Greater Toledo campaign. Not only does this community consistently get solid financial support from First Energy and its employees, but executive leadership has also demonstrated exceptional personal commitment to our work. In 1993, Don Saunders chaired the local United Way campaign, raising 12.5 million Dollars. In 2005, Jim Murray, now retired, but formerly First Energy President of Ohio Operations, chaired the local United Way campaign. Under Mr. Murrays leadership, the campaign raised 13.3 million Dollars. We also presented A-43
Appendix A Mr. Murray with our Prestigious Caring Award in 2006 for demonstrating value and concern for our community through vision, leadership, service and commitment to the people of our community. In 2009, Trent Smith, Regional President of Toledo Edison First Energy, became chairman of the United Way of Greater Toledos Board of Trustees and has drawn to a close on his second year of service. Mr. Smith has gone above and beyond the level of service, dedication and commitment we typically see from board chairs. He has become involved in virtually every level of our work, digging in and helping find real solutions. In addition to these executive leaders, numerous upper-level management have supported United Way by using their voice and relationships to help secure financial and volunteer support as well as advocating on behalf of the United Way and the Northwest Ohio Region. In addition to Don Saunders, Jim Murray, and Trent Smith, some of the stand-out employees include Debbie Paul, Mike Adams, and Mel Lomack. Additionally, in the 1990s Jennifer Schreiber served five years as the chair of our community impact cabinet, the highest level of community impact volunteers who decide how money is allocated in this community. Also joining her on the cabinet was Jenny Ammadon. Both are not retired. First Energy also demonstrates incredible commitment to the communities through sponsorships and/or participation in programs and events. In 1993 and 1994, Davis-Besse sponsored our loaned executive program. Jim Ferris, now retired from Davis-Besse, was the landed executive in those two years. First Energy has also sponsored loaned executives over the years, from 1996 continuing for 11 years. Employees consistently contribute to and participate in Stamp Out Hunger and/or Scouting for Food efforts each year. They were a major sponsor of our Family Food Fund in 2008. First Energy was the sponsor of our Community Building event in 2005, and was the initiator and sponsor of the Veterans Appreciation Event in 2006, which continued until 2009.
Comment: 5-1-SE; On behalf of the Union, I would like to voice our support in this public. A renewal of this license will not only promote and maintain employment for our members who live and shop and send their children to school in that area, but it will also assure the delivery of reliable electric service to our customers.
Comment: 8-2-SE; We also because we have the mandate but we do not receive government funds, I can speak to what Chris Galvin of United Way said with regards to the money that comes into the United Way. We are a United Way Agency, but even besides that, we have profited, the Red Cross organization, from financial support on many levels from First Energy and Davis-Besse as well as from the volunteer aspect of the employees that respond through the involvement of their families. We have three or four blood drives that we conduct at Davis-Besse that are very successful. We have had a lot of leadership that has come out of the Davis-Besse plant. Chuck Witt was a six-year chairman for our local advisory board. Currently, Terry Mortis, who is the Regional Manager also of the Ottawa County District with First Energy that provides a lot of leadership, a lot of guidance to the Red Cross.
Comment: 9-2-SE; Davis-Besse over the years has provided a good living, a good income for many residents of Ottawa County and surrounding counties and especially now in a time when unemployment is high.
Comment: 10-1-SE; Davis-Besse has been very generous with their donations to the Food Pantry in the past years. I also would like to say that if it were to close, they may be coming to our Food Pantry, and I would hate to see that.
Comment: 11-2-SE; It is also important from a license renewal aspect, 20 additional years of this asset to provide for the employment opportunities for the local community, and many of our young engineers are graduating from college today who wonder if nuclear power is a viable A-44
Appendix A future and a career path. Its important to know that plants such as Davis-Besse and others are undergoing renewal process have a future that they can depend on.
Comment: 12-4-SE; By extending the license here at Davis-Besse, it would continue to provide good clean power thats critical. In addition to that, also supporting the much-needed tax base, not only to this area but to the State, and Im confident along with our members, that IBEW, Local 245, that Davis-Besse will continue to be safe, not only for the employees but also for the area.
Comment: 1-3-SE; And, the county isnt successful unless youre surrounded by successful community partners, and I can tell you that Brush-Romley (ph) is one of those partners. They contribute tremendously to the good of this community. We also cherish the NRCs partnership that we have. You are our eyes and our ears. You are what helps us maintain the public safety here, and we appreciate that as well.
Comment: 2-5-SE; So Ive had some broad experience with the Davis-Besse people and with the Nuclear Regulatory Commission, and I think this process and the processes that the NRC uses are great processes, but I think its important to know that when we look at what Davis-Besse has done over the years and how they have responded to Ottawa County as a community, we couldnt have asked for anything more.
Comment: 15-2-SE; The renewal of this license will promote maintaining employment of not only our members who live and shop and send their children to the schools in this area, but it will also ensure the delivery of reliable electric service to all of our customers.
Comment: 11-5-SE; We have long-term employment opportunities for the surrounding communities. Younger engineers graduating from college need to know that the nuclear power is very efficient and is a great career. Davis-Besse has a significant impact on the economy of the local area, providing folks, several hundred people employment, providing materials and service in support of the operation of the plant. We have always had a commitment to ensure public safety and a protection of the environment, and that commitment continues today. As you have already heard from several of those speakers, we enjoy a good relationship with the surrounding communities, and we look forward to sustaining this relationship for an additional 20 years.
Comment: 4-3-SE; The Davis Besse Nuclear Power Station, and on a larger scale, the First Energy Corporation, are the tremendous community partner to the local United Way.
Since 1993, First Energy has contributed more than $13.5 million to United Way of Greater Toledo which serves Ottawa, Wood, and Lucas counties. $3.1 million came from corporate gifts. $10.4 million from its incredibly generous employees: First Energy has also earned United Ways Pillar Award each year since at least 1992...which means they consistently give more than $100,000 each year to the greater Toledo campaign. Not only does this community consistently get solid financial support from First Energy and its employees, but executive leadership has also demonstrated exceptional personal commitment to our work. In 1993, Don Saunders chaired the local United Way campaign, raising $12.5 million. In 2005, Jim Murray, now retired, but formerly First Energy President of Ohio Operations, chaired the local United Way campaign. Under Mr. Murrays leadership, the campaign raised $13.3 million.
We also presented Mr. Murray with our prestigious Spirit of Caring award in 2006 for demonstrating value and concern for our community through vision, leadership, service, and commitment to the people of our community. In 2009, Trent Smith, regional president of Toledo Edison/First Energy, became chairman of United Way of Greater Toledos Board of Trustees and is drawing to a close on his second year of service. Mr. Smith has gone above and beyond the level of service, dedication, and commitment we typically see from Board chairs. He has become involved in virtually every level of our work, digging in and helping find real solutions. In A-45
Appendix A addition to these executive leaders, numerous upper level management have supported United Way by using their voice and relationships to help secure financial and volunteer support as well as advocating on behalf of United Way and the NW Ohio region. In addition to Don Saunders, Jim Murray, and Trent Smith, some of these standout employees include Debbie Paul, Meg Adams, and Mel Womack. Additionally, in the 1990s, Jennifer Shriver served five years as the chair of our Community Impact Cabinet, the highest level of community impact volunteers who decide how money is allocated in the community. Also joining her on the cabinet was Jenny Amidon. Both are now retired. First Energy also demonstrates incredible commitment to the community through sponsorships of or participation in programs and events.
In 1993 and 1994, Davis Besse sponsored our Loaned Executive program, a program that provides United Way with temporary campaign employees. First Energy began sponsoring this program in 1996 and continued for 11 years. Employees consistently contribute to and participate in Stamp Out Hunger and/or Scouting for Food efforts each year. They were a major sponsor of our Family Food Fund in 2008. First Energy was a sponsor of our Community Building Event in 2005 and was the initiator and sponsor of our Veterans Appreciation Event in 2006 which continued until 2009.
Comment: 15-6-SE; A renewal of this license will promote and maintain employment of not only our members, who live and shop and send their children to schools in this area, but...it will assure the delivery of reliable electric service to all our customers.
Comment: 25-5-SE; And economically, as we all know, and others have testified to, nuclear power does not make economic sense. In as much as our economy is the management of our household, I think it relates directly to the ecology of our house or our State or our community here, and that ecological system that we are all part of and that this nuclear power plant and the NRC and the other governmental leaders and the other citizens that arent here, that ecosystem is very much a part of the environment, and any hearing that focuses on environmental impacts has to include all of that as the one ecosystem or environmental that were in.
Response: These comments concern the socioeconomic impact of Davis-Besse. The majority of the comments are supportive of license renewal, the applicant, in general, and describe the socioeconomic benefits of Davis-Besse. Comment 25-5-SE expresses opposition to license renewal because of the environmental costs. The socioeconomic impacts of renewing the Davis-Besse operating license are discussed in Chapters 2 and 4. In addition, the socioeconomic impact of not renewing the operating license (no action alternative) is discussed in Chapter 8.
A.1.12 Support of License Renewal (SL)
Comment: 1-2-SL; So, I will let these two gentlemen fill you in, but as President of the Ottawa County Commissioners, Im here to offer our support to you, Davis-Besse, in your application process.
Comment: 2-4-SL; We look forward to a license renewal. Ottawa County wants Davis-Besse to stay, and welcome them in the future and urge the NRC to move forward with this license renewal.
Comment: 3-2-SL; So, really, all this adds up to the fact that our relationship in Ottawa County with Davis-Besse is a benefit to the residents of Ottawa County Comment: 4-2-SL; Davis-Besse and First Energy are a valued community partner, both philanthropically and economically. They have been incredible contributors to our community over the past 20 years, and we only hope that this will continue for at least another 20 years.
A-46
Appendix A Comment: 6-3-SL; So, it is opinion of the Black Swamp Bird Observatory that the Davis-Besse Nuclear Power Plant is a critical player in bird conservation in the entire region of the western hemisphere.
Comment: 8-3-SL; I ask hard questions and I sometimes like the answers, sometimes Im not so sure about the answers, but I am confident in the safety of the Davis-Besse plant and the good that it does in the community for the people that are involved.
Comment: 9-3-SL; We support the license renewal, and we ask the NRC to support it as well.
Comment: 12-2-SL; In addition to that, we not only work out local issues but something more important or just as important. We work together on issues in Washington also through our labor management committee. A lot of people probably arent aware of that, but we do that through our Land Pact Committee.
Comment: 1-4-SL; With that said, were going to have a few people from the Agency describe what Davis-Besse does for Ottawa County, and on behalf of the Ottawa County Commissioners, I would like to extend our full support in regards to their application.
Comment: 15-1-SL; And, on behalf of the Union, I would like to voice our support at this public meeting for a multitude of reasons.
Comment: 11-4-SL; This effort is important to us for several reasons. This licensing extension will allow us to continue to provide safe, reliable environmentally friendly electricity to our customers for years to come. Davis-Besse is an important asset, and the Companys generation portfolio shows we have a good mix of power generation service.
Comment: 4-4-SL; Davis Besse and First Energy are a valued community partner, both philanthropically and economically. They have been incredible contributors to our community over the past 20 years and we only hope this will continue for at least another 20.
Comment: 15-5-SL; My name is Jane Ridenour and I am President of OPEIU Local 19.
OPEIU stands for Office & Professional Employees International Union and we represent the clerical support staff at Davis Besse. On behalf of the Union Id like to voice our support at this public meeting.
Response: These comments are general in nature and express support for nuclear power or the license renewal of Davis-Besse or both. The comments provide no new and significant information and will not be evaluated further.
A.1.13 Terrestrial Resources (TR)
Comment: 6-1-TR; Our organization has been conducting migratory bird regions in this area for more than 20 years, and we really take pride in this marriage, and we work hard like a good spouse to maintain it. The marsh represents a critical stop-over habitat for millions of migratory birds. And, in fact, many the worlds leading bird experts consider this marsh to be one of the most critical areas of stop-over habitat in the entire western hemisphere.
Comment: 6-2-TR; The observatory in these 20 years have had the full support of First Energy and Davis-Besse to conduct this critical research and, in fact, during a very exciting tumultuous time in this countrys history, we were very afraid that our consistent effort meaning that seven days a week, spring and fall, during song bird migration, our research staff was out at that marsh in front of the power tank conducting this research seven days a week for more than 20 years. When the tragedy occurred on 9/11, we were very concerned for, of course, the human tragedy, but also concerned that our research would be interrupted. And, in fact, A-47
Appendix A Davis-Besse really fully understood the importance of this research, and the importance of conserving the integrity of the data set, and we didnt miss a single day. And, perhaps nothing else, no other event in our history or recent history speaks more to how much they have said they understand the critical role that they play in local environmental and conservation issues than that event. So, based on our long-standing relationship, it is our opinion the Davis-Besse and First Energy have not only worked to fully understand and fully support the environmental issues for this local community, but have also fully embraced the role that they play in all of these issues.
Response: The NRC staff agrees with the Black Swamp Bird Observatory in its characterization of Davis-Besse marsh habitat as critical stop-over habitat. Additionally, the NRC staff incorporated the Black Swamp Bird Observatorys publically available research publications into Chapter 2 of the draft SEIS.
Comment: 45-1-TR; There are no Federal wilderness areas or designated critical habitat within the vicinity of the proposed site. Davis-Besse consists of 954 acres, of which approximately 733 acres are marshland that is leased to the U.S. Government as part of the Ottawa National Wildlife Refuge. In a letter dated December 16, 2009, we provided comments to FENOC on the proposed 20-year renewal of the operating license for Davis-Besse. At this time we have no additional comments.
Response: The NRC staff incorporated the U.S. Fish and Wildlife Services information provided in this comment into the draft SEIS, including the information in the referenced December 16, 2009, letter to FENOC, which was provided in Appendix C of FENOCs ER.
A.2 Comment Letters and Meeting Transcripts The following pages contain the comments, identified by commenter designation (from Table A-1) and comment number, from letters, e-mails, public scoping meeting transcripts and the transcript from the Peoples Hearing.
A-48
Appendix A COMMENTER: MARK STAHL 1-1-SE 1-2-SL A-49
Appendix A COMMENTER: JERE WITT 2-1-OS A-50
Appendix A 2-1-OS continued 2-2-OS A-51
Appendix A 2-2-OS continued 2-3-SE A-52
Appendix A COMMENTER: FRED PETERSEN 2-4-SL 3-1-OS A-53
Appendix A 3-1-OS continued A-54
Appendix A COMMENTER: CHRIS GALVIN 3-1-OS continued 3-2-SL 4-1-SE A-55
Appendix A 4-1-SE continued A-56
Appendix A 4-1-SE continued A-57
Appendix A COMMENTER: JACKIE VANTRESS 4-1-SE continued 4-2-SL A-58
Appendix A COMMENTER: KIMBERLY KAUFMAN 5-1-SE 5-2-AL 5-3-OS A-59
Appendix A 6-1-TR 6-2-TR A-60
Appendix A 6-2-TR continued 6-3-SL A-61
Appendix A COMMENTER: STEVE INCHAK 6-3-SL continued 7-1-OL 7-2-OS A-62
Appendix A 7-2-OS continued A-63
Appendix A 7-2-OS continued A-64
Appendix A 7-2-OS continued A-65
Appendix A 7-2-OS continued A-66
Appendix A COMMENTER: BETH LEGGETT 7-2-OS continued 8-1-OS A-67
Appendix A 8-1-OS continued 8-2-SE A-68
Appendix A COMMENTER: BRAD GOETZ 8-3-SL 9-1-OS A-69
Appendix A COMMENTER: ANN HECKERD 9-1-OS continued 9-2-SE 9-3-SL 10-1-SE A-70
Appendix A COMMENTER: BRIAN BOLES 11-1-AL 11-2-SE 11-3-OS A-71
Appendix A COMMENTER: LARRY TSCHERNE 11-3-OS continued A-72
Appendix A 12-1-OS A-73
Appendix A 12-2-SL 12-3-AL 12-4-SE 12-5-OS A-74
Appendix A COMMENTER: MARK STAHL 1-3-SE 1-4-SL A-75
Appendix A COMMENTER: JERE WITT 1-4-SL continued 2-5-SE 2-6-OS A-76
Appendix A COMMENTER: MIKE DRUSBACKY 2-6-OS continued A-77
Appendix A 13-1-OS A-78
Appendix A COMMENTER: JOSEPH DEMARE 13-1-OS continued 14-1-LR A-79
Appendix A 14-1-LR continued 14-2-OS 14-3-AQ 14-4-HH A-80
Appendix A 14-4-HH continued 14-5-OS 14-6-OS 14-7-OS A-81
Appendix A 14-8-PA 14-9-PA 14-10-HH A-82
Appendix A COMMENTER: JANE RIDENOUR 14-10-HH continued 14-11-OS 14-12-OL A-83
Appendix A 15-1-SL 15-2-SE 15-3-AL 15-4-OS A-84
Appendix A COMMENTER: PATRICIA MARIDA 16-1-LR 16-2-OL 16-3-OS A-85
Appendix A 16-3-OS continued 16-4-RW 16-5-AM A-86
Appendix A 16-6-AL 16-7-AM 16-8-AL A-87
Appendix A 16-8-AL continued 16-9-OS 16-10-OS A-88
Appendix A 16-10-OS continued 16-11-OS A-89
Appendix A 16-11-OS continued 16-12-PA 16-13-OS A-90
Appendix A COMMENTER: BRIAN BOLES 11-4-SL 11-5-SE A-91
Appendix A COMMENTER: MATTHEW HEYRMAN 11-5-SE continued 17-1-OS A-92
Appendix A 17-1-OS continued A-93
Appendix A A-94
Appendix A COMMENTER: JOSEPH DEMARE 14-13-LR A-95
Appendix A COMMENTER: ANITA RIOS 14-14-OL 14-15-LR 14-16-OL A-96
Appendix A 18-1-OL 18-2-OS 18-3-LR A-97
Appendix A 18-4-LR 18-5-OS 18-6-OS A-98
Appendix A 18-6-OS continued 18-7-OL 18-8-OL A-99
Appendix A COMMENTER: KEVIN KAMPS 18-8-OL continued A-100
Appendix A 19-1-OS A-101
Appendix A 19-1-OS continued 19-2-OS 19-3-OS 19-4-OS 19-5-OS A-102
Appendix A 19-5-OS continued 19-6-OS A-103
Appendix A 19-6-OS continued 19-7-OS A-104
Appendix A 19-7-OL continued 19-8-OL A-105
Appendix A 19-9-OL A-106
Appendix A 19-10-AQ 19-11-AL A-107
Appendix A COMMENTER: JOSEPH DEMARE 19-11-AL continued 14-17-OL A-108
Appendix A COMMENTER: AL COMPAAN 20-1-AL A-109
Appendix A 20-2-RW 20-3-HY 20-4-HH A-110
Appendix A 20-4-HH continued 20-5-OS 20-6-AL A-111
Appendix A 20-6-AL continued 20-7-AL 20-8-AL A-112
Appendix A 20-8-AL continued 20-9-AL A-113
Appendix A 20-9-AL continued 20-10-AL A-114
Appendix A 20-10-AL continued 20-11-AL A-115
Appendix A 20-11-AL continued 20-12-AL A-116
Appendix A COMMENTER: KATIE HOEPFL 21-1-AL A-117
Appendix A 21-2-AL A-118
Appendix A 21-2-AL continued 21-3-AL A-119
Appendix A COMMENTER: TONY SZILAGYE 21-3-AL continued 22-1-OL 22-2-AQ A-120
Appendix A 22-2-AQ continued 22-3-AQ A-121
Appendix A 22-4-HH 22-5-AQ 22-6-OS A-122
Appendix A 22-6-OS continued 22-7-OL 22-8-OS 22-9-AL A-123
Appendix A COMMENTER: ED MCARDLE 22-9-AL continued 23-1-LR A-124
Appendix A 23-2-OL 23-3-AL 23-4-AL A-125
Appendix A 23-4-AL continued A-126
Appendix A 23-4-AL (continued) 23-5-OL 23-6-AM 23-7-RW A-127
Appendix A churches, individuals, etc. So this is really the most effective thing that we can do, and we need to do this.
Thank You. (Applause)
Ms. Rios Okay, just to let you know, we have um one, four more speakers scheduled and I don't think we're going to have anybody else coming in um if we have somebody else coming in we'll certainly accomodate them. But then we wiU be able to take a break to share information, and also to let you know that one of the things that we're hoping to do today, before you all leave is that Kevin has um some information that um.. He has a contention. Which is a part of the next process in front of you. The process after we oppose the licensing.
But those of us who live within fifty miles of Davis-Besse have to validate what Kevin and Beyond Nuclear are saying for that for them to have standing. We'll talk about that. We'll bring Kevin up again before we finish up so that he can explain that process so that those of us who are willing to go ahead and sign on to his contentions.
Mr. DeMare (interrupting)
Uh Anita?
Yes?
Mr. DeMare Um we need to swap out our video card. It will take about 5 minutes.
Ms. Rios A-128
Appendix A COMMENTER: PHYLLIS OSTER 24-1-RW 24-2-OS A-129
Appendix A COMMENTER: DAVIS ELLISON 24-2-OS continued 24-3-OL 24-4-RW A-130
Appendix A 25-1-OL 25-2-LR A-131
Appendix A 25-2-LR continued 25-3-OS 25-4-AL A-132
Appendix A COMMENTER: MICHAEL KEEGAN 25-5-SE A-133
Appendix A 26-1-OL 26-2-LR 26-3-OS A-134
Appendix A 26-3-OS continued 26-4-LR 26-5-HH 26-6-HY A-135
Appendix A 26-6-HY continued 26-7-HH (HY) 26-8-OS 26-9-AQ A-136
Appendix A 26-9-AQ continued 26-10-LR 26-11-RW A-137
Appendix A COMMENTER: RALPH SEMROCK 26-11-RW continued 26-12-OL 27-1-OS A-138
Appendix A 27-1-OS continued A-139
Appendix A 27-1-OS continued A-140
Appendix A COMMENTER: MIKE LEONARDI 27-1-OS continued 27-2-OL A-141
Appendix A 28-1-HH A-142
Appendix A 28-1-HH continued 28-2-HH A-143
Appendix A COMMENTER: JOSEPH DEMARE 28-3-LR 14-18-OL A-144
Appendix A COMMENTER: UNIDENTIFIABLE WOMAN 29-1-AQ A-145
Appendix A 29-2-AQ 29-3-HH A-146
Appendix A COMMENTER: JOSEPH DEMARE 29-4-AQ 14-19-HH A-147
Appendix A COMMENTER: KEVIN KAMPS 14-19-HH continued 14-20-OL A-148
Appendix A So on this intervention deadline, we face a December 27th deadline to file our contentions, our intervention against the 20 year license extension. It's also the deadline for environmental scoping comments.
Umm.. the um Federal Register Notice appeared on October 24th. They have a very short window of Intervention opportunity of sixty days which fell on December 24th which is an official holiday, and the technical rule is the next business day. That becomes the deadline. That's December 27th. So, it's an indication, gives you an idea of how brutal the NRC's process is. That extends right into the technical requirements of intervening.
One of those is to obtain standing, and that's the main thing I'd like to talk about. Anyone who lives within 50 miles of Davis-Besse could, almost automatica11y, receive Standing to be a Party to this proceeding.
And it's important for a group like Beyond Nuclear. We do not live that close, we're about 500 miles away. So for us to enter a contention and get standing, we're gonna need supporters in the local area. And if you're a member of another environmental group you could encourage that group to join with Beyond Nuclear and become a Party to the proceedings as well.
So if you are interested and you do live within 50 miles, please afterwards come see me. I'd love to get your contact information. We can discuss it further. You don't need to decide today.
It's a simple form; it's a one sheet form. We already have the language.
Not with us; we didn't have enough time to pull it together. But we've used it in other proceedings like Fermi III, like Pallisades, and all you have to do is agree to it. It gets you individual standing, and it also gets organizations standing. We can actually file this paperwork in time.
And, um just to close, I would like to say that Italy was mentioned, and I took a lot of inspiration several years ago from (if I pronounce it A-149
Appendix A correctly) Scanzano, Italy where Berlesconi came out of the blue and said, "We've figured out where we're going to put all the nucJear waste.
We're going to put it in Scanzono." Just announced it one day, and within couple weeks, there were hundreds of thousands of people in the streets: blocking the train tracks; occupying the site that was targeted; and um two weeks later, Berlesconi said, "Well, we're going to study it some more." (Jaughter from audience) He reversed himself.
In Germany, what I was getting to here, in Germany the Angela Merkle Government has reneged on a ten year old agreement called the "nuclear consensus" that the Social Democrats and the Greens prioritized to phase out nuclear power plants at the end of their operating Jicenses. And so, what Merkle has done is to push for extensions at certain of the reactors.
Just like as proposed at Davis.:.Besse. And what this has led to is just incredibly large protests in the streets.
Several months ago, 120,000, 150,000 people formed a human chain between two nuclear power plants. It stretched 75 miles long. More recently, a few months back, about 100,000 people in the streets of Berlin, protesting the license extensions.
Then most recently, there's annual protests against radioactive waste shipments to um they call it a "centralized interim storage site." A warehouse which is right next door to a targeted deep geological disposal site. What a coincidence, Ha! And every year there's protests. I was there in 2001 there were 10,000 protestors 15,000 police.
So, it takes police state tactics to move a few containers of waste. At a huge cost. We're talking $100,000,000 for one of these shipments. And this past protest was 50,000 people.
So, I just wanted to leave on the hopeful note that, in other places where license extensions are proposed there are huge groundswells of opposition. So, inspiring stuff. Thanks. (Applause)
A-150
Appendix A A-151
Appendix A COMMENTER: SUZANNE PATSER, JAMES WHITAKER Suzanne Patser Hello my name is Suzanne Patser and I live in Columbus Ohio and Im very concerned about the Davis-Besse plant coming back online. I cant think of 31-1-OL anything that would be a worse idea for our state.
I believe that we have plenty of electricity. We do not need to bring this power plant back online. I dont care how many jobs you think it might create or how much you want to justify the expense of building the plant to begin with but 31-2-OS nothing is worth the lives of the people that are going to live near that plant and all of us because its going to affect everybody if there was any type of accident.
I know there is always just radioactive leakage anyway that we arent even told about.
There are so many other clean ways to provide energy. Wind Solar geothermal there is no reason to bring a nuclear plant online. There would have to be 31-3-AL some other agenda involved we hope that is not military agenda. But we know that we dont the electricity from that plant in this state.
And we know that it had a hole in a very vulnerable spot earlier. We dont trust the people that run these type of plants that the safety is there and regardless if it takes a million years to get rid of radioactive waste how is that a benefit to 31-4-OS anybody and human kind or on this planet.
So I am absolutely 100% against any nuclear plant opening anywhere. It is not the type of energy that our country needs, our state need, that Toledo needs 31-5-OL that anybody needs that lives or works in that area.
James Whitaker Hi my names is James Whitaker and Im from in Columbus Ohio and as far as the creation of more radioactive waste here in the state of Ohio I dont think we 32-1-RW need to do that I think that the any of the fuels that we have as far as fossil fuels is adequate if its done properly. But I certainly dont want to create more nuclear waste.
A-152
Appendix A COMMENTER: SCOTT ROBINSON, SIMONE MORGEN, EMILY JOURNEY, BOB PATRAICUS Scott Robinson 33-1-OL Hello my name is Scott Robinson from Worthington Ohio and Im opposed to the relicensing of the Davis-Besse nuclear power plant. Thank you.
Simone Morgen Hi my name is Simone Morgen Im a Columbus resident and I just want to say that a facility such as Davis Besse that has had numerous failures cumulating in that lovely hole that endangered people with a possible meltdown has no 34-1-OS business having a renewal without stringent oversight if it should have renewal at all.
It puts people in Toledo especially in danger and could possibly extend as far south as Columbus. So I really do not think that this should be renewed. 34-2-OL Emily Journey Im Emily Journey and Im from Westerville Ohio. Id like you to know that I do 35-1-OL not support the relicensing of the Davis-Besse Atomic reactor.
I believe we should be going in different directions when it comes to supplying energy to our communities. Direction that is not destructive that can provide new 35-2-AL green jobs. Thank You.
Bob Patraicus Hi my name is Bob Patraicus, I have a PhD in political Science. I am a JD. My concerns with Davis-Besse begin with the obvious. There has been contamination. Radioactive contamination at that plant in the past it continues to 36-1-RW occur.
Moreover the entire process of mining transporting and allowing radioactivity as a fuel source is inherently contaminating.
It is located there on the great lakes, the largest clean water source in the world and it seems extremely dangerous and unnecessary since there is other 36-2-AL alternative fuel sources to allow for Davis-Besse to ever be reopened with its incredibly bad history safety history with its dome.
36-3-OS A-153
Appendix A COMMENTER: BOB PATRAICUS, KEVIN MALCOLM, DOUG TODD, CONNIE HAMMOND Bob Patraicus (continued)
So because of the ongoing contamination and the inherent nature of the radioactive contamination in the process of it being mined and transported. I 36-4-OL would like the commission to look very closely at this and do what we all know is correct and keep Davis-Besse closed.
Kevin Malcolm Alright. Im totally against the nuclear power. I just Im an old guy and Ive been around for many years and I know the history damages that it can cause and Im really opposed to it. Thats why Im on camera here. Thats why Im on camera 37-1-OL and I will do whatever I can to support the cause against it. The actions, take actions against it. That what all I got to say. Thank you very much.
My name is Kevin Malcolm Jones originally from Cleveland Ohio but Ive been here in Columbus for 6 years.
Doug Todd Hi my name is Doug Todd Im from Columbus Ohio. Im very concerned about the Davis-Besse Plant. From what little I know the most recent containment 38-1-OS failure a few years ago was a result of laxed inspection. Im aware that FirstEnergy had requested a delay in inspection on the plant. And it was this delay that almost led to the containment break down which would have been a Chernobyl type disaster for Northern Ohio. By all means please do not approve the relicensure of Davis-Besse. Thank You 38-2-OL Connie Hammond My name is Connie Hammond I live in Columbus Ohio. Im a member of the Sierra Club nuclear issues committee and the Ohio Green party. My primary 39-1-RW concern is with the toxic legacy that we are leaving for our Children and Grandchildren. Beyond the obvious radioactivity and pollution that these plants produce.
The process of production of nuclear energy from mining through disposal of 39-2-AM waste is very carbon intensive and would contribute heavily to global warming.
A-154
Appendix A COMMENTER: BERNADINE KENT, UNKNOWN, PETE JOHNSON Connie Hammond (continued)
We need to invest our money into green technologies that would create job and also help our economy which is leaving the toxic legacy for our children as well 39-3-AL as these nuclear power plants.
Davis-Besse is not a safe plant it has a very bad track record and the Nuclear Regulatory Commission has been laxed in its inspections. I really am concerned 39-4-OS Im very disconcerned for the future of our children and future generations in terms of the toxicity and global warming. Also we dont need this energy and it is 39-5-OL just not a good way for our country to be going. Thank You Bernadine Kent My name is Bernadine Kent and Im from Columbus Ohio and I have been informed of the Davis-Besse power plant in Toledo. Im concerned about this 40-1-OL plant extending their license for the next 20 years. To me that doesnt make any sense especially since they have problems.
Rather than extending the license there should be some type of investigation or some kind of attempt to resolve these problems instead of just saying ok for the next 20 years these problems can continue. So my concern is that anyone that anyone that would allow this license to continue is not acting in the best interest 40-2-OS of the citizens.
Unknown I wish to join the wave of the future. Which is alternative energy sources. Fossil fuels and nuclear energy are part of the past. 41-1-AL Pete Johnson My name is Pete Johnson Im associated with the Columbus free press and 42-1-OL citizens alliance for secure elections and Im definitely opposed to relicensing Davis-Besse.
Its dangerous, its been mismanaged for a long time and Im definitely opposed to the relicensure of Davis-Besse. Thank you. I live in Franklin County, Ohio. 42-2-OS A-155
Appendix A COMMENTER: CONSTANCE GADWELL-NEWTON ESQ Constance Gadwell-Newton Esq This is Connie Gadwell-Newton Im an attorney. Im active with the Ohio Green party and I wanted to express my opposition to the relicensing of Davis-Besse for 20 years.
Basically I mean Ive heard a lot of the science about it and I cant really say a whole lot about that. But what I can say is that you know its going to be relicensed supposedly for 20 more years and that would be to 2037, I believe, so Im opposed to the relicensing of Davis-Besse because I think its a youth issue 43-1-OL and basically this is an important youth issue its important to the young people who are not allowed to vote and be politically active and children and the future generations. A lot of the people who are working to relicense this nuclear facility are going to have died of old age by the time its finished and then when its finished we are going to need to worry about cleaning it up keeping it in repair and I dont think that people are really looking ahead to the future and considering you know the work that going to be involved to make sure that its safe.
Nuclear waste and radioactivity has a half life of gabillion years to put it in kids terminology and you know a lot of the people who are going to be effected by 43-2-RW nuclear waste are not even born yet. And So speaking on behalf of the youth, babies, people who cannot speak for themselves. I just wanted to say that relicensing Davis-Besse and using nuclear energy is wrong. It may be expedient so for the people who are only planning on living you know 10 or 20 more years then fine but they dont care if the world is going to be destroyed. But there are people who that effects and I would just urge the people who are making this decision to think of the future generations and to be able to think about somebody other than yourselves really.
Yeah I want to make a statement on behalf of kids whose environment is being destroyed. There used to be a lot more nature to go to and tromp around in and now kids dont have that we have urban environments that are polluted kids getting cancer because of this kind of stuff and its really not ok. So this is Connie Gadwell Newton urging you to not renew the licensing for Davis-Besse. 43-3-HH Thank you.
A-156
Appendix A COMMENTER: PATRICIA MARIDA Patricia Marida Hi my name is Patricia Marida. Im the chair of the nuclear issues committee at the Ohio Sierra Club. I gave a presentation before the Nuclear Regulatory 16-14-OL Commission on November 4, 2010 as to why the Sierra Club opposes the extension of a license at Davis-Besse.
Tonight Im going to give my personal statement. I think that its well recorded there are 10 pages of documentation of very serious violations and illegalities, and actually nuclear accidents at Davis-Besse. It is the most accident ridden power plant, nuclear power plant in the nation. It is very clear that we have a serious problem here also because the Nuclear Regulatory Commission has been very laxed in enforcing Davis-Besse. In fact allowing them to, allowing 16-15-OL FirstEnergy and Davis-Besse Operating Company to continue operating the plant when it was supposed to be shut down for an inspection. And the reactor head came within 1/8 of metal left between containment and a nuclear holocaust. So It is very clear that the regulatory and the supervision is lacking were also would like the NRC to be sure to cover the safety issues there, there are many safety issues.
Apparently when an accident, when there is an alarm there is no response.
People say oh thats just a false alarm. So no one seems to get very excited, 16-16-OS when an alarm goes off at Davis-Besse.
We are also concerned about fish and Lake Erie and the heat coming out of the 16-17-AQ plant.
Even more we are concerned about the possibility of contamination of all the water in the great lakes from a reactor accident. This would be a nightmarish So the fleeting use of electricity in the past has left us with a legacy of nuclear waste. But However we understand that the nuclear regulatory commission does not have to even consider that when they are deciding whether or not to license Davis-Besse because in the past the Nuclear Regulatory Commission has made a decision that they are not going to, that this doesnt have anything to do with a 16-18-RW new license despite the fact that much more of this dangerous radioactivity is going to be stored at the plant there is no solution for it there is no magic solution that will turn lead into gold it will remain radioactive for millions of years and will gradually spread itself around. It is so important for the Nuclear Regulatory Commission to look at issues of the onsite storage and to look at containing and at least in the near future making this waste safe. The new waste is going to be generated there A-157
Appendix A Patricia Marida (continued) really does need to be a plan for isolating it onsite. We are not asking for a plan to isolate it for a hundred million years because we all know thats an impossibility.
16-18-RW We are asking for some sort of a plan working with Doctor Arjune Macajohny of continued the institute for environmental and economic research in Washington DC, we are asking for you the NRC to work with him and look at some serious ways of isolating this waste in canister that are hidden in bunkers where they are safe from terrorist attack.
So this fleeting use of electricity when we dont even need any more electricity. 16-19-OS What happened when Davis-Besse was shut down? We got along fine.
We are closing down Coal plants now because Ohio is actually using less electricity than they used to. Weve got efficiency weve got solar we have wind 16-20-AL we have geothermal we have all kinds of sustainable ways.
We dont need more nuclear power and we need to have the Nuclear Regulatory Commission look at wether or not more electric is needed especially the large 16-21-OS amount that Davis-Besse produces because we think it could be shut down today we think it should be shut down today.
Dr. David Lochbaum has sent you a very well documented statement as to why that this plant needs to be shut down now, it is dangerous to operate and the NRC dismissed it out of hand with what Dr. Lauchbaum characterized as 16-22-OS superfluous reasons.
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Appendix A COMMENTER: PATRICIA MARIDA A-159
Appendix A 16-23-LR 16-24-RW 16-25-LR 16-26-AM A-160
Appendix A 16-27-AL 16-28-AL 16-29-OS 16-30-OS 16-31-OS 16-32-LR 16-33-OS 16-34-OS A-161
Appendix A COMMENTER: LEE BLACKBURN 44-1-LR A-162
Appendix A COMMENTER: MARY KNAPP 45-1-TR 45-2-AQ A-163
Appendix A COMMENTER: JOHN P. FROMAN 46-1-AR A-164
Appendix A COMMENTER: CHRIS GALVIN 4-3-SE A-165
Appendix A 4-3-SE continued 4-4-SL A-166
Appendix A COMMENTER: JANE RIDENOUR 15-5-SL 15-6-SE 15-7-AL 15-8-OS A-167
Appendix A COMMENTER: JOSEPH DEMARE 14-21-AM A-168
Appendix A COMMENTER: DENNIS KUCINICH 47-1-OL 47-2-OS A-169
Appendix A 47-2-OS continued COMMENTER: MARILYN & PAUL NESSER A-170
Appendix A 48-1-OL A-171
Appendix A COMMENTER: JESSICA LILLIAN WEINBERG 49-1-LR A-172
Appendix A 49-1-LR continued A-173
Appendix A COMMENTER: ERIC BRITTON 30-1-OL 30-2-OS 30-3-RW 30-4-AL 30-5-OL A-174
Appendix A COMMENTER: MATT TROKAN 90-1-OL 90-2-OS 90-3-RW 90-4-AL 90-5-OL A-175
Appendix A COMMENTER: LEE BLACKBURN 44-2-OL 44-3-OS 44-4-RW 44-5-AL 44-6-OL A-176
Appendix A COMMENTER: BOB GREENBAUM 59-1-OL 59-2-OS 59-3-RW 59-4-AL 59-5-OL A-177
Appendix A COMMENTER: ROBERT KYLE 71-1-OL 71-2-OS 71-3-RW 71-4-AL 71-5-OL A-178
Appendix A COMMENTER: TIM WAGNER 78-1-OL 78-2-OS 78-3-RW 78-4-AL 78-5-OL A-179
Appendix A COMMENTER: JIM WAGNER 75-1-OL 75-2-OS 75-3-RW 75-4-AL 75-5-OL A-180
Appendix A COMMENTER: SANDY BIHN 58-1-OL 58-2-OS 58-3-RW 58-4-AL 58-5-OL A-181
Appendix A COMMENTER: ELISA YOUNG 89-1-OL 89-2-OS 89-3-RW 89-4-AL 89-5-OL A-182
Appendix A COMMENTER: LINDA MILLIGAN 88-1-OL 88-2-OS 88-3-RW 88-4-AL 88-5-OL A-183
Appendix A COMMENTER: CONNIE HAMMOND 39-6-OL 39-7-OS 39-8-RW 39-9-AL 39-10-OL A-184
Appendix A COMMENTER: PAUL WOJOSKI 87-1-OL 87-2-OS 87-3-RW 87-4-AL 87-5-OL A-185
Appendix A COMMENTER: CAROL RAINEY 60-1-OL 60-2-OS 60-3-RW 60-4-AL 60-5-OL A-186
Appendix A COMMENTER: MARGARET HOLFINGER 66-1-OL 66-2-OS 66-3-RW 66-4-AL 66-5-OL A-187
Appendix A COMMENTER: SIMONE MORGEN 34-3-OL 34-4-OS 34-5-RW 34-6-AL 34-7-OL A-188
Appendix A COMMENTER: CONSTANCE GADWELL-NEWTON ESQ 43-4-OL 43-5-OS 43-6-RW 43-7-AL 43-8-OL A-189
Appendix A COMMENTER: MARY BETH LOHSE 80-1-OL 80-2-OS 80-3-RW 80-4-AL 80-5-OL A-190
Appendix A COMMENTER: JEAN PUCHSTEIN 57-1-OL 57-2-OS 57-3-RW 57-4-AL 57-5-OL A-191
Appendix A COMMENTER: ANDY TROKAN 72-1-OL 72-2-OS 72-3-RW 72-4-AL 72-5-OL A-192
Appendix A COMMENTER: CHRISTIAN GEORGE 51-1-OL 51-2-OS 51-3-RW 51-4-AL 51-5-OL A-193
Appendix A COMMENTER: DONNA EMIG 82-1-OL 82-2-OS 82-3-RW 82-4-AL 82-5-OL A-194
Appendix A COMMENTER: BEN SHAPIRO 67-1-OL 67-2-OS 67-3-RW 67-4-AL 67-5-OL A-195
Appendix A COMMENTER: NICK MELLIS 86-1-OL 86-2-OS 86-3-RW 86-4-AL 86-5-OL A-196
Appendix A COMMENTER: KATHLEEN BODNAR 65-1-OL 65-2-OS 65-3-RW 65-4-AL 65-5-OL A-197
Appendix A COMMENTER: JOAN DELAURO 73-1-OL 73-2-OS 73-3-RW 73-4-AL 73-5-OL A-198
Appendix A COMMENTER: VIRGINIA DOUGLAS 79-1-OL 79-2-OS 79-3-RW 79-4-AL 79-5-OL A-199
Appendix A COMMENTER: JUNE DOUGLAS 76-1-OL 76-2-OS 76-3-RW 76-4-AL 76-5-OL A-200
Appendix A COMMENTER: JEREMY BANTZ 55-1-OL 55-2-OS 55-3-RW 55-4-AL 55-5-OL A-201
Appendix A COMMENTER: LEEZA PERRY 54-1-OL 54-2-OS 54-3-RW 54-4-AL 54-5-OL A-202
Appendix A COMMENTER: LANCE WILSON 84-1-OL 84-2-OS 84-3-RW 84-4-AL 84-5-OL A-203
Appendix A COMMENTER: ERIKA AGNER 50-1-OL 50-2-OS 50-3-RW 50-4-AL 50-5-OL A-204
Appendix A COMMENTER: LIZ LORING 83-1-OL 83-2-OS 83-3-RW 83-4-AL 83-5-OL A-205
Appendix A COMMENTER: CATE RENNER 62-1-OL 62-2-OS 62-3-RW 62-4-AL 62-5-OL A-206
Appendix A COMMENTER: GEORGE M WILLIAMS 81-1-OL 81-2-OS 81-3-RW 81-4-AL 81-5-OL A-207
Appendix A COMMENTER: AMANDA BALDINO 52-1-OL 52-2-OS 52-3-RW 52-4-AL 52-5-OL A-208
Appendix A COMMENTER: JOAN LANG 74-1-OL 74-2-OS 74-3-RW 74-4-AL 74-5-OL A-209
Appendix A COMMENTER: SUSAN JONES 68-1-OL 68-2-OS 68-3-RW 68-4-AL 68-5-OL A-210
Appendix A COMMENTER: GEORGE M WILLIAMS 81-6-OL 81-7-OS 81-8-RW 81-9-AL 81-10-OL A-211
Appendix A COMMENTER: LEONARD BILDSTEIN 61-1-OL 61-2-OS 61-3-RW 61-4-AL 61-5-OL A-212
Appendix A COMMENTER: MIKE FREMONT 85-1-OL 85-2-OS 85-3-RW 85-4-AL 85-5-OL A-213
Appendix A COMMENTER: STEPHEN & CONNIE CARUSO 70-1-OL 70-2-OS 70-3-RW 70-4-AL 70-5-OL A-214
Appendix A COMMENTER: LESLIE STANSBERY 69-1-OL 69-2-OS 69-3-RW 69-4-AL 69-5-OL A-215
Appendix A COMMENTER: KAREN HANSEN 63-1-OL 63-2-OS 63-3-RW 63-4-AL 63-5-OL A-216
Appendix A COMMENTER: INEZ GEORGE 53-1-OL 53-2-OS 53-3-RW 53-4-AL 53-5-OL A-217
Appendix A COMMENTER: NATALIE SCHAFRATH 64-1-OL 64-2-OS 64-3-RW 64-4-AL 64-5-OL A-218
Appendix A COMMENTER: DAVID GREENE 56-1-OL 56-2-OS 56-3-RW 56-4-AL 56-5-OL A-219
Appendix A COMMENTER: TEKLA LEWIN 77-1-OL 77-2-OS 77-3-RW 77-4-AL 77-5-OL A-220
Appendix A A.3 Comments Received on Draft Supplemental Environmental Impact Statement On February 26, 2014, the NRC issued the Generic Environmental Impact Statement for License Renewal of Nuclear Power Plants, Supplement 52, Regarding Davis-Besse Nuclear Power Station, Draft Report for Comment (SEIS). The NRC staff distributed the draft SEIS to Federal, tribal, state, local governmental agencies, the applicant, and interested members of the public listed in Chapter 11, Mailing List. As part of the process to collect comments on the draft SEIS, the staff:
- Placed a copy of the draft SEIS on the license renewal Web site, http://www.nrc.gov/reactors/operating/licensing/renewal/applications/
davis-besse.html.
- Provided a copy of the draft SEIS to the Toledo-Lucas County Public Library in Toledo, Ohio, and to the Ida Rupp Public Library in Port Clinton, Ohio.
- Published a notice of availability of the draft SEIS in the Federal Register on March 7, 2014 (79 FR 13079).
- Held two public meetings on March 25, 2014, at the Camp Perry Conference Center in Port Clinton, Ohio, to describe the results of the environmental review and provide the public with an opportunity to provide oral comments.
The staff has reviewed the transcripts from the public meetings and the written comments submitted via Regulations.gov. All of the comments are available on line at the NRC Public Document Room (using ADAMS) or at the NRCs Public Document Room at the NRCs Headquarters in Rockville, Maryland, using the appropriate ADAMS accession number shown in Table A-4.
Each commenter was given a unique identifier, so that comments could be traced back to the author. Table A-4 lists the individuals who provided comments on the draft SEIS and their identifiers. The individuals are listed in the order in which they spoke at the public meetings and in the order received for written comments.
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Appendix A Table A-4. Commenters on the Draft Supplemental Environmental Impact Statement Each commenter is identified along with their affiliation and how their comments were submitted.
Commenter Affiliation ID Comment Source ADAMS Accession Number (a)
John Q. Public Resident 1 Afternoon Transcript ML14097A254 Victoria Clemons Resident 2a Afternoon Transcript ML14097A254 Copy of e-mail 2b submitted at Public ML14098A027 Meeting Letter 2c ML14112A075 Guy Parmigian Superintendent - 3a Afternoon Transcript ML14097A254 Benton-Carroll-Salem School District 3b Evening Transcript ML14097A253 Brad Goetz International 4 Afternoon Transcript ML14097A254 Brotherhood of Electrical Workers (IBEW), Local 1413 Jodi Regal President, Board of 5 Afternoon Transcript ML14097A254 Ottawa County Commissioners Larry Tscherne IBEW, Local 245 6 Afternoon Transcript ML14097A254 Ron Donnal GEM, Inc. 7 Afternoon Transcript ML14097A254 Bill Buckles Plumbers and 8 Afternoon Transcript ML14097A254 Steamfitters and Service Mechanics, NW Ohio Brian Dicken Vice President of 9 Afternoon Transcript ML14097A254 Public Affairs, Toledo Regional Chamber of Commerce Chuck McCune IBEW, Local 8 10a Afternoon Transcript ML14097A254 10b Evening Transcript ML14097A253 Connie Kline No Affiliation Given 11 Afternoon Transcript ML14097A254 A-222
Appendix A Commenter Affiliation ID Comment Source ADAMS Accession Number Mike Jay Toledo Regional 12 Evening Transcript ML14097A253 Growth Partnership and Jobs Ohio Northwest Jamie Beyer Director, Ottawa 13 Evening Transcript ML14097A253 Grant County Improvement Corp.
Copy of the ML14098A024 statement read at (b) meeting Terry Lodge Beyond Nuclear, 14a Evening Transcript ML14097A253 Dont Waste Michigan, the 14b Copy of the ML14098A026 Citizens Alliance of statement read at Southwestern Ohio (b) meeting Dan Rutt No Affiliation Given 15 Evening Transcript ML14097A253 Copy of the ML14098A025 statement read at (b) meeting Michael Leonardi No Affiliation Given 16a Evening Transcript ML14097A253 16b E-mail ML14122A026 Joseph DeMare No Affiliation Given 17a Evening Transcript ML14097A253 17b Letter ML14122A019 Michael Keegan Dont Waste 18a Evening Transcript ML14097A253 Michigan 18b E-mail ML14122A032 Pat Marida Ohio Sierra Club, 19a Evening Transcript ML14097A253 Nuclear Free Committee 19b Sierra Club ML14098A028 (c)
Information Pages 19c Letter ML14122A021 Alicia Rivers No Affiliation Given 20 Evening Transcript ML14097A253 Valerie Crow No Affiliation Given 21 Evening Transcript ML14097A253 Kevin Gar No Affiliation Given 22 Evening Transcript ML14097A253 Melissa Powell Resident 23 Letter ML14091A247 A-223
Appendix A Commenter Affiliation ID Comment Source ADAMS Accession Number Paul Resident 24 Letter ML14098A023 Szymanowski Kenneth A. U.S. EPA Region 5 25 Letter ML14113A425 Westlake FENOC FirstEnergy Nuclear 26 Letter ML14113A214 (Ray Lieb) Operating Company Anthony Szilagye No Affiliation Given 27 E-mail ML14122A020 Jim Sherman No Affiliation Given 28 E-mail ML14122A022 Bill Katakis No Affiliation Given 29 E-mail ML14122A023 Kathy Barnes No Affiliation Given 30 E-mail ML14122A024 Connie No Affiliation Given 31 E-mail ML14122A025 Hammond Kevin Kamps Beyond Nuclear 32a E-mail ML14122A027 32b E-mail ML14122A028 32c E-mail ML14122A029 32d E-mail ML14122A030 32e E-mail ML14122A031 (a)
This gentleman did not want to provide his name for the transcripts, and when asked, he stated his name was John Q. Public.
(b)
This copy was provided after the evening public meeting and is identical to statement in the transcript.
(c)
Informational material related to Sierra Clubs Nuclear Free Campaign that was provided at the evening public meeting. The staff did not provide responses to this informational material because it is generic to the nuclear industry.
Comments received on the draft SEIS were placed into one of the technical issue categories, which are based on the issues that are contained in this SEIS. These technical issue categories and their abbreviation codes are presented in Table A-5.
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Appendix A Table A-5. Technical Issue Categories Comments were divided into one of the categories below, each of which has a unique abbreviation code.
Technical Issue Code Alternative Energy Sources AL Air & Meteorology AM Aquatic Resources AQ Cumulative Impacts CI Cultural Resources CR Human Health HH (a)
Hydrology HY License Renewal & Its Process LR (a)
Land Use LU (a)
Noise NO Opposition to License Renewal OL (b)
Outside of Scope OS Postulated Accidents & SAMA PA Radioactive & Non-radioactive Waste RW (a)
Socioeconomics SE Support of License Renewal SL Terrestrial Resources TR (a)
No comments specific to the categories of hydrology, land use, noise, and socioeconomics were submitted during the comment period for reviewing the draft SEIS.
(b)
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 planning; safety; security; terrorism; and spent nuclear fuel storage and disposal.
A.3.1 Alternative Energy Sources (AL)
Comment 11-1: Mine is also a question, so I dont know if you will be able to answer it now.
Was the recently approved wind farm in Herndon and Logan Counties, I dont see how it could have been factored in to the Environmental Impact Statement, because it was just approved by the Ohio Power Siting Commission last week, I believe. It is a 300 megawatt wind farm. Are you familiar with this at all, or is this something you are unfamiliar with?
Response: This question is referring to the Scioto Ridge Wind Farm and transmission lines in Hardin and Logan Counties in Ohio. The Ohio Power Siting Board (OPSB) granted a Certificate A-225
Appendix A of Environmental Compatibility and Public Need for this project on March 17, 2014. This project was considered in the combination alternative in Chapter 8 of this SEIS. When the SEIS was published as a draft, the Scioto Ridge Wind Farm project was included in the total of Megawatts (MW) for projects that were awaiting approval by the OPSB. Section 8.2 has been revised to reflect the change in MW for projects that have been approved by OPSB and that are pending before the OPSB (OPSB 2014).
Comment 17a-2: Another error in judgement [sic], a number of the comments on the original Environmental Impact Statement, talked about the cost, the high cost of nuclear power compared to the cost of solar power, and wind power which have both continued, solar and wind, to become more and more inexpensive. They have been getting cheaper and cheaper over the past four years, at an accelerating rate, while the cost of nuclear has been increasing.
When asked to consider this, in the report the author say that cost is not considered in the DEIS because that is not part of what they are supposed to do.
Comment 17a-7: And finally, one of the things that we are contending, Im representing the Ohio Green Party, and we are part of the contention process, is that alternative energy can replace Davis-Besse, we do not need the Davis-Besse generation. And there was talk, earlier, about 700 jobs here. Well, there are 3,000 jobs at risk in Perrisburg, at the First Solar Plant.
We are at a point where we have to choose. Will we choose clean energy sources, like solar and wind, with thousands, tens of thousands of jobs, or will we continue to use nuclear power with hundreds and dozens of jobs?
Comment 17b-14: There are many errors of fact in this document, but the most important is the NRC staffs assertion that the power generated by Davis-Besse cannot be replaced by clean sources of electrical generation such as wind and solar. This is one of the Contentions raised by the Intervenors (The Green Party of Ohio, Beyond Nuclear, the Citizens Environment Alliance of Southwestern Ontario, and Dont Waste Michigan) in opposition to the initial application of FENOC for a license renewal. The Intervenors presented testimony and research demonstrating that wind and solar power, with or without energy storage technologies could reliably replace the power generated by Davis-Besse. The Atomic Safety Licensing Board (ASLB) reviewed the evidence supplied by the Intervenors and agreed to hear their contentions.
The Nuclear Regulatory Commissioners then took the unprecedented step of overruling the ASLB and throwing out the Intervenors contention. The Commissioners based this action on the pragmatic belief that neither wind nor solar nor any storage technology will be sufficiently advanced to replace DB in 2017, when its license expires, almost exactly three years from now.
Comment 17b-15: The Commissioners and the NRC Staff are wrong, and their error is being clearly and decisively demonstrated in Denmark. In 2013, wind power alone provided 33.2% of that countrys electricity demand. With an installed capacity of almost 5,000 MW, Denmark has successfully integrated wind power, despite its intermittency, by having wind farms that cover a wide area, and the ability to export power to neighboring countries when it is producing excess.
In fact, during a wind storm in December, 2013, the nation of Denmark met more than 100% of its needs from wind power alone, and exported the excess to neighboring countries. Denmark has had to upgrade its grid, in order to shift loads and demands quickly and efficiently. Our country is capable of making the same improvements. There is no technical reason FENOC could not do the same as Denmark.
Comment 18a-1: What was particularly lacking, and bothersome, is how alternative energy was pooh pooed, and cant have it, cant -- wont be baseload. And yet we are seeing it, it is happening now in real time.
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Appendix A Comment 18a-2: The alternative of First Energy seeking out alternative energy that they dont generate, that they could bring in through the grid, was not brought into consideration. This is a self-serving economic game here. And theres vested interest. I understand there are a lot of good jobs, paying jobs. But there will be more jobs in a renewable and alternative kind of economy, because those jobs are labor intensive.
Comment 18b-1: We did participate back in the scoping process. And as I review the SDEIS, they sliced and diced away my comments, but didnt seem to adequately address them, in my mind. What was particularly lacking, and bothersome, is how alternative energy was pooh pooed, and cant have it, cant -- wont be baseload. And yet we are seeing it, it is happening now in real time.
In mid March a company came forward and said they were going to be building 300 megawatts of wind energy in Ohio and it would be up within 12 to 18 months. It is doable.
Also in mid March, 2014 the PJM Interconnect grid, the largest grid in the U.S. said they could easily accommodate 30 percent wind and solar brought onto the grid.
Comment 18b-2: It was well known to Pennsylvania Jersey Maryland Interconnect covering 13 states and nations [sic] largest Interconnect has known and published since this 2010 report that Wind and Solar are available in abundance and that there is no disruption or destabilizing of baseload grid. Replacement power was available in 2010 and is available now and certainly in 2017. The NRC Commission Order of March 27, 2012 must be reversed because they are simply wrong. Within FENOCs own system there are 14,000 MW. With [sic] FENOC is selling to wholesale markets electricity which is not needed on the grid. FENOC could easily retire Davis-Besse and meet that loss of power generation from within their own system. This amounts to gaming of the system to rationalize the need for the Davis-Besse license renewal.
Please review FENOC 10 K to learn how they game the system. For the NRC Commission to reverse Contention 1,2,3 calling for reasonable look at Alternatives amounts to the NRC Commission aiding and abetting the rigid status quo.
Comment 18b-3: The alternative of First Energy seeking out alternative energy that they dont generate, that they could bring in through the grid, was not brought into consideration. This is a self-serving economic game here at the detriment of FENOC ratepayers. We understand that theres [people with a] vested interest who are obstructing introduction of renewable and alternatives of wind and solar. We understand that there are a lot of good paying jobs. But there will be more jobs in a renewable and alternative economy, because those jobs are labor intensive. Whereas jobs in the nuclear industry are capital intensive, you get very few jobs for the money you spend. This has not adequately been considered.
Comment 19a-2: So in reviewing the supplement, the NRC must revisit contentions that the electricity can be readily replaced. And we have heard others talk about this. But we are asking that the NRC review Emory Levens, and Mahajanis articles and books, on how both carbon and nuclear can be replaced with renewables by 2050.
Comment 19c-12: It is increasing clear that a combination of wind, solar and efficiency could replace Davis-Besse by 2017. In addition to these, other alternative energy sources such as geothermal heating and cooling are increasing in popularity. The public is also undertaking an increasing number of conservation measures. The NRC has failed to keep up with the rapidly increasing ability of safer renewables technology and efficiency to supplant the need for the Davis-Besse reactor.
Comment 21-3: We act like there is some kind of a lack of ways to move forward, but we have renewable energy, we can generate enough power.
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Appendix A Comment 23-2: In the Supplemental Generic Environmental Impact Statement it said that alternative forms of energy were considered but not evaluated further. I dont understand this.
Other forms of alternative energy are great alternatives to a form of energy that has a potential to cause grave harm to local residents.
Comment 27-1: Adequate alternatives do exist to replace the capacity of Davis Bessie [sic].
The combination of renewable solar and wind with the decreased demand in electricity resulting from savings from energy efficiency are more than sufficient to replace the capacity of Davis Bessie [sic]. A good example of what is possible can be learned from recent developments in wind energy.
Comment 29-1: They refuse to build, own, or operate wind farms, which are by far the cheapest new energy source that can be built, but they love nuclear, which is the most expensive and dangerous form of energy generation that can be built.
Comment 32a-4: Mark Cooper, an energy economist at Vermont Law School, warned on April 10, 2014 that nuclear utilities must plan for replacement power - as from efficiency upgrades and development of renewable sources of electricity - in advance of the inevitability that atomic reactors will one day close, lest our electric grids lurch from crisis to crisis. In fact, in July 2013, Cooper identified Davis-Besse as one of a dozen reactors most at risk of near-term shut down, due to a variety of factors, including economic factors (cost, old age, stand alone status, and only a 25-year future even if it gets an extension), operational factors (lack of reliability, long-term outages), as well as multiple safety factors. (see Exhibit ES-1: Retirement Risk Factors of the Nuclear Fleet, page iv, posted online at http://216.30.191.148/
071713%20VLS%20Cooper%20at%20risk%20reactor%20report%20FINAL1.pdf).
Response: These comments relate to the use of renewable energy in place of nuclear power.
Consistent with 10 CFR 51.91(a)(1) and 51.91(b), in Chapter 8 of the SEIS, the NRC evaluates potential replacement power alternatives to Davis-Besse license renewal, including a discreet alternative that considers energy production generated from a combination of wind energy, solar energy, compressed air energy storage, and natural gas. In the NRC staffs best professional opinion, an alternative capable of producing as much baseload power as Davis-Besse and which relied more significantly or exclusively on wind or solar energy was not deemed to be a reasonable option at this time.
The NRC ultimately does not make the decision regarding which alternative (including the proposed action) to implement as part of its NEPA review, since that decision falls to utility and other energy-planning decision-makers. Comparing the environmental effects of the analyzed alternatives in Chapter 8 assists the NRC in deciding whether the adverse environmental impacts of license renewal are so great that preserving the option of license renewal for energy-planning decision-makers would be unreasonable (10 CFR 51.95(c)(4)). If the NRC decides to issue a renewed license, all of the alternatives, including the proposed action, will be available to energy-planning decision-makers. If the NRC decides not to renew the license (the no action alternative), then energy-planning decision-makers will need to replace Davis-Besse with another energy source, which may or may not be one of the alternatives considered in Chapter 8.
These comments provide no new information. Therefore, no changes were made to the SEIS as a result of these comments.
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Appendix A A.3.2 Air and Meteorology (AM)
Comment 20-2: Is there a mechanism that will absolutely guarantee us that Lake Erie will not have that same experience from some of the climate change that we are likely to experience here? Second, it seems to me that based on the uncertainty that we are facing, with the changes that are going to come about, as our climate changes, we cant be sure of anything.
And that if there is something that we could depend on, it would be that things would get better if we would reduce risks.
Response: Changes in climate have the potential to affect air and water resources, ecological resources, and human health, and are taken into consideration when evaluating cumulative impacts over the license renewal term. Because of the implications for global climate change, staff reviewed the impact greenhouse gas emissions have on the environment as it relates to energy production. Section 6.2 of the SEIS describes greenhouse gas emissions from continued plant operation and compares the emissions to coal, natural gas, and renewable energy sources.
No new information is presented in this comment. Therefore, no changes were made to the SEIS as a result of this comment.
Comment 25-4: The Draft SEIS does not identify any air quality impacts as a result of the proposed refurbishment projects. While EPA recognizes that Ottawa County is an attainment area for all criteria pollutants, we expect construction equipment used during refurbishment activities to emit diesel emissions. The National Institute for Occupational Safety and Health (NIOSH) has determined that diesel exhaust is a potential occupational carcinogen, based on a combination of chemical, genotoxicity, and carcinogenicity data. In addition, acute exposures to diesel exhaust have been linked to health problems such as eye and nose irritation, headaches, nausea, asthma, and other respiratory system issues.
Recommendations: Although every construction site is unique, common actions can reduce exposure to diesel exhaust. EPA recommends that the applicant and NRC commit to the following actions during construction in the Final SEIS and license:
- Using low-sulfur diesel fuel (15 parts per million sulfur maximum) in construction vehicles and equipment.
- Retrofitting engines with an exhaust filtration device to capture diesel particulate matter before it enters the construction site.
- Positioning the exhaust pipe so that diesel fumes are directed away from the operator and nearby workers, thereby reducing the fume concentration to which personnel are exposed.
- Using catalytic converters to reduce carbon monoxide, aldehydes, and hydrocarbons in diesel fumes. These devices must be used with low sulfur fuels.
- Ventilating wherever diesel equipment operates indoors. Roof vents, open doors and windows, roof fans, or other mechanical systems help move fresh air through work areas. As buildings under construction are gradually enclosed, remember that fumes from diesel equipment operating indoors can build up to dangerous levels without adequate ventilation.
A-229
Appendix A
- Attaching a hose to the tailpipe of diesel vehicles running indoors and exhaust the fumes outside, where they cannot re-enter the workplace.
Inspect hoses regularly for defects and damage.
- Using enclosed, climate-controlled cabs pressurized and equipped with high efficiency particulate air (HEPA) filters to reduce the operators exposure to diesel fumes. Pressurization ensures that air moves from inside to outside.
HEPA filters ensure that any incoming air is filtered first.
- Regularly maintaining diesel engines, which is essential to keep exhaust emissions low. Follow the manufacturers recommended maintenance schedule and procedures. Smoke color can signal the need for maintenance.
For example, blue/black smoke indicates that an engine requires servicing or tuning.
- Reducing exposure through work practices and training, such as turning off engines when vehicles are stopped for more than a few minutes, training diesel-equipment operators to perform routine inspection, and maintaining filtration devices.
- Purchasing new vehicles that are equipped with the most advanced emission control systems available.
- Using electric starting aids such as block heaters with older vehicles to warm the engine reduces diesel emissions.
- Using respirators, which are only an interim measure to control exposure to diesel emissions. In most cases, an N95 respirator is adequate. Workers must be trained and fit-tested before they wear respirators. Depending on work being conducted, and if oil is present, concentrations of particulates present will determine the efficiency and type of mask and respirator.
Personnel familiar with the selection care and use of respirators must perform the fit testing. Respirators must bear a NIOSH approval number. Never use paper masks or surgical masks without NIOSH approval numbers.
Response: The commenter states that the Draft SEIS did not identify air quality impacts due to the proposed refurbishment activities associated with license renewal. The published Draft SEIS discussed potential air quality impacts from refurbishment activities in Sections 3.2.10 and 4.2 of the SEIS. Section 3.2.10 of the SEIS identifies that main contributors to air quality impacts associated with completed and ongoing refurbishment activities would be fugitive dust generation from facility construction activities, refurbishment work to open the shield building and containment vessel to replace the steam generators and related equipment, and exhaust emissions from motorized equipment and vehicles of temporary workers.
Furthermore, as concluded in Section 3.2.10, estimated vehicle exhaust emissions from the additional needed workforce would not exceed de minimis levels. Since the screening analysis presented in Section 3.2.10 did not exceed the de minimis levels, a conformity determination is not required and it is unlikely that emissions from refurbishment activities would have affected a nonattainment or maintenance area or cause or contribute to any new violation of National Ambient Air Quality Standards.
The commenter is also concerned about the exposure of diesel exhaust during refurbishment activities involving construction equipment and identifies actions the NRC and applicant should commit to, to mitigate impacts from diesel exhaust exposure. Based on its limited statutory authority under the Atomic Energy Act, NRC cannot impose mitigation measures or standards on its nuclear power plant licensees that are not related to public health and safety from A-230
Appendix A radiological hazards or common defense and security. These actions and recommendations identified are outside the NRCs statutory authority. Nevertheless, licensees are required to comply with all applicable Federal, State, and local permit requirements relevant to their activities. Chapter 3 of the SEIS describes the activities that the licensee identified in the ER as refurbishment activities but have subsequently been completed in the years since the ER was submitted in 2010. The last of the activities identified as refurbishment, steam generator replacement, was completed during the spring 2014 refueling outage.
No new information is presented in this comment. Therefore, no changes were made to the SEIS as a result of this comment.
Comment 26-56: The DSEIS states that the various studies it reviewed show that the relatively lower order of magnitude of GHG emissions from nuclear power, when compared to fossil fueled alternatives (especially natural gas), could potentially disappear if available uranium ore grades drop sufficiently . . . (Emphasis added.) This statement is speculative, apparently based on worst-case assumptions, and a review of the data presented in Table 6.2-2 reveals it to be unsupported. See, e.g., POST (2006) (referenced and described in Table 6.2-2). FENOC recommends deleting this sentence.
Response: The NRC staff relied on current available information in discussing its independent analysis of Greenhouse Gas Emissions in Section 6.2 of the SEIS. Tables 6.2-1, 6.2-2, and 6.2-3 present a sampling and wide range of studies of lifecycle GHG emissions estimates of various electricity generation technologies. The statement the commenter identifies is supported by Mortimer (1990), Storm van Leeuwen and Smith (2008), and POST (2006) (all cited in Tables 6.2-1 and 6.2-2). These studies present data on the variation of carbon dioxide emissions released from nuclear power and illustrate that for low grade uranium ores (less
[than] 0.01% uranium oxide), nuclear power lifecycle carbon dioxide emission could potentially exceed those of fossil-fuel fire power plants. Storm van Leeuwen and Smith (2008) particularly present the comparison between nuclear power and a gas-fired power plant emissions with decreasing ore grade.
The statement regarding future relative magnitudes of GHG emissions has not been revised as this independent analysis has presented current available data and the references, presented in Tables 6.2-1 and 6.2-2 of the SEIS (i.e., Mortimer (1990, Storm van Leeuwen and Smith (2008)), that support the statement the commenter believes is subjective.. However, the NRC staff recognizes that additional clarification should be provided and additional clarification has been inserted under the note on Table 6.2-1 and Table 6.2-2 in Chapter 6 of the SEIS.
Comment 26-57: The DSEIS states that [f]ew studies predict that nuclear fuel cycle emissions will exceed those of fossil fuels within a timeframe that includes the Davis-Besse period of extended operation. But none of the studies cited in Table 6.2-2 appear to support this thesis at least based on the data presented. Therefore, FENOC suggests revising this sentence to state: Nearly all studies predict that nuclear fuel cycle emissions will remain an order of magnitude or more below those of all types of fossil fuels during the Davis-Besse period of extended operation.
Response: The NRC staff agrees that the statement needs to be revised. However, there are studies that support that nuclear power GHG emissions can possibly exceed those of fossil fuels if the ore grade decreases after the year 2050 (See Storm van Leeuwen and Smith 2008).
Since the renewed operating licenses would allow an additional 20 years of operation for A-231
Appendix A Davis-Besse the renewed license would expire in 2037. Therefore, the bulleted statement in Section 6.2.2, Conclusions, of the SEIS has been revised to read:
A few studies (e.g. Mortimer 1990, Storm van Leeuwen and Smith 2008) predict that nuclear lifecycle GHG emissions will exceed those of fossil fuels as a result of declining ore grade; however, it is not expected for nuclear lifecycle GHG emissions to exceed those of fossil fuels within the timeframe that includes the period of extended operation of Davis-Besse.
Comment 26-58: The DSEIS concludes that it is likely that GHG emissions from renewable energy sources would be lower than those associated with Davis-Besse at some point during the period of extended operation. This conclusion appears to be unsupported by the data presented in Table 6.2-3. FENOC suggests revising this sentence to state that most of the relevant studies show that it is likely that GHG emissions associated with Davis-Besse will remain comparable to or below those from renewable energy sources throughout the period of extended operation.
Response: The NRC staff agrees that the statement needs to be revised since the period of extended operation for Davis-Besse would be from 2017 to 2037 and studies indicate that increases in GHG emissions from nuclear power may occur after the year 2050. Therefore, the statement in Section 6.2.2, Conclusion, has been revised to read:
Currently, the lifecycle GHG emissions associated with nuclear power and renewable energy sources are of comparable magnitude. It is likely that GHG emissions from renewable energy sources and those associated with Davis-Besse will remain comparable during the period of extended operation.
Comment 26-60: The conclusion that the air quality impacts of new natural gas combined cycle generation would be SMALL to MODERATE appears inappropriate, in that it blurs the significant difference between emissions from Davis-Besse and natural gas sources. See Table 6.2-2 (page 6-6). FENOC suggests that if the impacts from Davis-Besse are SMALL, then the impacts from natural gas facilities should logically be at least MODERATE, consistent with the Davis-Besse Environmental Report.
Response: The NRC staff disagrees that the SMALL to MODERATE determination reached in the SEIS for air quality impacts of an NGCC is inappropriate. The conclusion reached in the SEIS is not solely determined by the absolute value of emissions (intensity), but also considers context. As discussed in Section 8.1.1 of the SEIS, emissions, county designation, and applicable regulations and requirements were considered, and a SMALL to MODERATE conclusion is appropriate. No change to the SEIS was made because of this comment.
A.3.3 Aquatic Resources (AQ)
Comment 17a-6: I made a comment about the effect of the hot water discharge, from the plant, and how that affects invasive species. Because I believe warming the water encourages invasive species, such as the grass carp.
Response: In the 2013 GEIS, the staff reviewed the potential impact of a thermal plume of discharge water to the receiving surface water body. Staff determined that thermal stratification due to nuclear power plant operations has not been encountered, and therefore the impact was A-232
Appendix A considered to be SMALL. The Ohio Environmental Protection Agency (OEPA) issued FENOC a National Pollution Discharge Elimination System (NPDES) permit that requires a continuous temperature monitoring of the non-radioactive cooling water discharged at the main station outfall. OEPA ensures that FENOC complies with the provisions of the Federal Water Pollution Control Act, as amended, and with the Ohio Water Pollution Control Act. No change to the SEIS was made because of this comment.
Comment 20-1: One thing that surprised me, about what was said tonight, is that the impact that is expected for surface water, and groundwater, from a license renewal by Davis-Besse, would be very small. And I just wonder how, in this world, after our experience with Fukushima, and with what we know of climate change, we could possibly be saying something like that now.
Response: Staff reviewed impacts to the surface and groundwater from plant operations to determine the impact to the environment from the operation of Davis-Besse. Based upon the information available, the staff has determined that the impact to surface and ground water from Davis-Besse operating for an additional 20 years would be SMALL. The NRC has staff (Japan Lessons Learned Division) that is evaluating and developing actions that are necessary to enhance the safety of the nuclear reactors in the United States as a result of the accident at Fukushima. This group is evaluating many issues related to the safe operation of nuclear power plants, such as seismic and flooding hazards, emergency preparedness, hardened vents and filtration, and spent fuel pool instrumentation. As staff develops guidance from the lessons learned from the Fukushima accident, the guidance will be provided to nuclear plant operators to avoid an accident like Fukushima from happening in the United States. Information on work that is being done at the NRC in relation to the Fukushima accident can be found at the NRC public Web site: http://www.nrc.gov/reactors/operating/ops-experience/japan-dashboard.html.
No change to the SEIS was made because of this comment.
Comment 25-5: The Draft SEIS references two areas of concern near Buffalo and the Ashtabula River on page 2-34, lines 12-16 and the lakewide management plan (LaMP) for Lake Erie. The Draft SEIS does not, however, state that Davis-Besse is within the EPA-designated Maumee River Area of Concern (AOC), which was extended in 1992 to include the Toussaint River. The document references the Remedial Action Plan (RAP), but it does not clarify that it is specific to the Maumee River AOC.
Recommendations: The Final SEIS should update this section to reflect that areas of concern are EPA-designated Areas of Concern, with specific locations, degradations, and improvement goals. In this context, where areas of concern are described, the correct term AOC should be used. The Buffalo area of concern should be updated to refer to the Buffalo River AOC.
Further, the document should reflect that Davis-Besse is within the Maumee River AOC and that the RAP has been developed to improve water quality of the Maumee River and Lake Erie.
Response: The NRC recognizes that Davis-Besse lies within the EPA-designated Maumee River Area of Concern. The NRC has incorporated the EPAs recommended modifications into Section 2.2.6 of the SEIS.
Comment 25-6: The Davis-Besse site is largely wetland, per the description on page 2-1, but the Draft SEIS does not include a map of the types of wetlands found onsite. EPA is particularly interested in wetlands that are not actively managed under the Ottawa National Wildlife Refuge, but rather those that could be impacted or adjacent to refurbishment and other activities related A-233
Appendix A to the operation of Davis-Besse. The Draft SEIS is unclear whether a wetland delineation was completed and whether wetlands are adjacent to areas proposed for construction.
Recommendation(s): EPA recommends including a wetland map and a proposed refurbishment facilities map in the Final SEIS. We acknowledge that the new facilities are proposed for previously-disturbed land, but without a map of both the aquatic resources and the proposed facilities, it is difficult to review potential direct and indirect impacts. EPA reminds NRC and the applicant to avoid even temporary, direct impacts to wetlands, such as staging construction equipment in wetlands. We recommend the Final SEIS include how the applicant and NRC will ensure direct and indirect impacts to wetlands are avoided. Temporary impacts to jurisdictional wetlands would trigger the need for a Clean Water Act Section 404 permit from the U.S. Army Corps of Engineers.
Response: As described in Section 2.2.7.2, the Davis-Besse site comprises 954 acres.
Navarre Marsh, which is leased to the U.S. Fish and Wildlife Service (FWS) for management as part of the Ottawa National Wildlife Refuge, covers 733 acres, and the remaining 221 acres contain facility buildings, structures, and parking lots; woodlands; low grasslands; and marginal agricultural land. Figure 2.1-3 depicts the on-site wetlands (Navarre Marsh). The proposed license renewal would include some construction activities associated with refurbishment (i.e., replacement of the steam generators). As indicated in Section 3.1, all construction associated with the steam generator replacement was completed during a 70-day refueling outage in the spring of 2014, and less than 10 acres of land was affected, all of which was developed industrial land. Navarre Marsh was unaffected by the construction. The NRC understands that if FENOC were to perform activities that could impact jurisdictional wetlands, it would need to seek a Clean Water Act Section 404 permit from the U.S. Army Corps of Engineers. However, because refurbishment activities did not directly or indirectly affect any wetlands, a permit was not necessary.
No revisions to the SEIS were made as a result of this comment.
A.3.4 Cumulative Impacts (CI)
Comment 25-9: Based on the discussion provided in section 4.15.5.1, Human Health -
Radiological, EPA commends the applicant and NRC for maintaining an operational radiation dose level that is within public dose standards and are as low as reasonably achievable (ALARA). However, because of the new facility at Fermi in Michigan scheduled to come online as early as 2021 and other nuclear reactors along Lake Erie, EPA recommends the public dose levels be closely monitored to ensure values do not increase past historical levels.
Recommendation: EPA recommends that, with the addition of the new facility at Fermi in Michigan and other operating nuclear reactors adjacent to Lake Erie, public radiation doses are monitored closely to ensure no exceedances are recorded. Any exceedances should be reported to EPA.
Response: Section 4.15.5.1 of the Davis-Besse FSEIS discusses the cumulative impacts of the operation of Davis-Besse and any other currently operating or proposed new nuclear facilities within a 50-mile radius. The currently operating facilities and proposed new nuclear facilities at the Fermi plant site would contribute to the cumulative radiological impacts in the vicinity of the Davis-Besse site. However, the cumulative radiological impacts from all uranium fuel cycle facilities in proximity to each other are limited to the radiation protection standards in 10 CFR Part 20 and 40 CFR Part 190. The NRC staffs review of radioactive releases from Davis-Besse shows that the annual radiation dose to the public has been less than 1.0 mrem A-234
Appendix A (0.01 mSv). This dose is well within the NRCs and EPAs radiation protection standards. In addition, as discussed in Section 4.8.1, Davis-Besse conducts a REMP around its site. The program measures radiation and radioactive materials in the environment from Davis-Besse and all other sources (i.e., other nuclear power plants such as Fermi, as well as other licensed users of radioactive material). Therefore, the REMP would monitor any cumulative impacts. As discussed in Section 4.8.1, the NRC staff reviewed the historical radiological environmental monitoring results for Davis-Besse and found no significant environmental impact associated with the operation of the plant. No revision to the SEIS was made as a result of this comment.
A.3.5 Cultural Resources (CR)
Comment 19a-14: So -- the last thing I want to talk about was that the -- if I read this right, it says that, the supplement says that it has relied on consultation with the tribes. And so with that consultation with the tribes, if I read this right, said consisted of writing letters to eight tribes, seven of which letters went unanswered. So we would like the NRC to have actual dialogue with all of these eight tribes. And dialogue should take place at, or close to, the tribal location, where the Native American cultural traditions can be respected, and where they dont have to drive long distances, or whatever.
Comment 19c-7: NRC maintains in its summary that it has relied on consultation with Tribes.
This consisted of writing letters to eight tribes, 7 of which letters went unanswered. We submit that the NRC must have actual dialogue with these eight tribes, which dialogue should take place at or close to the tribal meeting location. Native American cultural traditions must be respected.
Response: These two comments are related to how staff interacts with Native American tribes in the area around Davis-Besse. At the beginning of the scoping period, staff sent letters to leaders of the Federally recognized Native American tribes, which have historical ties to the area around Davis-Besse, requesting the tribes provide comments on the environmental review associated with the license renewal application. One tribe responded to this request. They indicated no objection to the proposed action of license renewal and asked to be contacted in the event skeletal remains were found in the vicinity of Davis-Besse. The other tribes did not provide comments, which is their prerogative. Additionally, the draft SEIS was sent to the same tribes inviting them to provide comments on the draft. Again, they exercised their prerogative to participate or not. To ensure the letters are sent to the correct individuals, the NRC staff reviews the latest version of the Bureau of Indian Affairs (BIA) Tribal Leaders Directory. This semiannual publication contains the most current information available at the time of publishing and takes into account tribal elections and other changes in tribal leadership that occurred since the last edition. In the case of the Davis Besse SEIS, the NRC staff consulted BIAs directory when preparing the letters discussed above. The latest version of the directory can be found at http://www.bia.gov/cs/groups/webteam/documents/document/idc1-028053.pdf.
No revision to the SEIS was made as a result of these comments.
A.3.6 Human Health (HH)
Radioactive Releases Comment 19a-8: We are also looking, Id like to mention the possibility of the contamination, radioactive contamination of the fresh water of Lake Erie, and maybe Lake Ontario, and maybe A-235
Appendix A the Great Lakes. And any of these reactors, any of the 37 reactors in the watershed of the Great Lakes could cause serious damage to our lakes. It never should have been allowed to happen.
Comment 19a-9: So all, a lot of unimagined scenarios have happened already, and continue to take place. And, unfortunately, Davis-Besse is located where it has the potential to contaminate the waters of Lake Erie for an eternity, actually.
Comment 19a-10: The NRC should address, look at routine radioactive releases that was mentioned before. There are tritium leaks, and so forth.
Comment 19c-3: The NRC has failed to adequately address the consequences of Davis-Besses routine radioactive releases. The NRC has concluded that if the radionuclides are diluted, the problem will disappear. However, studies have shown that there is no safe dose of ionizing radiation, and that low doses of radioactivity can be far more deadly than originally thought. The NRC appears to be taking the industry position that if a particular cancer, stroke, heart attack, or birth defect cannot be proven to have been caused by radioactivity, then the conclusion must be that radioactivity did not cause these health problems. The NRC has used selective studies to back their position that there is little or no increase health risks around nuclear reactors, ignoring other studies that contradict this assumption.
Response: Section 4.9.2 of the SEIS discusses the environmental impacts of the operation of the plant in the renewal term. NRC regulations require that radioactive liquid releases from nuclear power plants must meet radiation dose limits specified in 10 CFR Part 20, and the as low as is reasonably achievable (ALARA) dose criteria in Appendix I to 10 CFR Part 50.
Regulatory limits are placed on the radiation dose that members of the public can receive from radioactive material released by a nuclear power plant. As part of the Radioactive Effluent Control Program, and as required by 10 CFR 50.36(a), Davis-Besse is required to submit an annual report to the NRC listing the types and quantities of radioactive effluents released into the environment. Davis-Besse is also required to have a Radiological Environmental Monitoring Program (REMP) to assess the radiological impact, if any, to its employees, the public, and the environment from plant operations. The REMP measures the aquatic, terrestrial, and atmospheric environment for radioactivity, as well as the ambient radiation. The REMP supplements the Radioactive Effluent Monitoring Program by verifying that any measurable concentrations of radioactive materials and levels of radiation in the environment are not higher than those calculated using the radioactive effluent release measurements and transport models. NRCs review of the REMP reports submitted by Davis-Besse has shown that there has been no measurable impact to the environment from operations at Davis-Besse. The NRC staffs review of the Davis-Besse Radioactive Effluent Control Program has shown that the radiation doses to members of the public from radioactive effluents were within the Federal radiation protection standards in NRCs 10 CFR Part 20, Appendix I to 10 CFR Part 50, and EPAs 40 CFR Part 190. Continued compliance with NRC and EPAs regulatory requirements is expected during the license renewal term; therefore, the impacts from radioactive effluents determination of SMALL in the Davis-Besse SEIS will not change. No new information was provided in these comments. Therefore, no revisions to the SEIS were made.
Algae Comment 17a-3: Some errors of omission. Some comments were made about the algae blooms that we are experiencing here in Lake Erie. The NRC has said that there have been no reports of algae blooms near Davis-Besse. Well, I have to tell you, it is here. I have personally A-236
Appendix A seen it. I may not publish my reports in any journals, but I have been to the Ottawa Wildlife Refuge, and the local refuges, and I have seen piles of algae on the shoreline.
Comment 17b-12: Also, one of the contentions made by commenters on the original Environmental Impact Statement was that the heating of Lake Erie by Davis Besses effluent would encourage the growth of cyanobacteria such as Microcystis aeruginosa and Lyngbya wollei. The NRCs response was, Current operation of Davis-Besse has not been linked to the presence or growth of the cyanobacteria in Lake Erie. However, simply because no researcher has made the link, does not mean that the link does not exist. Several facts are known. Algea
[sic] grows more quickly in warmer water. I have personally observed large mats of algea [sic]
that have washed up onshore downstream from Davis-Besse. Probably, DBs discharges are encouraging more algeal [sic] growth.
Response: In Sections 4.15.2, Cumulative Impacts on Water Resources, 4.15.3, Cumulative Impacts on Aquatic Resources, and 4.15.5, Cumulative Human Health Impacts, blue-green algae or cyanobacteria has been discussed. As noted on the Ohio Environmental Protection Agency (OEPA) Web site (http://epa.ohio.gov/habalgae.aspx), factors that can contribute to harmful algal blooms include sunlight; low-water or low-flow conditions; calm water; warmer temperatures; and excess phosphorus or nitrogen that can be used as nutrients. In 2010, the U.S. Environmental Protection Agency (EPA) initiated the Great Lakes Restoration Initiative (GLRI) to protect and restore the Great Lakes. Further information on this initiative can be found at: http://greatlakesrestoration.us/index.html. On September 24, 2014, the GLRI Action Plan II was issued. This report lays out the steps that the 11 Federal agencies involved in the GLRI will take between 2015 and 2019 to protect the water quality of the Great Lakes. The GLRI Action Plan II can be found at:
http://greatlakesrestoration.us/actionplan/pdfs/glri-action-plan-2.pdf. On the State level, in 2012, Ohio Governor John Kasich charged the Directors of the Ohio Department of Agriculture, the Ohio Department of Natural Resources, and OEPA to work together to develop recommendations for improving the quality of Ohios waterways. Further information on this can be found at: http://www.agri.ohio.gov/topnews/waterquality/.
No new information was provided by these comments. Therefore, the SEIS was not revised as a result of these comments.
Cancer Reports Comment 16a-1: You mentioned, in the draft there, that there are no studies that have been published in well recognized scientific journals, which I dont understand what that, the definition of that is. But there are some studies that I would recommend that you look at, on the causative effects of the operation of nuclear power plants and public health.
Comment 16a-3: There is also a study written by Dr. Gordon Edwards, from Canada, on the effects of tritium, which I think is -- I dont have the title of it with me, but I recommend that one as well, Dr. Gordon Edwards and tritium.
Comment 16b-1: I especially refer you to the comments of Joseph Demare [sic] regarding medical studies on the harmful effects of radiation, especially from aging nuclear reactors and the studies of Joe Mangano. I did want to point you to the studies on Uranium and Tritium by Canadian Doctor, Gordon Edwards: His organizations Web site is a wealth of information on the harmful health effects of radiation on human beings and provides in-depth detail on how, exactly, this radiation enters the human body and effects [sic] human health.
http://www.ccnr.org, http://www.ccnr.org/tritium_1.html.
A-237
Appendix A Comment 17a-4: One of the largest, probably the biggest and most serious errors of omission, Im quoting now: No studies to date, that are accepted by the nothings leading scientific authorities that indicate a causative relationship between radiation dose from nuclear power facilities, and cancer in the general public exists. In other words, you are saying there arent any studies linking living near a nuclear power plant to increased rates of cancer. And you list a number of studies that seem to indicate there isnt. Well, the omission is the many, many studies which do show a link between living near a nuclear power plant and increased cancer rates.
Comment 17a-5: But somehow France managed to do it, even though it is an incredibly nuclear dependent country, they published a study, it is called The Childhoood [sic] Leukemia Around French Nuclear Plants, and it was published in the International Journal of Cancer, in 2012. This study found, also, that leukemia rates for children doubled around nuclear power plants.
Comment 17b-9: In the initial public comment on the license renewal application, many people pointed out that nuclear power plants release radioactive isotopes which are known to cause cancer. There is a cancer cluster downwind of the power plant. This supports the conclusion is that radiation from Davis-Besse is causing the cancers. However, the NRC staff response to this assertion on page A-24 was that, In summary, there are no studies to date that are accepted by the nations leading scientific authorities that indicate a causative relationship between radiation dose from nuclear power facilities and cancer in the general public. To support this, they cite six studies done between 1979 and 2001. However, they have omitted many studies published in respected scientific journals which have been published since then which DO show a link between living near a nuclear power plant and doubling of cancer rates.
This is not too surprising, since cancers caused by radiation can take up to 20 years to appear.
Therefore, studies done when nuclear plants are only 10 or 15 years old would mask the long term effects of exposure to low level radiation.
Comment 17b-10: Finally, the works of Dr. Joseph Mangano, J.M. Gould and their many collaborators can not simply be dismissed out of hand. One of Dr. Mangnos [sic] most recent studies, Infant Death and Childhood Cancer Reductions after Nuclear Plant Closings in the United States, with J.M. Gould, J.J. Mangano, W. McDonnell, J.D. Sherman and J. Brown, Archives of Environmental Health, 57, 23 - 31, 2002. Comes as close as ethically possible to establishing a causative link between nuclear plants and infant mortality. He found that, when nuclear plants were forced to have prolonged shutdowns, infant mortality rates dropped. When the shutdowns ended and the plants again began releasing radiation into the environment, the mortality rates again went up. Children and women are more vulnerable to radiation than men.
A fact which the NRC does not seem to take into account in this report. This is explainable because dividing cells are the most sensitive to damage from radiation, and infants have extremely rapidly dividing cells. Older men, in comparison have cells which divide much less frequently. Dr. Mangano has many other studies which are included in these comments as Appendix A.
Comment 23-3: Nuclear reactors have caused cancer among so many. I think that some of these cases of cancer need to be evaluated further to see whether environmental factors such as Davis-Besse has to blame. People in the community shouldnt have to live in fear.
Response: The NRCs mission is to protect the public health and safety and the environment from the effects of radiation from nuclear reactors, materials, and waste facilities. A discussion of these responsibilities beginning with the Atomic Energy Act of 1954 can be found on the NRC Web site at http://www.nrc.gov/about-nrc/history.html. The NRCs regulatory limits for radiological protection are set to protect workers and the public from the harmful health effects A-238
Appendix A (i.e., cancer and other biological impacts) of radiation. The limits are based on the recommendations of standards-setting organizations. Radiation standards reflect extensive scientific study by both national and international organizations. The NRC actively participates in, and monitors, the work of these organizations to keep current on the latest trends in radiation protection. If the NRC determines that there is a need to revise its radiation protection regulations, it will initiate a rulemaking. Members of the public who believe that the NRC should revise or update its regulations may request that the NRC do so by submitting a petition for rulemaking.
The NRC has based its dose limits and dose calculations on a descriptive model of the human body referred to as standard man. However, the NRC has always recognized that dose limits and calculations based on standard man must be informed and adjusted in some cases for factors such as age and gender. For example, the NRC has different occupational dose limits for pregnant women workers once they have declared (i.e., made known) they are pregnant, because the rapidly developing human fetus is more radiosensitive than an adult woman. NRC dose limits are also much lower for members of the public, including children and elderly people, than for adults who receive radiation exposure as part of their occupation. Finally, NRC dose calculation methods have always included age-specific dose factors for each radionuclide in order to consider the varied sensitivity to radiation exposure by infant, child, and teen bodies, which are also generally smaller than adult bodies. In addition, the calculation methods have always recognized that the diets (amounts of different kinds of food) of infants, children, and teens are different from those of adults. The NRC is currently updating 10 CFR Part 20, Standards for Radiation Protection, and information about this rulemaking can be found at:
http://www.nrc.gov/about-nrc/regulatory/rulemaking.html.
One of the Davis-Besse public scoping comments stated that there is no safe dose of ionizing radiation. The BEIR VII report (National Research Council 2006) conclusions are specific to estimating cancer risk and do not state that there is no safe level or threshold of radiation exposure. However, the report did note that the BEIR VII Committee said that the higher the dose, the greater the risk; the lower the dose, the lower the likelihood of harm to human health.
Further, the report notes that [t]he Committee maintains that other health effects, such as heart disease and stroke, occur at high radiation doses but that additional data must be gathered before an assessment of any possible dose response can be made of connections between low doses of radiation and non-cancer health effects. Although the LNT model is still considered valid, the BEIR VII Committee concluded that the current scientific evidence is consistent with the hypothesis that there is a linear dose-response relationship between exposure to ionizing radiation and the development of radiation-induced solid cancers in humans. Further, the Committee concluded that it is unlikely that a threshold exists for the induction of cancers but notes that the occurrence of radiation-induced cancers at low doses will be small.
Although radiation may cause cancers at high doses, currently there are no reputable scientifically conclusive data that unequivocally establish the occurrence of cancer following exposure to low doses (i.e., below about 10 rem (0.1 Sv)). However, radiation protection experts conservatively assume that any amount of radiation may pose some risk of causing cancer or a severe hereditary effect and that the risk is higher for higher radiation exposures.
Therefore, a linear, no-threshold dose response relationship is used to describe the relationship between radiation dose and adverse impacts such as incidents of cancer. Simply stated, in this model any increase in dose, no matter how small, results in an incremental increase in health risk. This theory is accepted by the NRC as a conservative model for estimating health risks from radiation exposure, recognizing that the model probably over-estimates those risks. Based on this theory, the NRC conservatively establishes limits for radioactive effluents and radiation exposures for workers and members of the public. Although the public dose limit in 10 CFR A-239
Appendix A Part 20 is 100 mrem (1 mSv) for all facilities licensed by the NRC, the NRC has imposed additional constraints on nuclear power reactors. Each nuclear power reactor has enforceable license conditions that limit the total annual whole body dose to a member of the public outside the facility to 25 mrem (0.25 mSv). The amount of radioactive material released from nuclear power facilities is well-measured, well-monitored, and known to be very small. The doses of radiation that are received by members of the public as a result of exposure to nuclear power facilities are very low (i.e., less than a few millirem) such that resulting cancers attributed to the radiation have not been observed and would not be expected. As stated in the GEIS, the NRC believes the public and occupational impacts during the license renewal term would be SMALL.
Although a number of studies of cancer incidence in the vicinity of nuclear power facilities have been conducted, no studies to date accepted by the scientific community show a correlation between radiation dose from nuclear power facilities and cancer incidence in the general public.
The following is a list of some of the most recent radiation health studies that the NRC recognizes:
In 1990, at the request of Congress, the National Cancer Institute conducted a study of cancer mortality rates around 52 nuclear power plants and 10 other nuclear facilities. The study covered the period from 1950 to 1984 and evaluated the change in mortality rates before and during facility operations. The study concluded there was no evidence that nuclear facilities may be linked causally with excess deaths from leukemia or from other cancers in populations living nearby.
In June 2000, investigators from the University of Pittsburgh found no link between radiation released during the 1979 accident at Three Mile Island power plant and cancer deaths among nearby residents. Their study followed 32,000 people who lived within 5 miles of the plant at the time of the accident.
The American Cancer Society in 2000 concluded that, although reports about cancer clusters in some communities have raised public concern, studies show that clusters do not occur more often near nuclear plants than they do by chance elsewhere in the population. Likewise, there is no evidence that links strontium-90 with increases in breast cancer, prostate cancer, or childhood cancer rates. Radiation emissions from nuclear power plants are closely controlled and involve negligible levels of exposure for nearby communities.
In 2000, the Illinois Public Health Department compared childhood cancer statistics for counties with nuclear power plants to similar counties without nuclear plants and found no statistically significant difference.
The Connecticut Academy of Sciences and Engineering, in January 2001, issued a report on a study around the Haddam Neck nuclear power plant in Connecticut and concluded radiation emissions were so low as to be negligible and found no meaningful associations with the cancers studied.
In 2001, the Florida Bureau of Environmental Epidemiology reviewed claims that there are striking increases in cancer rates in southeastern Florida counties caused by increased radiation exposures from nuclear power plants. However, using the same data to reconstruct the calculations, on which the claims were based, Florida officials were not able to identify unusually high rates of cancers in these counties compared with the rest of the State of Florida and the Nation.
On April 7, 2010, the NRC announced that it asked the National Academy of Sciences (NAS) to perform a state-of-the-art study on cancer risk for populations surrounding nuclear power facilities. The NAS has a broad range of medical and scientific experts who can provide the best available analysis of the complex issues involved in discussing cancer risk and commercial A-240
Appendix A nuclear power plants. More information on its methods for performing studies is available at http://www.nationalacademies.org/studycommitteprocess.pdf.
The NAS study will update the 1990 U.S. National Institutes of Health National Cancer Institute (NCI) report, Cancer in Populations Living Near Nuclear Facilities (NCI 1990). The studys objectives are to (1) evaluate whether cancer risk is different for populations living near nuclear power facilities; (2) include cancer occurrence; (3) develop an approach to assess cancer risk in geographic areas that are smaller than the county level; and (4) evaluate the study results in the context of offsite doses from normal reactor operations. Phase I of the NAS study report was published on March 29, 2012, and is available on the NAS Web site (http://www.nap.edu).
The NRC staffs discussion on the impacts to human health from the operation of Davis-Besse during the proposed license renewal term is discussed in Davis-Besse FSEIS Section 4.9.
No new information was presented in these comments. Therefore, no changes were made to the SEIS as a result of these comments.
Comment 16a-2: One is a recent report that came out just after this one was published on the 26th of February, was when you guys published this. This came out March 3rd, 2014, and its title is, A Report of Health Status of the California Residents in San Luis Obispo, and Santa Barbara Counties, Living Near the Diablo Canyon Nuclear Reactors Located in Avila Beach, California.
Response: This comment refers to the report Joseph Mangano wrote entitled Report on Health Status of Residents in San Luis Obispo and Santa Barbara Counties Living near the Diablo Canyon Nuclear Reactors Located in Avila Beach, California which was released on March 3, 2014. This report was written for the World Business Academy, located in Santa Barbara, California, and can be found at:
http://worldbusiness.org/nuclear-power-health-impact-study/. The San Luis Obispo County Public Health Department reviewed the report and issued their own report on April 11, 2014, stating that the County Public Health Department disputed the findings in the Mangano report.
The press release informing the public that the County Public Health Department report was available can be found at:
http://www.slocounty.ca.gov/Assets/PH/Media+Release+-+DCNPP+Health+Study.pdf. The Countys report can be found at:
http://www.slocounty.ca.gov/Assets/PH/Health+Concerns+from+DCNPP.pdf. No new information was provided by this comment. Therefore, no changes to the SEIS were made.
Electromagnetic Fields - Chronic Effects Comment 25-8: Per section 4.9.3, Electromagnetic Fields - Chronic Effects, because chronic exposure to electromagnetic fields continues to be studied and are not known at this time, NRC does not catgorize [sic] chronic effects from electromagnetic fields to be either Category 1 or 2 (generic or site-specific), but rather UNCERTAIN. EPA believes it would be prudent to consider the chronic effects of exposure to electromagnetic fields to be a Category 2 issue (site-specific), until a generic determination can be made.
Recommendation: EPA recommends NRC consider exposure to electromagnetic fields to be a Category 2 issue (site-specific) until a scientific consensus can be made and impacts can be analyzed as a Category 1 (generic).
Response: Section 4.9.1.1.4 of the License Renewal Generic Environmental Impact Statement (GEIS); NUREG-1437, discusses the health effects of electromagnetic fields (EMFs) used to A-241
Appendix A determine its categorization of UNCERTAIN. A review of the biological and physical studies of 60-Hz EMFs did not find any consistent evidence that would link harmful effects with field exposures. EMFs are unlike other agents that have a toxic effect (e.g., toxic chemicals and ionizing radiation) in that dramatic acute effects cannot be forced, and longer-term effects, if real, are subtle. Because of inconclusive scientific evidence, the chronic health effects of EMF are considered UNCERTAIN, and currently, no generic impact level can be assigned. The NRC will continue to monitor the research initiatives, both those within the national EMF program and others internationally, to evaluate the potential carcinogenicity of EMFs as well as other progress in the EMF study disciplines. If the NRC finds that the appropriate Federal health agencies have reached a consensus on the potential human health effects from exposure to EMF, the NRC will revise the GEIS to include the new information, change the categorization if needed, and determine what to require of all future license renewal applicants.
No changes were made to the SEIS as a result of this comment.
Tritium Comment 17a-1: In the area of errors of judgement [sic], discussing the tritium leaks that happened, and have happened, and may still be happening at Davis-Besse, the -- there is a description of the measurements of tritium, and it shows a graph of how they were high, and then they went low, and they went up again, and then they went down. And then the NRC, in this report, says that, well we have a plausible explanation for this leakage. Plausible explanation is not a high enough standard to protect any of us from tritium pollution.... And having a plausible explanation for why the plant is leaking is not satisfactory. We need to know why it is leaking in order to say, with any confidence, that it wont continue to leak over the next 20 years, if we re-license the plant.
Comment 17b-8: Another area of a serious error of judgment has to do with the leakage of tritium into the groundwater around Davis-Besse in the 2007-2010 time period. In Section 2, it states, ERM (2008) provided a plausible explanation regarding tritium release and migration.
However, the explanation is simply a list of possible tritium sources, potential inadvertent releases from the power block, including the spent fuel pool, would migrate vertically down through the unsaturated zone to the water table. Potential releases from structures below ground could release tritium directly to the upper or lower dolomite unit. Potential tritium sources in the power block are the reactor containment, auxiliary building, circulating water pump house, turbine building, and borated water storage tank (ERM 2007), (ERM 2008). In addition, several spent fuel pool leaks have been documented (Davis-Besse Undated). These sources would all produce leaks of varying amounts, degrees of radioactivity, and seriousness in terms of compromising the safety of the plant. Before allowing the plant to be relicensed, the NRC must require FENOC to demonstrate a causal link between an accidental release of radiation and tritium entering the ground water. As long as the source of tritium and the cause of the leaks are unknown, there is a very real danger that another, more serious release of radiation will occur. As was demonstrated with the NRCs response to the cracks in the containment dome, simply accepting a plausible explanation from FENOC is not a high enough standard of oversight to protect the public health and safety.
Comment 23-4: There has been reported leaks of tritium.
Comment 32d-3: On July 31, 2006, FirstEnergy publicly admitted four occurrences of inadvertent releases of radioactive liquids that had the potential to reach groundwater, adding Davis-Besse to the growing list of 102 reactors in the U.S. that have leaked radioactivity into the A-242
Appendix A environment since the early 1960s (and as the reactor ages, such leaks will become more likely). These four inadvertent releases of radioactive liquids were, specifically:
[1] Following a primary to secondary leak, contaminated secondary resin was transferred to the South Settling Basin, where it remains. The Davis-Besse South Settling Basin was designed to accept spent resin from backwashed secondary polishing demineralizers. Spent resins from the secondary polishers are no longer directed to this basin.
[2] Water from the Backwash Receiver Tank leaked into the ground from a break in a 3-inch line located between the Backwash Receiver Tank and the South Settling Basin.
The line break was excavated and repaired, and 7 cubic yards of contaminated soil was sent to a disposal facility.
[3] Primary grade water was spilled onto the ground near the Borated Water Storage Tank while draining the Hydrogen Addition System. Approximately 20 cubic yards of contaminated soil was excavated from the area and shipped to a disposal facility.
[4] While pumping water from the North Settling Basin to the Collection Box, the discharge hose from the pump fell out of the Collection Box and spilled water containing low-level [sic, emphasis added] tritium (4 E+04 pCi/L) [that is 4 x 10,000 picoCuries per liter, twice the U.S. Environmental Protection Agencys permissible concentration level for tritium contamination under the Safe Drinking Water Act] onto the ground.
In October, 2008, Davis-Besse admitted an uncontrolled release of tritium - carcinogenic, mutagenic, and teratogenic -- discovered by a fluke when workers checked fire protection systems. Of course, Davis-Besse - as with every operating reactor in the U.S. -- has permission from NRC, EPA and other government agencies to release radioactivity into air, water, and soil on a routine basis, despite the fact that every radiation exposure, no matter how small, carries a health risk, and those risks are cumulative.
Response: As described in Section 1.4 of this SEIS, in 2013, the NRC approved a revision to its environmental protection regulation, 10 CFR Part 51. With respect to groundwater quality, the final rule amends Table B-1 in Appendix B to Subpart A, of 10 CFR Part 51 by adding a new Category 2 issue, Radionuclides released to groundwater, with an impact level range of SMALL to MODERATE, to evaluate the potential impact of discharges of radionuclides from plant systems into groundwater. This new Category 2 issue has been added to evaluate the potential impact to groundwater quality from the discharge of radionuclides from plant systems, piping, and tanks.
As described in Section 2.2.5 of this SEIS, Davis-Besse has had leaks of tritium to onsite groundwater. In response to the Nuclear Energy Institutes groundwater protection initiative, the licensee installed a number of new onsite groundwater sampling wells based on the sites hydrogeology. These wells are sampled on a routine basis and the sample results are sent to the NRC as part of the Annual Environmental Report. The sources of leaks to groundwater have been identified and repaired. The highest tritium concentrations reported are well below the U.S. EPA drinking water standard of 20,000 pCi/l (40 CFR 141.66). Additionally, the tritium-contaminated groundwater has not moved off site. Therefore, as stated in Section 2.2.5, the impact of radionuclides released to groundwater is determined to be SMALL and is expected to remain SMALL during the license renewal term. No new information was presented in these comments. Therefore, no revisions were made to the SEIS as a result of the comments.
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Appendix A A.3.7 License Renewal and Its Process (LR)
Generic Environmental Impact Statement, NUREG-1437 Comment 25-1: The Draft SEIS identifies several resource areas with impact categories ranges as SMALL to MODERATE, or MODERATE to LARGE, including offsite impacts to terrestrial resources from refurbishment and impacts to historic archaeological resources from operation. There is little indication how the impacts to those resources could potentially increase from SMALL to MODERATE or from MODERATE to LARGE. For example, certain categories of impacts have clear and objective metrics that determine whether the site-specific impact is SMALL, MODERATE, or LARGE, such as Groundwater Use and Quality, page B-4.
Recommendation: EPA recommends the Final SEIS clarify how impacts to resources that are defined in a range could move from lesser significance to higher significance. For example, the metric for becoming a MODERATE impact to offsite terrestrial resources from refurbishment could be direct take of a certain number of acres or type of habitat. Further, NRC and the applicant should identify mitigation measures, including coordination with the Ohio Department of Natural Resources (ODNR) and the U.S. Fish and Wildlife Service (USFWS), to ensure that impacts are avoided or minimized and remain in the SMALL category. Mitigation measures should be specific; the Draft SEIS currently states use of best management practices, but this is too general. The Final SEIS should identify which specific best management practices will be used, where appropriate. For impacts to resources that are described in a range of significance, an adaptive management approach to mitigation should be outlined in the Final SEIS and committed to in the license.
Response: Impacts to resources affected by license renewal are defined in the License Renewal (LR) Generic Environmental Impact Statement (GEIS), NUREG-1437. The LR GEIS also explains how impacts could range from lesser significance to higher significance for each resource. As explained in Section 1.4 of the SEIS, impact levels were established for each environmental impact NEPA issue or resource based on the Council on Environmental Quality (CEQ) terminology for significantly (see 40 CFR 1508.27). The range or extent of the impact would depend on how much of the resource would be affected by license renewal and refurbishment activities. Generic environmental impact analyses in the LR GEIS combined with site-specific environmental impact analyses in the Davis-Besse SEIS constitute the NRCs NEPA analysis for license renewal.
The NRC evaluates the impacts of license renewal using information provided by the licensee in its environmental report and information gathered from various agencies, experts, and the public. On the basis of this evaluation, the NRC may identify mitigation measures to reduce certain impacts. However, the NRC can only require a licensee to mitigate impacts of those actions that are within the NRCs statutory authority. Therefore, the NRC cannot impose mitigation measures that are not related to this statutory authority, (i.e., to the public health and safety from radiological hazards or common defense and security). Other mitigation requirements may be imposed by other Federal and state agencies that have jurisdiction over affected resources. These mitigation requirements are often prerequisites for obtaining permits from these agencies. The NRC will not grant a renewed license unless the licensee has obtained all necessary permits for operations. No change was made to the SEIS in response to this comment.
Comment 25-7: Section 4.6.1, Exposure of Aquatic Organisms to Radionuclides, and Section 4.7.2, Exposure of Terrestrial Organisms to Radionuclides, provide information about the new Category 1 issues added in 2013 to the relicensing review process. Because this is a A-244
Appendix A new issue, EPA finds the discussion lacking. There is no specific reference to guidance nor specific metrics that govern how the significance category was assigned.
Response: Exposure of Aquatic Organisms to Radionuclides and Exposure of Terrestrial Organisms to Radionuclides are two new categories that were identified in the 2013 LR GEIS.
Chapter 4 of the LR GEIS describes the analyses the staff used to evaluate the impact and determine the significance of these two new categories. As noted in the LR GEIS, the dose rates for aquatic and terrestrial biota were calculated with the RESRAD-BIOTA dose evaluation model using site-specific radionuclide concentrations in water, sediments, and soils reported in the Radiological Environmental Monitoring Program (REMP) reports for 15 NRC-licensed power plants (see Table 4.6-5 in the 2013 LR GEIS for the plant list). These 15 plants represent plants with a range of radionuclide concentrations in environmental media. The total estimated dose rates for aquatic biota for these plants were all less than 0.2 rad/d (0.002 Gy/d), considerably less than U.S. Department of Energy (DOE) guideline value of 1 rad/d (0.01 Gy/d). Thus, it is anticipated that normal operations of these facilities would not result in negative effects on aquatic biota. Effects on populations of aquatic biota from such doses would be SMALL. This is considered a Category 1 issue.
Results of the RESRAD-BIOTA dose modeling show the dose estimates for three different terrestrial ecological receptors: riparian animal (an animal that is assumed to spend 50 percent of its time in water and 50 percent of its time on land), terrestrial animal, and terrestrial plant.
The maximum estimated dose rate calculated for any of the 15 nuclear power plants was 0.0354 rad/d (3.54E4 Gy/d) which is below the DOE guideline value of 0.1 rad/d (0.001 Gy/d) for a riparian animal receptor. On the basis of these calculations and a review of the available literature, the NRC concluded that the impact of routine radionuclide releases from past and current operations and refurbishment activities on terrestrial biota would be SMALL for all nuclear plants and would not be expected to appreciably change during the renewal period.
This is considered a Category 1 issue. The SEIS was not revised as a result of this comment.
Comment 26-1: Although the DSEIS discusses the revised GElS and the related final rule, FENOC believes that the discussion should be further clarified to confirm that, as applicable to Davis-Besse, the NRC has considered each of the Category 1 issues in the revised rule and determined that there is no new and significant information and the Category 1 determinations remain valid for Davis-Besse and/or provided a justification for any differences between what is in the DSEIS versus what is in the revised GElS/final rule.
Comment 26-7: This background sentence on the 2013 rulemaking states that the new Category 1 issues set forth in the revised GEIS and Part 51 rules include geology and soils, exposure of terrestrial organisms to radionuclides, exposure of aquatic organisms to radionuclides, human health impact from chemicals, and physical occupational hazards. A similar statement appears in Appendix B. This list does not appear to be comprehensive. The final rule (78 Fed. Reg. at 37,283) states: New Category 1 issues were added: geology and soils; effects of dredging on surface water quality; groundwater use and quality; exposure of terrestrial organisms to radionuclides; exposure of aquatic organisms to radionuclides; effects of dredging on aquatic organisms; impacts of transmission line right-of-way management on aquatic resources; employment and income; tax revenues; human health impacts from chemicals; and physical occupational hazards. and Several issues were changed from Category 2 to Category 1: Offsite land use, air quality, public services (several issues), and population and housing. FENOC requests that the DSEIS be revised to add all of the new Category 1 issues to this background sentence or to specifically clarify that this sentence in not intended to be comprehensive or to match the scope of new issues evaluated in the DSEIS.
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Appendix A Relatedly, and as proposed below regarding the substantive evaluations in Chapters 3 and 4, FENOC wants to ensure that all new Category 1 issues are fully and clearly addressed, or a justification be included for those not otherwise addressed in the DSEIS.
Comment 26-8: This background sentence on the 2013 rulemaking states that Radionuclides released to groundwater, effects on terrestrial resources (non-cooling system impacts), minority and low-income populations (i.e., environmental justice), and cumulative impacts were added as new Category 2 issues. This list appears to be inconsistent with the final rule (78 Fed. Reg. at 37,283), which states: New Category 2 issues were added: Radionuclides released to groundwater, water use conflicts with terrestrial resources, water use conflicts with aquatic resources, and cumulative impacts. and One uncharacterized issue was reclassified as Category 2: Environmental justice/minority and low-income populations. FENOC requests that the DSEIS be revised to include all of the new Category 2 issues to this background sentence or to specifically clarify that this sentence is not intended to be comprehensive.
Comment 26-9: This paragraph discusses the effectiveness of the final rule with regard to the new or revised Category 1 and 2 issues, and explains that the NRC must consider them.
FENOC recommends that the NRC add a brief discussion providing additional details, explaining how the NRC considered the Category 1 and 2 issues.
Comment 26-41: Although these substantive chapters evaluating the environmental impacts of refurbishment and operation appear to address most of the new issues in the June 20, 2013 final rule that revised Table B-1, it is not clear whether each individual issue has been addressed. For example, it does not appear to be clearly stated whether the following Category 1 issues are applicable to Davis-Besse and, if so, how they are addressed: effects of dredging on surface water quality, groundwater quality degradation resulting from water withdrawals, effects of dredging on aquatic organisms, and impacts of transmission line ROW management on aquatic resources. Therefore, FENOC recommends that the NRC include a discussion in this chapter, or elsewhere in the SEIS, to provide an explanation of how the Category 1 issues in the new final rule have been addressed, or, in the alternative, to provide a justification for any differences between what is in the DSEIS versus what is in the revised GEIS/final rule.
Comment 26-47: FENOC requests that the DSEIS be revised to include an affirmative statement in this section clarifying that the NRC has reviewed the Category 1 issues in Table B-1, as revised in the June 20, 2013 final rule, and has determined that, to the extent such topics are applicable to Davis-Besse, there is no new and significant information, and therefore the Category 1 designations for these issues remain correct and the small impact designations in Table B-1 remain correct. Alternatively, the SEIS should provide a justification for any differences between what is in the DSEIS versus what is in the revised GEIS/final rule.
Response: These six comments are related to the 2013 GEIS. As described in Section 1.4 of the SEIS, in the 2013 GEIS some Category 1 and 2 issues were consolidated, some Category 2 issues were changed to Category 1, and some new Category 1 and 2 issues were identified.
The list of environmental issues in Section 1.4 was not meant to be a detailed list of all the 2013 GEIS issues. In Section 1.4 of the SEIS, the staff discussed its use of the 1996 and the revised 2013 Generic Environmental Impact Statement for License Renewal of Nuclear Plants, NUREG-1437 (GEIS). For Category 1 issues, the 1996 and 2013 GEISs documented the results of the NRC staffs systemic approach to evaluate the environmental consequences of renewing the licenses of individual nuclear power plants and operating them for an additional 20 years. The staff analyzed in detail and resolved those environmental issues that could be resolved generically in the GEIS.
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Appendix A The staffs evaluation of the environmental issues applicable to Davis-Besse was based on both the 1996 and the 2013 GEISs. For Category 1 issues, no additional site-specific analysis was required in the SEIS unless new and significant information was identified that would change the generic evaluation in the GEIS. Section 4.14 of the SEIS contains the information on the process the staff used to identify any new and potentially significant information for Category 1 issues applicable to Davis-Besse and the process used for that determination. No new and significant information was discovered during the review period or from the public comments; therefore, the Category 1 issues were not discussed in the SEIS.
The Davis-Besse SEIS contains the staffs evaluation of all applicable Category 2 issues.
Category 2 issues not applicable to Davis-Besse were not evaluated by the staff and were not cited in the SEIS.
No new information was presented in these comments. Therefore, no revisions were made to the SEIS as a result of these comments.
License Renewal Process Comment 17b-13: In Section 4.1 LAND USE it was stated, The review included a data gathering site visit to Davis-Besse. No new and significant information was identified during this review that would change the conclusions presented in the GEIS. Given the NRC staffs poor judgement [sic] in other matters the report from this visit should have included ANY new information found, so that the public could make a judgment as to what constituted significant information. This study is supposed to be addressing the impacts of operation after renewal, but it seems in Section 4.2 they only address air quality during the revisions, not after.
Section 4.5.2 discusses releases of radiation into local groundwater. It describes unknown, uncontrolled, and unmonitored releases of radioactive substances that have occurred in the past, but claims that such leaks are not expected to occur again. Therefore the impact is listed as small but in reality it could be much more significant. If the causes of radioactive releases are unknown and uncontrolled, no accurate estimates of their future impacts can be made.
In section 4.11 Environmental Justice the report states, ...During 2010, analyses performed on samples of environmental media showed no significant or measurable radiological impact above background levels from site operations (FENOC 2011). The NRC omitted what it considers significant. Section 4.4.1 claims that there will be no significant change in surface water use and water quality. However, if projections by the EPA and other agencies are correct, and Lake Erie will warm and shrink as a result of climate change, then there will almost certainly be altered impacts on issues such as thermal stratification of lakes and eutrophication.
Response: This comment questions the lack of new and significant information discovered during the environmental review. The NRC uses the Council on Environmental Qualitys (CEQ) definition of Significantly (40 CFR 1508.27) to determine if information is new and significant.
The National Environmental Policy Act (NEPA) requires consideration of both context and intensity when evaluating information. Context means that the information must be analyzed in several contexts, such as society as a whole, the affected region, the affected interests, and the locality. Both short-term and long-term effects are also relevant to context. Intensity refers to the severity of the impact or extent of the impact. Direct, indirect, and cumulative effects are used to determine intensity. To determine intensity of an effect, the following should be considered:
- 1. Impacts that may be both beneficial and adverse.
- 2. Degree to which the proposed action affects public health and/or safety.
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Appendix A
- 3. Unique characteristics of the geographic area, such as proximity to historic or cultural resources, park lands, prime farmlands, wetlands, wild and scenic rivers, or ecologically critical areas.
- 4. Degree to which the effects are likely to be highly controversial.
- 5. Degree to which the possible effects on the human environment are highly uncertain or involve unique or unknown risks.
- 6. Degree to which the action may establish a precedent for future actions with significant effects.
- 7. Whether the action is related to other actions with individually insignificant but cumulatively significant impacts.
- 8. Degree to which the action may adversely affect districts, sites, highways, structures, or objects listed in or eligible for listing in the National Register of Historic Places or may cause loss or destruction of significant scientific, cultural, or historical resources.
- 9. Degree to which the action may adversely affect an endangered or threatened species or its habitat that has been determined to be critical under the Endangered Species Act of 1973.
- 10. Whether the action threatens a violation of Federal, State, or local law or requirements imposed for the protection of the environment.
The staff reviewed information for the SEIS and used this definition as the basis for determining whether the information was new and significant. No changes were made to the SEIS as a result of this comment.
Comment 19c-8: The Sierra Club would like an explanation as to why the NRC would expect the Environmental Report submitted by FENOC to be anything other than a corporation acting in its own best interest? Why would a report by a vested financial interest be determined by the NRC to have credibility, while public concerns are rejected?
Response: The regulations specific to the license renewal of nuclear power plants are found in 10 CFR Part 54, Requirements for Renewal of Operating Licenses for Nuclear Power Plants.
The information provided by an applicant as part of the license renewal application, including the environmental report (ER), is required to be complete and accurate in all material respects, as indicated in 10 CFR 54.13. Applicants are required to affirm, under penalty of perjury, that the information submitted is true and correct. The staff reviews the ER as part of an independent environmental review. The staff also considers comments made by the public during the scoping period and on the draft SEIS. Under the NRCs NEPA regulations in 10 CFR Part 51, the staff must determine the scope of the license renewal action and identify the significant issues to analyze in depth. The staff must also identify and eliminate from detailed study issues which are peripheral or are not significant or which have been covered by prior environmental review. The staff must provide a brief discussion as to why the issues are considered peripheral or will not have a significant effect on the quality of the human environment. No change has been made to the SEIS as a result of this comment.
Comment 19c-11: The democratic process is undermined when members of the public have their ideas and critical information disallowed because they are not in a position to conform to the legalistic process crafted by the NRC. Not only has the general public been dismissed, but the evidence of skilled professionals has also been dismissed by the NRC. Additionally, the A-248
Appendix A rejection of professional arguments by the NRC occurred after the Atomic Safety and Licensing Board hearing the arguments agreed with the petitioners that wind and solar could well have the ability to replace the power from Davis-Besse by 2017. This is another reason that the NRC must revisit the contention that renewables have the ability to replace the power generation of the Davis-Besse reactor.
Response: This comment is referring to the Atomic Safety and Licensing Boards (ASLB) decision to dismiss the intervenors contention relating to FENOCs failure to consider in the ER, combinations of wind and/or solar photovoltaic energy sources as alternatives to relicensing Davis-Besse. On December 27, 2010, the intervenors submitted three contentions that alleged the applicants ER did not adequately analyze wind power, solar power, or wind and solar power in combination as baseload power alternatives. On April 26, 2011, the ASLB admitted an amended contention, which combined these three contentions alleging that the ER had failed to adequately evaluate the full potential for renewable energy sources, specifically wind power in the form of interconnected wind farms and/or solar photovoltaic power, in combination with compressed air energy storage, to offset the loss of energy production from Davis-Besse (LBP-11-13). In September 2011, FENOC submitted revisions to the ER which expanded the discussion of renewable energy alternatives and submitted a request to the ASLB to dismiss the alternatives contention, which the ASLB denied. FENOC then appealed the ASLBs decision to the Commission. The Commission reviewed the submitted information and on March 27, 2012, the Commission issued its decision (CLI-12-08) that the ASLB had erred in admitting the alternatives contention and the contention was dismissed. Chapter 8 of the SEIS documents the staffs review of the reasonable alternatives. No changes to the SEIS were made as a result of this comment.
Comment 32d-1: Article from Beyond Nuclear: Davis-Besse Atomic Reactor: 20 MORE Years of Radioactive Russian Roulette on the Great Lakes shore?! November 2010, corrected May 10, 2011.
Response: This article was originally prepared in November 2010 by the organization Beyond Nuclear. This article presents a history of Davis-Besse operations and Beyond Nuclears reasons for being opposed to the relicensing of Davis-Besse for an additional 20 years. This article described events such as the F2 tornado that hit Davis-Besse on June 24, 1998, the acid-induced corrosion of the reactor vessel head in 2002, and the northeast blackout of 2003. The issues discussed in this article were related to the current operations of the plant at the time of each event. No new information is provided in this article. No changes to the SEIS were made as a result of information in the article.
Comment 32e-1: Beyond Nuclear Fact Sheet - What Humpty Dumpty doesnt want you to know: Davis-Besses Cracked Containment Snow Job, August 8, 2012 Response: This is an article that was prepared by Beyond Nuclear in August 2012. The article generally chronicles the history of the cracks in the concrete shield building. The article calls into question FENOCs root cause report on the cracking. The article also discusses NRC documents, such as e-mails, that Beyond Nuclear believes demonstrates how structural integrity of the shield building has been compromised. The e-mails reflect questions NRC staff was asking early on in the investigation of the cracks. The NRC staff continues to review and evaluate the shield building cracks. The results of staffs review will be documented in a supplemental safety report which will be completed in late 2015. No new information is A-249
Appendix A provided in this fact sheet. No changes to the SEIS were made as a result of information in the fact sheet.
Comment 32e-3: The SER, issued on 7/31/12, includes not one, but four, open items:
management of shield building cracks during the period of extended operations; operating experience review prior to entering the period of extended operations; time limited aging analyses of reactor vessel neutron embrittlement; and pressure-temperature limits. An embrittled reactor pressure vessel, given its metals loss of ductility, can fracture like a hot glass under cold water due to pressurized thermal shock (PTS) if the emergency core cooling system is activated. Despite this, NRC has repeatedly weakened its PTS safety standards, in order to allow old, dangerously degraded reactors like Davis-Besse to keep operating. Davis-Besse is the hottest operating atomic reactor in the U.S., one theory for why it has required three lids in a single decade (2002-2011). And such a sudden drop, from such high temperatures, due to ECCS activation in an emergency would exacerbate PTS risks.
Response: The SER (safety evaluation report) that was issued on 7/31/12, had the four open items that are listed above. The open items in the SER are issues that the staff continues to review and needs further information from the licensee to adequately resolve the issues. The NRC staff issued a final SER (ML13248A267) on September 3, 2013, after the open items were resolved.
The SER with open items is staffs interim report that is presented to the Advisory Committee on Reactor Safeguards (ACRS) Subcommittee for Plant License Renewal for review. The ACRS subcommittee will discuss the SER at a public meeting with representatives from the applicants staff, NRC staff, and other interested parties. The ACRS Subcommittee reviews the SER and provides comments to the staff on areas of the SER that need further explanation. After staff has resolved the open items in the SER and the ACRS Subcommittee comments, staff prepares a final SER which is provided to the ACRS full committee for review. The ACRS holds another public meeting with representatives from the applicants staff, NRC staff, and other interested parties to discuss the final SER. After the ACRS has completed its review and has determined a plant can operate safely for 20 additional years, the Chairman of the ACRS sends a letter to the Chairman of the NRC with ACRSs conclusion and recommendation. A decision on whether or not to relicense a nuclear power plant will not be made until after the ACRS provides their conclusions and recommendations to the NRC Chairman. More information about the ACRS can be found at: http://www.internal.nrc.gov/ACRS/.
No new information was presented in this comment and therefore, no changes were made to the SEIS.
License Renewal - Past Contentions Comment 32a-1: 4 21 14 draft EIS comment vis a vis 1 10 12 cracking contention. The following is provided as public comment on the NRC draft EIS re: Davis-Besses proposed 20 year license extension. Link to original Jan. 10, 2012, cracking contention filed with the NRC ASLB: http://www.beyondnuclear.org/storage/
FINAL%20Contention%205%20Cracking%20January%2010%202012.pdf. [Also available in ADAMS - ML12010A172]
Response: On January 10, 2012, the organization Beyond Nuclear, in conjunction with Citizens Environmental Alliance of Southwestern Ontario, Dont Waste Michigan, and the Green Party of Ohio (Intervenors), submitted a motion for admission of Contention No. 5 on the A-250
Appendix A Davis-Besse concrete shield building cracking (ADAMS ML12010A172). Contention No. 5 asserted that the concrete shield building should be subject to an aging management review and that the concrete shield building cracks be analyzed within the Davis-Besse SEIS. The contention argued that the cracking of the concrete shield building also now required a site-specific review of severe accidents for NEPA compliance.
On February 6, 2012, the applicant, FENOC, filed a motion opposing Contention No. 5. On February 6, 2012, NRC staff also filed a motion (1) to admit, in part, the contention as it relates to the need for the concrete shield building to have an adequate aging management review, and (2) to deny, in part, claims that an evaluation of the cracks be included in the SEIS. NRC staff agreed that FENOC should have an aging management program (AMP) in place for the concrete shield building. On April 5, 2012, FENOC submitted notification to the ASLB that FENOC had provided to the NRC a Shield Building AMP (ML12097A216) to be added to the license renewal application.
On December 28, 2012, the ASLB, in Memorandum and Order (LBP-12-27), denied the motions to admit, amend and/or supplement proposed Contention No. 5 (ML12363A200). In LBP-12-27, the ASLB wrote that proposed Contention No. 5 was comprised of three central concerns:
- 1. There is extensive cracking of unknown origin in the shield building structure.
- 2. The cracking is an aging-related feature of the plant.
- 3. This condition precludes safe operation of the plant.
ASLB wrote that with regard to these concerns, the Intervenors have not provided facts or expert opinions as to why FENOCs analyses and conclusions are incorrect. The ASLB also indicated that the Intervenors did not provide specifics as to why the new Shield Building AMP was wrong or inadequate. Finally, with respect to Intervenors claim that the cracking precludes safe operation, no specific information was submitted that supported this claim. The ASLB also wrote that questioning the safe operation of the plant is actually claiming a current safety issue, and that current safety issues are beyond the scope of a license renewal hearing.
The NRC staff continues to review information about the cracking in the shield building and anticipates issuing a supplemental Safety Evaluation Report in May 2015 to document staffs review.
No new information has been provided. Therefore, no changes to the SEIS were made as a result of this comment.
Comment 32a-5: Although we also filed a steam generator replacement contention at Davis-Besse in May, 2013, which included concerns about Shield Building breaches, that contention was summarily dismissed by the ASLB. Thus, the steam generator replacement experiment at Davis-Besse is now well underway, and only time will tell how long they will last, and how soon the Shield Building must again be breached, if FENOC chooses to replace large nuclear components located within the Shield Building.
Response: This comment refers to the license amendment request submitted by FENOC to revise their technical specifications to operate the new steam generators. An Atomic Safety and Licensing Board (ASLB) was established in May 2013 as a result of a request for a hearing submitted by Beyond Nuclear, Citizens Environment Alliance of Southwestern Ontario, Dont Waste Michigan, and the Ohio Sierra Club. As documented in ASLB Order LBP-13-11 (ML13224A110), dated August 12, 2013, the contention and request for a hearing were denied because the license amendment was for proposed changes to the technical specifications for operating the new steam generators, not for the replacement of the steam generators. FENOC A-251
Appendix A was following the requirements in 10 CFR 50.59 for the analysis to replace the steam generators. The NRC has previously stated that members of the public can only challenge actions taken under 10 CFR 50.59 by submitting a petition in accordance with 10 CFR 2.206.
NRC staff continues to review the concrete cracking in the shield building. The environmental impacts related to the replacement of the steam generators have been evaluated and are documented in Chapter 3 of the SEIS. No new information has been provided. Therefore, no changes to the SEIS were made as a result of this comment.
Comment 32b-1: 4 21 14 DEIS comments vis a vis 2012 D-B Cracking Contention Supplements. The following is provided as public comment on the NRC draft EIS re:
Davis-Besses proposed 20 year license extension I have previously submitted comments regarding our environmental coalitions contention, dated Jan. 10, 2012, seeking a hearing, on Shield Building cracking at Davis-Besse, submitted to the NRC ASLB. The following comments stem from our coalitions five supplements to that contention, submitted between Feb. and August of 2012.
Response: This comment relates to four motions to amend proposed Contention No. 5 which was originally submitted on January 10, 2012, by the organization Beyond Nuclear, in conjunction with Citizens Environmental Alliance of Southwestern Ontario, Dont Waste Michigan, and the Green Party of Ohio (Intervenors). The Intervenors submitted Contention No. 5 also on the Davis-Besse concrete shield building cracking (ADAMS ML12010A172). The four Motions to Amend Contention No. 5 are summarized below. The fifth motion to supplement proposed Contention No. 5 is discussed in the Response to Comment 32c-1.
Intervenors Motion to Amend Motion for Admission of Contention No. 5 was submitted on February 27, 2012 (ML12058A249). This motion was submitted because the Intervenors believed that an NRC inspection report issued on January 31, 2012 (ML12032A119), contained new information that was relevant to Contention No. 5. The motion to amend also includes information related to information released by former Congressman Kucinich.
Intervenors submitted the Motion to Amend and Supplement Proposed Contention No. 5 (Shield Building Cracking) on June 4, 2012 (ML12156A411). This motion was submitted for the purpose of exposing discrepancies between FENOCs February 27, 2012, Root Cause Analysis Report and the RAI AMP. The February 2012 Root Cause Analysis Report contained the licensees analysis to determine the direct cause of the laminar cracking in the Davis-Besse concrete shield building. Intervenors claimed that FENOCs response to NRC staffs Request for Additional Information (RAI) on the cracking in the Shield Buildings concrete (ML12097A520) demonstrated that the Root Cause Analysis Report was deficient.
Intervenors Third Motion to Amend and/or Supplement Proposed Contention No. 5 (Shield Building Cracking) was submitted on July 16, 2012 (ML12198A561). The stated purpose for this motion to amend was to demonstrate the discrepancies between FENOCs Root Cause Analysis Report and the Shield Building AMP. The Intervenors stated that they believed there was serious incongruity between the cracking problems as defined by FENOC, and the proposed remedy, exemplified by the AMP.
Intervenors Fourth Motion to Amend and/or Supplement Proposed Contention No. 5 (Shield Building Cracking) was submitted on July 23, 2012 (ML12205A507). This motion to amend and/or supplement was in response to FENOCs consultant, Performance Improvement Internationals report, Root Cause Assessment: Davis-Besse Shield Building Laminar Cracking, Vol. 1, which was added to NRCs ADAMS on May 24, 2012 (ML12138A037).
Intervenors still maintain there is serious incongruity between the cracking problems and the A-252
Appendix A shield building AMP. The Intervenors argued that the shield building AMP submitted by FENOC was inadequate.
Based upon the Intervenors motions to admit and amend the contention and FENOCs and NRC staffs answers to the motions, on December 28, 2012, the ASLB, in the Memorandum and Order (LBP-12-27), denied the motions to admit, amend and/or supplement proposed Contention No. 5 (ML12363A200). In LBP-12-27, the ASLB wrote that the Intervenors do not articulate why the information contained in the proposed Contention No. 5, and its proposed amendments, is new or materially different from information on shield building cracking that was previously submitted. The ASLB also pointed out that the Intervenors do not provide information as to why the AMP is not adequate.
The NRC staff continues to review information about the cracking in the shield building and anticipates issuing a supplemental Safety Evaluation Report in May 2015 to document staffs review. No new information has been provided. Therefore, no changes to the SEIS were made as a result of this comment.
Comment 32c-1: 4 21 14 DEIS comment vis a vis 5th Cracking Contention Supplement dated 8 16 12 Response: This comment refers to the collection of NRC documents received by the organization Beyond Nuclear as a result of the January 26, 2012, Freedom of Information Act (FOIA) request (FOIA/PA-2012-0121). On August 16, 2012, Beyond Nuclear, Citizens Environment Alliance of Southwestern Ontario, Dont Waste Michigan, and the Green Party of Ohio (Intervenors) submitted these documents in support of Intervenors Fifth Motion to Amend and/or Supplement Proposed Contention No. 5 (Shield Building Cracking) (ML12229A584, ML12229A585, ML12229A586, ML12229A587, ML12229A588, ML12230A000, ML12230A001, ML12230A002, ML12230A003 and ML12230A004).
These documents consist of staff e-mails, conference call summaries, informational slides prepared for briefing management, and proposed questions to ask the applicant in requests for information. These documents represent a snapshot of the work (through January 2012) the NRC staff was doing with regard to the concrete shield building cracking.
As documented in LBP-12-27, dated December 28, 2012, the ASLB determined that this fifth supplement to proposed Contention No. 5 was inadmissible because the Intervenors did not demonstrate how the information in this supplement is new and materially different from previously available information and if the information in these documents is material to NRCs ultimate licensing decision. The NRC staff continues to review the information related to the cracking in the concrete Shield Building and anticipates issuing a supplemental SER in May 2015. No licensing decision will be made until all safety issues have been resolved.
These documents provide no new information. No changes to the SEIS were made as a result of these documents.
Editorial Comments Comment 25-10: Section 2.1.2.2, Radioactive Gaseous Waste, page 2-9, line 3, references 40 CFR Part 40, which is Research and Demonstration Grants. Please clarify if this is the intended citation.
Recommendation: Clarify whether this is correct; if not, please reflect the correct citation in the Final SEIS.
A-253
Appendix A Response: The commenter is correct in that the wrong regulation was cited. The regulation that should be have cited is 40 CFR Part 190, Environmental Radiation Protection Standards for Nuclear Power Operations. Section 2.1.2.2 has been revised to cite the correct regulation.
Comment 25-11: EPA recommends that resources agencies be provided with and the public have access to color versions of maps within the Draft SEIS, particularly for maps that rely on a color gradient. All maps in the paper copy and the CD of the Draft SEIS are provided in grey-scale, making it difficult to fully analyze certain impacts. For example, figures 2.1-2, 2.1-3, 2.2-1 should be provided in color, or at minimum the document should include specific location in NRCs Agencywide Documents Access and Management System (ADAMS). This means the citation should not just be given as an ADAMS access number, but should also include a specific page number.
Recommendation: NRC should provide access to color versions of maps that rely on color gradient. If nothing else, the ADAMS access number and specific page location should be provided indicating where the color versions can be found.
Response: The version of the draft SEIS that is in ADAMS should have had color figures. For some unknown reason, when the PDF file of the draft SEIS was entered into ADAMS, the figures were not saved in color. When the final SEIS is published and entered into ADAMS, the staff will ensure that the figures will appear in ADAMS in color. No changes were made the SEIS as a result of this comment.
Comment 26-5: The DSEIS concludes that its preliminary recommendation is that the adverse environmental impacts of license renewal for Davis-Besse are not great enough to deny the option of license renewal for energy planning decisionmakers. Consistent with 10 CFR § 51.95(c)(4) and Section 9.4 of the DSEIS, this conclusion should be revised to read as follows: the adverse environmental impacts of license renewal are not so great that preserving the option of license renewal for energy planning decision makers would be unreasonable.
Comment 26-10: Similar to Comment 5, above, the sentence should be revised to read as follows: Commission that the adverse environmental impacts of license renewal are not so great that preserving the option of license renewal for energy planning decision makers would be unreasonable.
Response: These comments relate to the wording of the preliminary recommendation in the draft SEIS. The wording in the draft SEIS was not consistent with the wording in the regulations at 10 CFR 51.95(c)(4). The wording of the recommendation in the Executive Summary and in Chapter 1 of the SEIS has been revised so that it is consistent with the wording in the regulation and in Chapter 9.
Comment 26-21: FENOC recommends changing or deleting the reference source cited (Brown 2010) since there is no corresponding reference citation in the references list in Section 2.4.
Response: Staff agrees with this comment. The reference to (Brown 2010) has been corrected to (FENOC 2010d).
A-254
Appendix A Comment 26-2: FENOC notes that the description of the combinations alternative on this page does not match the similar description on page xix, Line 7.
Response: Staff agrees with this comment. The list of alternatives in the Executive Summary has been revised to reflect the alternatives evaluated in Chapter 8 of the SEIS.
Comment 26-3: FENOC suggests changing Nuclear Power Plant to Nuclear Power Station.
Comment 26-4: FENOC recommends changing is to are, since the topic is environmental impacts.
Comment 26-6: FENOC suggests that the word million following MMBtu should be in the right-hand column in front of British thermal unit.
Comment 26-11: FENOC suggests changing Accession Nos. to the singular Accession No.
Response: Staff agrees with these editorial changes. The Executive Summary, Abbreviations & Acronyms, and Chapter 1 of the SEIS were revised to incorporate these changes.
Comment 26-12: FENOC suggests removing the extra spaces (25 mi) (40 km) (2500 m) in lines 2 & 5. Also, the statement [a]pproximately 700 ac (300 ha) are marshland is the only location in the DSEIS where 700 ac is used; elsewhere, the statement approximately 733 ac is used multiple times. Recommend using approximately 733 ac throughout the DSEIS.
Comment 26-13: FENOC recommends the use of 908 megawatts-electric (MWe) instead of 913 MWe in the DSEIS, to be consistent with the License Renewal Application and Environmental Report. The reference cited on page 2-6, Line 11 (i.e., FENOC 2010c), is the License Renewal Application, which lists electrical output as 908 MWe. Also, 908 MWe is used later in the DSEIS for the comparison of Alternatives.
Comment 26-14: The sentence states that each primary coolant loop contains one reactor coolant pump, but Davis-Besse has two reactor coolant pumps per loop. FENOC recommends changing Line 17 from ...one reactor coolant pump, to one or two (depending on the plant design) reactor coolant pumps.
Comment 26-15: FENOC suggests revising the 3 cited references (FENOC 2011) on this page to be consistent with the references Section 2.4, which lists the references as FENOC 2011a, 2011b, or 2011c. Same comment for page 2-11, line 26 (FENOC 2010), which has no alpha character (a, b, c or d) following the year.
Comment 26-16: The Magee Marsh Wildlife Area entrance is approximately 6 miles west of the station. Lake Erie is east of the station. FENOC recommends revising Line 19 to read, The Navarre Marsh partially surrounds the station to the north, east and southeast.
Comment 26-17: Regarding the sentence, Davis-Besse has many sources of criteria pollutants and HAPs to include the following:, FENOC recommends changing the sentence to read: The Davis-Besse sources of criteria pollutants and HAPS are as follows: As currently written, the sentence suggests there are more sources than those listed.
Comment 26-18: FENOC requests that, at the beginning of the sentence at the end of the Line, NRC consider adding However, in front of In 1992, Davis-Besse to make it clear that the previous discussion of fires and the chemicals released during transformer fires didnt apply in this case.
A-255
Appendix A Comment 26-19: FENOC recommends changing August 14, 2006 to July 1, 2011 to align with the new permit date and the suggested update to Appendix C, below.
Comment 26-20: FENOC recommends deleting asbestos, because the updated permit does not require monitoring for asbestos.
Comment 26-22: FENOC recommends changing 2006 to 2011 to align with the new permit date, a previous comment and the suggested update to Appendix C, below.
Comment 26-24: The change has been submitted and approved, and zinc acetate is being used, so FENOC recommends revising the last sentence to be past tense.
Comment 26-23: The use of the terms violate with respect to NPDES requirements and NOV (Notice of Violation issued by a regulator e.g., OEPA) are confusing when used interchangeably in the first two sentences. The statements need to be clear that site personnel may indicate an action, lack of action, or parameter may have exceeded (violated) permit requirements, but there were no formal NOVs issued for the cases described where FENOC exceeded permit requirements for a period of time. FENOC recommends changing NOV on line 17 to violations.
Comment 26-25: FENOC recommends changing the sentence to read, December 2010 at monitoring wells 30S.
Comment 26-26: FENOC recommends changing Ce-137 to Cs-137 and Ce-134 to Cs-134. Also, the cited reference (NRC 1991) is not included in the list of references in Section 2.4, page 2-87.
Comment 26-27: FENOC recommends changing sodium hydroxide to sodium hypochlorite.
Comment 26-28: FENOC suggests that the reference to Table 2.3-8 in this line should instead be Table 2.2-8.
Comment 26-29: FENOC suggests that the reference to Section 2.2.6 in this line should instead be Section 2.2.7.2.
Comment 26-30: FENOC suggests underlining and separating the heading Transportation in a manner similar to the formatting of the previous heading Education.
Comment 26-31: A space is needed between the first two words in the line.
Comment 26-32: The word temporary is missing the letter t.
Comment 26-33: There is an errant comma following the word of.
Comment 26-34: FENOC recommends rewording the following sentence as shown:
One documented fluted projectile point is located was discovered at the Peters site in Ottawa County, south of Davis-Besse along the Portage River was discovered (Prufer and Shane 1973).
Comment 26-35: FENOC recommends changing north to northwest, because the Maumee River runs from the southwest to the northwest of Davis-Besse.
Comment 26-36: The Magee Marsh is approximately 6 miles west of Davis-Besse. FENOC recommends adding a period after agricultural purposes and deleting the remainder of the sentence.
Comment 26-37: Many of the titles for the Code of Federal Regulations citations are incorrect or duplicated. Examples include 10 CFR Part 60, Part 70, 15 CFR Part 930 has multiple citations bundled together, 40 CFR Part 80, 40 CFR Part 239, etc. FENOC recommends A-256
Appendix A verifying the titles for these citations in this section and in the other references sections of the DSEIS.
Comment 26-38: FENOC suggests that the title of this document reference should read, Loggerhead Shrike: First Ever Captured.
Comment 26-39: FENOC recommends deleting the (2010b) at the end of the reference to be consistent with the other FENOC 2010 citations.
Comment 26-40: This FENOC 2011 citation appears to be out of chronological order and should be located between lines 11 and 12. On line 20, [FENCO] should read [FENOC].
Response: Staff agrees with these editorial changes. Chapter 2 of the SEIS was revised to incorporate these changes.
Comment 26-43: FENOC is an entity. FENOC recommends changing the sentence from FENOC noted in their ER that to FENOC noted in its ER that. This issue appears in multiple locations (at least 8 instances) in the DSEIS (see Chapter 4 for more examples).
Similarly, FENOC recommends changing the statement in Line 1 on the next page from FENOCs procedures require them to coordinate with the FWS to FENOCs procedures require coordination with the FWS.
Comment 26-44: FENOC recommends changing Environmental Procedure to Environmental Evaluations procedure to match the title of the procedure.
Response: Staff agrees with these editorial changes. Chapter 3 of the SEIS was revised to incorporate these changes.
Comment 26-45: FENOC recommends deleting one of the uses of the word vicinity in the 2nd paragraph, 1st sentence.
Comment 26-46: The first sentence begins with an errant period.
Comment 26-49: The sentence at the end of the second paragraph in this section is not complete and has no period.
Response: Staff agrees with these editorial changes. Chapter 4 of the SEIS was revised to incorporate these changes.
Comment 26-50: In response to NRC requests for additional information (RAIs), the total number of SAMAs was changed from 167 to 168, and the number of SAMAs eliminated based on screening was changed from 152 to 153. (see ADAMS Accession No. ML11180A233
[FENOC Letter L-11-154 dated June 24, 2011], RAI 5.c). This comment also applies to Appendix F, Section F.1 (page F-1). However, since this Appendix is written chronologically, FENOC recommends adding the following bullet to page F-2 under the list of FENOC provided information via letter dated June 24, 2011: - identification of a new SAMA candidate (OT-9R),
which changed the total number of SAMA candidates evaluated to 168 instead of the original 167.
Comment 26-53: FENOC recommends clarifying the following two initiating event descriptions:
From: Flooding in CCW pump room To: Flooding in CCW pump room from SW [or, Service Water] and, From: Flooding in turbine building To: Flooding in turbine building from Circ A-257
Appendix A water. Also, consider noting that the % contribution to CDF values are slightly different from those reported in FENOC Environmental Report Table E.3-1 due to rounding.
Comment also applies to Appendix F, Section F.2.1, Table F-1.
Comment 26-54: FENOC recommends that the Population Dose and % Contribution be updated to match those included in FENOC Letter L-12-244 dated July 16, 2012 (see Table E.3-21). Comment also applies to Appendix F, Section F.2.1, Table F-2.
Response: Staff agrees with these editorial changes. Chapter 5 and Appendix F of the SEIS were revised to incorporate these changes.
Comment 26-51: FENOC suggests adding the text in bold/underline: In the third step, FENOC estimated the benefits and the costs associated with each of the 15 candidate SAMAs.
Comment 26-52: The text states: Column totals in Table 5.3-2 may differ due to round off.
The table reference appears to be incorrect. The correct reference is Table 5.3-1.
Comment 26-55: Suggest adding the text in bold/underline: FENOCs derivation of each of the associated costs is summarized in Appendix E of the ER.
Response: Staff agrees with these editorial changes. Chapter 5 of the SEIS was revised to incorporate these changes.
Comment 26-59: FENOC recommends changing FENOC Service Companys to FirstEnergy Service Companys.
Comment 26-61: FENOC suggests revising the acronym GGNS to read Davis-Besse.
Response: Staff agrees with these editorial changes. Chapter 8 of the SEIS was revised to incorporate these changes.
Comment 26-62: FENOC recommends changing the name Nesser to Nusser in 3 locations.
Nusser is the correct spelling according to the signature on the email included as page A-173.
Response: Staff agrees with this editorial change. Appendix A was revised to correct the spelling of the individuals name.
Comment 26-42: There are numerous references in Chapters 3 & 4 to replacement of the steam generators and that these activities will be performed during an extended outage scheduled for the spring of 2014 (e.g., Pg 3-3, lines 17-20). At the time of this review, both steam generators have been replaced and the 2014 refueling outage is nearing completion.
Consider changing the tense for steam generator replacement to past tense, although FENOC realizes that this change would impact many pages and sections of the DSEIS.
Response: Staff agrees with this comment. Chapters 3 and 4 of the SEIS have been revised to reflect that all activities that had been identified as refurbishment activities in the ER have been completed in the years since the ER was submitted. The last of the activities identified as refurbishment, steam generator replacement, was completed during the spring 2014 refueling outage.
A-258
Appendix A Comment 26-48: At the bottom of page 4-32, the first project listed under Energy Projects is the Independent Spent Fuel Storage Installation on Davis-Besse site; dry spent-fuel storage. It is not clear why the Status discusses Spent Fuel Pool and transfer pit storage versus the dry fuel storage pad and current dry fuel storage capability. On page 4-33, the 3rd PROJECT/ACTION listed (Toledo Refinery Substation Project), the LOCATION description ends abruptly Oregon, Ohio, near the intersection of.
Response: Staff agrees with these comments. Table 4-13 has been revised to include the use of the NUHOMS 24P canisters to store spent nuclear fuel. The location of the Toledo Refinery Substation Project was revised to include the correct location.
Comment 26-63: Storage of spent nuclear fuel & high-level radioactive waste:
STATUS - The word Expired should read Expires.
Comment 26-64: Permit to operate an air containment source:
STATUS - should read as follows:
Operation of station auxiliary boiler Facility ID#: 0362000091 Permit #: P0110436 Issued: 02/28/2013 Expires: 02/28/2023 Comment 26-65: NPDES Permit - Treatment of wastewater and effluent discharge to surface receiving waters (Toussaint River and Lake Erie):
STATUS - the Ohio Permit No. should read 21B00011*JD Issued: 07/01/2011 Expires: 04/3012016 Comment 26-66: Hazardous material registration:
STATUS - should read as follows:
Transportation of hazardous materials Permit Number: 052112 020 004UW Issued: 05/22/2012 Expires: 06/30/2015 (Renewed Triennially)
Comment 26-67: License to deliver radioactive waste:
STATUS - should read as follows:
Shipment of radioactive material to a licensed disposal-processing facility within the State of Tennessee Tennessee Delivery License
- T-OH003-L14 Issued: Annually Expires: 12/31/2015 Comment 26-68: New Row:
License to deliver radioactive waste:
AGENCY - should read as follows:
South Carolina Department of Health and Environmental Control AUTHORITY - should read as follows:
South Carolina Radioactive Waste Transportation and Disposal Act No. 429 of 1980 A-259
Appendix A STATUS - should read as follows:
Shipment of radioactive material to a licensed disposal-processing facility within the State of South Carolina Permit #: 0054-34-14 Issued: 12/5/2014 Expires: 12/31/2015 Comment 26-69: Underground storage tank registration:
STATUS - should read as follows:
Facility # 62000072 Expires: 06/30/2015 Comment 26-70: X-ray generating equipment registration:
STATUS - should read as follows:
Expires: 05/31/2016 Comment 26-71: Scientific Collection Permit:
STATUS - should read as follows:
Permit #: 15-112 Issued: 03/16/2014 Expires: 03/15/2015 Response: These comments provide the updated information on the Federal, State and local permits, and other authorizations FENOC has related to the operation of the Davis-Besse plant.
Appendix C of the SEIS has been revised to include this information.
Comment 26-72: The following FENOC letter is missing from the list of correspondence:
Letter L-12-244 from John C. Dominy, Davis-Besse Nuclear Power Station, Unit 1, Docket No. 50-346, License Number NPF-3, Correction of Errors in the Davis-Besse Nuclear Power Station. Unit No.1, License Renewal Application (TAC No. ME4613) Environmental Report Severe Accident Mitigation Alternatives Analysis, and License Renewal Application Amendment No. 29 (dated July 16, 2012) FENOC notes that this same correspondence is listed in Appendix F, Section F.8 (References), page F-36, Lines 34-38 (FENOC 2012a). However, the ML number listed in Appendix F is a duplicate of the ML number for FENOC letter dated June 24, 2011. Also, FENOC was not able to find the document in ADAMS using various search terms (may not be available to the public).
Response: Staff agrees with this comment. The July 16, 2012, letter has been added to Appendix E. The ADAMS Accession Number of this letter has been corrected in Appendix F of the SEIS.
Comment 26-73: FENOC suggests inserting the word are as follows: The Level 1 core damage sequences are grouped into core damage bins according to similarities in their impact on containment response.
Comment 26-74: FENOC suggests editing the quoted sentence as follows: Data from 2006 through 2008 were considered, but the 2006 data were chosen because they were the most complete data set. Data from year 2008 were considered unusable as they contained too many missing long data sequences of unusable data.
Comment 26-75: FENOC suggests adding to the following sentence the language in bold/underline: In response to an NRC staff RAI, FENOC revised the Level 3 PRA to include A-260
Appendix A that portion of the Canadian population located within the 50-mi radius SAMA analysis region (FENOC 2011).
Comment 26-77: FENOC suggests editing the quoted sentence as follows: In response to the RAIs, FENOC addressed the suggested lower cost alternatives and determined that they were already implemented at Davis-Besse (b), not feasible (c), or not cost-beneficial (a, d, e, and f)
(FENOC 2011).
Comment 26-78: The word applicants should be applicants.
Response: Staff agrees with these editorial changes. Appendix F of the SEIS was revised to incorporate these changes.
Comment 26-76: Same issue as Comment 49 [5.3.1]. Specifically, the total number of SAMAs was changed from 167 to 168, and the number of SAMAs eliminated based on screening was changed from 152 to 153.
However, since Appendix F is written chronologically, FENOC recommends adding the following sentence after line 6 on page F-18 and after line 19 on page F-35: In response to NRC RAIs, FENOCs initial list of 167 SAMA candidates was increased to 168, of which 153 were eliminated based on screening.
Response: Staff agrees that the number of SAMAs should be changed from 167 to 168, and the number that were screened out should be 153. Appendix F of the SEIS was revised to incorporate these changes. Staff does not agree that the suggested sentence needs to be added. This change was not made.
A.3.8 Opposed to License Renewal (OL)
Comment 14b-4: You must heed the lesson and shut Davis-Besse down, not allow it to limp through another score of years, creating even more uncontainable lethality for our childrens childrens children.
Comment 15-1: We must listen to our future generations. If not us, who? If not now, when?
As for me, in this generation, I will gladly live without Davis-Besse. I will gladly trade the sliver of energy produced, during my lifetime, to spare thousands of generations the poison of nuclear waste. Though make no mistake. Even if the problem of nuclear waste disposal was somehow miraculously solved, I would still gladly trade this energy source, simply to avoid the probability of a nuclear catastrophe, from the safety disaster that Davis-Besse has so proven. Shut it down.
Comment 18a-8: Im vehemently opposed to this nuclear power plant.
Comment 18b-7: Cease and desist. Stop making it period. Do not relicense. You dont know what to do with the High Level Nuclear Waste that you have already made.
Comment 19a-1: So in talking about the GEIS, and the preliminary recommendation says that there is not enough adverse environmental impacts to deny the license renewal, the Sierra Club does not agree with that. The NRC has wholly failed to acknowledge public concerns, as well as hard science, about the dangers of current and future radioactive contamination, and about nuclear power being a dated technology.
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Appendix A Comment 20-3: My children, Im afraid, arent going to be able to find a single foot of ground, in this earth, that is safe for them to be on, or air safe to breathe. And Davis-Besses license extension isnt going to help that problem. It will exacerbate it.
Comment 22-2: Davis-Besse is an old plant. As it ages more accidents will happen. Im against this renewal, and I dont think it is right. Thank you for your time.
Comment 23-1: I support closing down Davis-Besse for good. I am a Toledo resident and a mother of two children. I am fearful that other accidents in the future will threaten me as well as my childrens lives. There have been too many close calls in the past.
Comment 24-1: Living only 15 miles from Davis-Besse, I am opposed to the license renewal for 20 years. This plant is an accident waiting to happen. It has a long history of near accidents and disrepair. To renew a license here would be irresponsible of the NRC.
Comment 27-2: Davis Bessie [sic] is not needed to produce reliable power and the license needs to be denied. The above information applies only to wind power but other technologies exist that do address storage problems with solar energy. When the potential of wind power is added to both solar power and energy efficiency there is no need for energy from Davis Bessie
[sic].
Comment 28-1: Please deny the renewal of this monstrosity.
Comment 29-4: Moral hazard and corporate greed are the problem at F.E./DB and its shell companies. NRC can and should limit the damage to us and to the people who live over the next 250,000 years or so by denying the license to renew the Davis Besse nuclear power plant.
Comment 30-4: Even if repaired Davis Besse is not a good investment. As a taxpayer I am horrified the government uses my tax dollars to subsidize the nuclear industry.
Comment 30-5: Sometimes the best thing to do is to quit trying to fix a broken thing. When a car rusts out underneath, you dont keep driving it down the road even though the engine is still running. You shouldnt allow a dangerous nuclear ... aging ... power plant to keep operating.
The risk is too great.
Comment 31-1: I would like to request that the License renewal application for the Davis-Besse nuclear power plant be denied. I am very concerned about the history of chronic problems that have not be fully explained or addressed like the cracking in the concrete shield.
My concern is that these cracks weaken the plants viability in severe weather and increase vulnerabitilty [sic] to earthquakes.
Comment 32a-2: Such risky behavior by FENOC and NRC, working in collusion and complicity, cannot be endured for an additional 20 years.
Response: These comments are generally opposed to the renewal of the Davis-Besse operating license. No new information was provided in these comments, and the SEIS has not been revised as a result of these comments.
A.3.9 Outside of Scope (OS)
Comment 18a-10: It is based on economic drivers, and now we are looking at a plant that has just invested close to 6, 700 million dollars, on steam generators, which have not been scrutinized, which could not have been scrutinized, which Incadel [sic] 690 issue could have not been known, because it wasnt realized in two years ago. The NRC did that on the oversight.
The utility relied on an in-house studies, of 50/59 processing, same, same, just checking it out, A-262
Appendix A same piece of equipment going in. The steam generators that came out weighed 590 tons.
The ones that are going in 465 tons. That is not same for same. So the NRC oversight, there has been a meltdown, there is no credibility with the Nuclear Regulatory Commission.
Response: This comment is outside of the scope of the Davis-Besse license renewal environmental review because it is questioning the use of the 50.59 process for steam generator replacement. The evaluation for the replacement of the two steam generators was done under the regulations in 10 CFR 50.59, Changes, tests, and experiments. This regulation established the conditions under which licensees may make changes to the facility or procedures and conduct tests or experiments without prior NRC approval. The 50.59 evaluation looks at the effect the proposed change, test, or experiment may have on the safety analyses that are contained in the plants updated Final Safety Analysis Report (UFSAR). Prior to taking an action, a licensee must determine if the action meets the criteria listed in 10 CFR 50.59(c)(1).
If the action meets the criteria, then the licensee is required to submit an application to amend the operating license. If the action does not require an amendment to the license, then the licensee can proceed with the action. However, the licensee is required to maintain the records of changes and must include a written evaluation that provides the reasons for the determination a license amendment was not needed. For changes to the facility, the licensee is required to maintain the records for the life of the plant. These records are also the subject of inspections by NRC inspectors. NRC Inspection Report 05000346/20130101 (ML14204A317) documents the NRC staffs inspection of the Davis-Besse steam generator replacement project.
The impact to the environment from activities associated with steam generator replacement are discussed in Chapter 3 of the SEIS. No new information was presented in this question, and no changes to the SEIS were made.
Comment 19a-11: The NRC must address the increasing brittleness of the metal, and the cement, when it is in contact with the radioactivity, as the years progress.
Response: This comment related to the embrittlement of metal and concrete is outside of the scope of the Davis-Besse license renewal environmental review because it is an issue that is reviewed as part of the Davis-Besse license renewal safety review. As described in Chapter 3 of NUREG-1850, Frequently Asked Questions on License Renewal of Nuclear Power Reactors (ML061110022), embrittlement is an aging process in which material becomes more brittle and likely to fracture. In nuclear reactors, continual irradiation of material by neutrons is one of the causes of embrittlement of metal and concrete. Another cause is due to the wide temperature fluctuations that occur in the structures and components associated with producing and carrying steam. Embrittlement is reviewed as part of the safety review for license renewal.
Applicants must have programs that can detect and mitigate the effects of aging. The programs must be able to examine the systems, components, and structures and verify that they still function as they were originally designed. The program must also demonstrate that the systems, components, and structures have not been compromised or degraded. The programs related to embrittlement will be discussed in the safety evaluation report prepared to document the safety review for license renewal.
Additionally, long-term research in the areas of metal and concrete embrittlement is being performed by organizations such as the NRC, the National Institute of Standards and Technology, and the Electric Power Research Institute. NUREG-1925, Research Activities:
FY 2012-FY 2014 (ML13242A030) describes the long-term research projects being conducted by the NRC. No new information has been presented in this comment, and no changes to the SEIS were made.
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Appendix A Comment 19c-2: The NRC has failed to acknowledge that the engineered lifespan of nuclear reactors is 40 years. Extending reactor operations beyond engineered lifespans poses a considerably greater the risk of a nuclear catastrophe. The NRC has failed to address the risks of accident from increasing brittleness of metal and cement when in contact with radioactivity as years progress.
Response: This comment is outside of the scope of the Davis-Besse license renewal environmental review because it questions the lifespan of nuclear reactors. As described in Chapter 1 of NUREG-1850, Frequently Asked Questions on License Renewal of Nuclear Power Reactors (ML061110022), the Atomic Energy Act of 1954 originally specified that commercial power reactors could be granted a license for a period not exceeding 40 years and may be renewed upon the expiration of such period. The 40-year term for an operating commercial nuclear reactor was based on economic and antitrust considerations instead of the technical limitations of the plant. No new information was provided in this question, and no changes to the SEIS were made.
Comment 19c-6: Another critical factor that was not adequately addressed is evacuation of the surrounding area in case of a radioactive emergency. Across the nation and around the world, real emergencies reveal the inadequacy of disaster preparation. Loss of electric power and generator failures have consistently contributed to nuclear emergencies worldwide.
Response: This comment is outside of the scope of the Davis-Besse license renewal environmental review because it questions the emergency preparedness of the plant. As described in Chapter 4 of NUREG-1850, Frequently Asked Questions on License Renewal of Nuclear Power Reactors (ML061110022), when the regulations relating to license renewal (10 CFR Part 54) were being developed, it was determined that all nuclear power facility licensees are required to have a specific level of protection regardless of plant design, construction or license date. The regulations that pertain to all operating nuclear power facilities are in 10 CFR 50.47 and Appendix E to 10 CFR Part 50. Staff reviews the emergency preparedness plans and observes the required exercises throughout the lifetime of the plant.
Because of the ongoing review of the emergency preparedness plans, the Commission determined that a special review of emergency planning issues for license renewal was not needed. No new information was provided by this comment, and no revisions to the SEIS were made.
Comment 22-1: 801805 Revision 27 gave the plant manager permission to override QA. I reported it to the NRC. The NRC says we need this many, this much time to investigate. When I called the NRC back they had lost the file. Senators Metzenbaum and Glenn became involved, and the NRC decided to open the case again. There were three violations and a fine of 275,000 dollars. I didnt know utility companies could tell people not to go to the NRC.
Response: This comment is outside of the scope of the Davis-Besse license renewal environmental review because it relates to an allegation investigation. Anyone should feel free to communicate any safety concern to the U.S. Nuclear Regulatory Commission (NRC). It is the NRCs policy to encourage workers at NRC-regulated facilities to take safety concerns to their own management first, since the facility operator has the primary responsibility for, and is most able to ensure, safe nuclear operations. However, workers and other members of the public can bring safety concerns directly to the NRC at any time. It is the agencys responsibility to respond to those concerns in a timely manner and to protect the identity of the individual to the greatest degree possible. For more information on how to bring concerns directly to the NRC, A-264
Appendix A please refer to Brochure 0240, Reporting Safety Concerns to the NRC (NUREG/BR-0240, ML12146A003). No new information was provided in this comment, and no changes to the SEIS were made.
Comment 25-3: Based on the discussion above pertaining to the development of new permanent and temporary facilities on the Davis-Besse site, EPA understands that some parking lots will be used for new permanent or temporary facilities. The Draft SEIS does not state whether the parking lots will be permanently lost due to construction and, if so, where new parking will be located. If the parking lots are currently in use and slated for conversion to permanent or temporary facilities, new parking facilities would need to be constructed to compensate for lost parking.
Recommendation: The Final SEIS should identify which parking lots are slated for permanent conversion to permanent or temporary facilities and whether parking spaces will need to be compensated for in another area of the Davis-Besse site. Any resultant impacts should be disclosed and mitigated. If new parking facilities are required because of the new permanent and temporary refurbishment facilities, EPA recommends permeable pavement be used, reducing runoff and helping to improve the health of Lake Erie.
Response: This commenter made a recommendation that FENOC consider where new parking lots will be located if current parking lots are lost due to construction, and also the type of pavement should be considered for use. Chapter 3 of the SEIS contains the discussion of the refurbishment activities that were originally identified in the application for license renewal that was submitted in 2010. All construction of permanent and temporary facilities related to refurbishment was performed within the developed industrial area of the site on previously-disturbed land. Additionally, all activities identified as refurbishment have been completed. The last of the refurbishment activities was completed during the spring 2014 refueling outage.
However, this comment is outside of the scope of the Davis-Besse license renewal environmental review because it is recommending actions that are outside of NRCs statutory authority. The NRC does not have the authority to suggest the types of paving material to use or where to locate parking lots on plant sites. No new information was provided in this comment, and no changes were made to the SEIS because of this comment.
Comment 30-3: Just like Consumers Power promised to repair Palisades, what happened after it was relicensed? CP sold it to Entergy who still has not done the repairs CP thought necessary, and were contingent upon relicensing. The NRC has not made Entergy do the repairs, but has left it up to Entergy to decide whether the repairs are necessary or not.
Meanwhile, Palisades has had leaks, come close to meltdowns, and sump pump failure etc. ...
Davis Besse also may run the risk of being resold ... possibly to a foreign nation if they can unload it that way ... and not do repairs.
Response: This comment is outside of the scope of the Davis-Besse license renewal environmental review because it relates to the ownership of nuclear plants. Regardless of ownership, the Palisades nuclear facility is still subject to routine safety inspections, has resident inspectors on site to review operations, and still must comply with all the regulations and laws. The Atomic Energy Act of 1954, as amended, limits foreign ownership of commercial nuclear plants. The regulation in 10 CFR 50.38, Ineligibility of certain applicants, states that a company that is owned or controlled by an alien, a foreign corporation, or a foreign government is ineligible to obtain a license for a commercial nuclear plant licensed under 10 CFR Part 50.
No new information is provided in this comment, and no revisions to the SEIS were made.
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Appendix A Shield Building Cracks Comment 17b-3: The containment dome was designed to protect the nuclear core from external attacks such as tornadoes. However, since the EIS was submitted, it has come to light that the containment dome (or shield building) around the reactor core is full of large cracks.
Also the structure has been operating with large voids in the concrete shell. The initial explanation of the cracks was that they occurred during construction as a result of the blizzard of 1978. NRC and FENOC concluded that these cracks were, therefore, stable and posed no threat to the structure. However, in 2013 it was discovered that these cracks are, in fact, growing. This means that the original explanation for their formation is wrong. It also means that the structure is, by definition, unstable. Whether that instability could lead to structural failure requires study before an accurate answer can be given. The original answer, based on estimates and judgements [sic] was clearly wrong.
Comment 18a-11: And we were told that the cracks were not propagating, and everything was being looked at. A simple ultrasound would have found that. But for over two years the NRC allowed them to operate that and only found it when they came in to cut a fourth hole into that shield building, which does not meet the design criteria, does not meet seismic qualification, which will crumble around that primary containment and, potentially, tip into the reactor.
Comment 19a-12: Also the cracking of the shield building, and the determination that the cracks were the result of the blizzard of 78 was proved to be inaccurate, because the cracks are now widening, which cracks do over time.
Comment 19a-13: And the fourth cutting of through the shield building that will weaken that.
And as one engineer put it, the shield building will hold up just fine until something stresses it.
So, and then we have heard about the 25 foot gap. So we are trying to imagine how this could happen, when multiple inspectors, supposedly on the job all the time, and then also who knows how to pour concrete there?
Comment 19c-4: The NRC has failed to take into account the continued cracking of the shield building. The NRC and FENOCs original determination that the cracks were the result of the blizzard of 1978, that they were not age related and that they were not widening defied scientific credibility. That conclusion has since been proven erroneous with the lengthening and expanding of the cracks. This new cracking was found in a dozen core bore locations, leaving us to ponder what cracking actually exists throughout the entire concrete mass. The reactor was allowed to restart without the issue of the cracking being resolved. The latest, fourth cut-through of the shield building to install the new steam generators has only increased the probability of cracks enlarging over time. As one engineer put it, The shield building will hold up just fine until something stresses it.
Comment 19c-5: Then NRC must address a new contention of the 25-foot gap in the resealed cement of the shield building, revealed with the concrete forms or plates were recently removed from the previous 2011 pour. The public is incredulous as to how this gap could happen, first with multiple inspectors assigned to watch every action and second with any reasonable concrete pouring skills being used. We recently found in an ADAMS search that gaps were found in Davis-Besses previous concrete patch of 2002 when the plates were removed from the concrete pour. The Sierra Club would like an explanation as to why, considering this 2002 scenario, the plates holding the 2011 concrete pour were allowed to remain in place until recently.
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Appendix A Comment 29-2: The containment building is full of cracks, which is the only thing we know will happen with concrete, it will definitely crack, especially when its very old concrete as in the containment building.
Comment 30-2: Davis Besse has had a history of huge running cracks. Even though the cracks are patched the real problem has not been solved. What is causing the cracking?
Because cracking could lead to containment compromise, including a full blown melt down, I believe Davis Besse and its cracks should be shut down and decommissioned, not relicensed.
Response: These comments are referring to the cracks discovered in the Davis-Besse concrete Shield Building. The cracks in the Shield Building are outside of the scope of the environmental review because the cracks are being evaluated under the current licensed operations. The Shield Building is subject to an aging management review under the regulations in 10 CFR Part 54, and the staff must make a determination that FENOC can adequately manage the effects of aging on the Shield Building before issuing a renewed license. Staff is evaluating the issue and will document their findings in a safety evaluation report. No new information was presented in these comments, and the SEIS was not revised.
Loss of Offsite Power Comment 17b-7: Loss of offsite power is also estimated at twice every hundred thousand years. In April of 2013, snipers systematically destroyed a power substation near San Jose, California. It took almost a month to restore the stations function. The power grid, and its vulnerable points such as substations are a potential target for a variety of potential aggressors.
Terrorists, criminals, or agents of hostile governments could all attack vital parts of the grid system, causing prolonged loss of outside power. A study published in the May, 2014 issue of Ecological Economics, entitled Human and nature dynamics (HANDY): Modeling inequality and use of resources in the collapse or sustainability of societies suggests that we are most likely entering a period of societal instability. This instability could create multiple scenarios that would lead to long term disruption of offsite power, from severe weather events, to wars, to civil unrest. There have also been many local examples of prolonged power outages. The estimate of twice every hundred thousand years is clearly wrong. All the estimates of initiating events in Section 5 that could lead to a core meltdown are similarly, demonstrably wrong.
Response: Loss of offsite power is outside of the scope of the Davis-Besse environmental review for license renewal. Loss of offsite power resulting in station blackout is an issue that is important to current operation. If plants lose offsite power, they are required to have reliable emergency diesel generators available to provide onsite power to structures, systems, and components that are important to safety. No new information was presented in this comment, and no revisions to the SEIS were made.
High Burnup Fuel Comment 18a-3: And I see, from a document that Davis- Besse was authorized, according to amendment number 213, to move to a fuel cycle which lasted 730 days. What happens is the fuel gets super burnt up, becomes super hot, radioactively, and super hot thermally, decay. And it embrittles the actual cladding around the fuel rods. So when you pull it out of the spent fuel pool and go to put it in dry cask storage, you have a multitude of problems. It is not known how this will respond in a Yucca Mountain, or some other proposal. So the whole entire industry, for two decades, has been operating blind, and going about generating high burnup fuel.
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Appendix A Comment 18a-4: I would like to know exactly when did Davis-Besse begin their high burnup fuel cycles, and if indeed they will be projected to go for 20 additional years of high burnup fuel cycles, when it is not known what to do with this waste that wasnt considered in the beginning.
Comment 18a-5: Im going to leave with you a document, generated by a Dr. Marvin Resnikoff, within the last month or so, speaking about the high burnup nuclear fuel and how problematic it is, and it was never taken into consideration.
Comment 18b-4: New information has been coming out on the high burnup fuel that is being utilized at reactors around the U.S. that initially began in the early 90s. And I see, from a document that Davis-Besse was authorized, according to amendment number 213, to move to a fuel cycle which lasted 730 days. What happens is the fuel gets super burnt up, becomes super hot, radioactively, and super hot thermally, decay. And it embrittles the actual cladding around the fuel rods. So when you pull it out of the spent fuel pool and go to put it in dry cask storage, you have a multitude of problems. It is not known how this will respond in a Yucca Mountain, or some other proposal. So the whole entire industry, for two decades, has been operating blind, and going about generating high burnup fuel. We would like to know exactly when did Davis-Besse begin their high burnup fuel cycles, and if indeed they will be projected to go for 20 additional years of high burnup fuel cycles, when it is not known what to do with this waste that wasnt considered in the beginning. This was not addressed in the DSEIS.
Comment 19a-5: [] there was talk about the high burnup waste, and the Sierra Club would like the NRC to look at the high burnup waste.
Comment 19c-10: The issue of high burnup fuel waste must also be addressed. Even our best engineers are unsure how to properly handle out-of-water storage of this far hotter waste.
Response: These comments are related to the use and storage of high burnup fuel, which is outside of the scope of the Davis-Besse license renewal. Burnup is the energy produced by the nuclear fuel as a measure of the time the fuel assembly stays in the reactor core, usually expressed in gigawatt days per metric ton of uranium (GWD/MTU). High burnup fuel is generally defined as fuel with a burnup greater than 45 GWD/MTU. Using fuel with a high burnup allows the power plant to have longer operating cycles (usually 18 to 24 months) between refueling outages. Davis-Besse has been using high burnup fuel since the mid-1990s.
Fuel burnup is addressed as part of system design safety reviews. Staff evaluated the nuclear, thermal, mechanical, and materials design of the fuel system. Fuel burnup is one of the fuel design operating limits established to ensure fuel reliability and acceptable performance during normal operations, anticipated operational occurrences, and postulated accidents. The NRC, through the Office of Nuclear Regulatory Research, is actively participating in research activities related to high burnup fuel. NRC sponsors a number of experimental programs at Oak Ridge National Laboratory and Studsvik Nuclear AB hot cell Laboratory in Sweden to provide data.
NRC contracts with the Pacific Northwest National Laboratory for support for NRCs fuel rod computer codes. The NRC is actively engaged with international high burnup fuel research programs in Norway, France, Japan, and Sweden. More information about this can be found in NUREG-1925, Rev. 2, at:
http://www.nrc.gov/reading-rm/doc-collections/nuregs/staff/sr1925/r2/. More information concerning international activities regarding high burnup fuel can be found at:
http://www.iaea.org/gsearch/high%2Bburnup%2Bfuel.
These comments do not provide new information, and no changes were made to the SEIS.
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Appendix A Flooding Comment 18a-6: I also had problems with how the issue of flooding has been addressed. And I dont believe it properly has. Lake Erie is known for its seisches [sic] that is where the wind, straight line wind blow the lake out, and it sloshes back and forth, back and forth.
Comment 18a-7: So the whole of flooding has been inadequately addressed, and has been swept under the rug.
Comment 18b-5: We have also had problems with how the issue of flooding has been addressed. And I dont believe it properly has. Lake Erie is known for its seisches [sic] that is where the wind, straight line wind blow the lake out, and it sloshes back and forth, back and forth. In fact the recent storm, in 2012, on the East Coast, created a lot of havoc on the Great Lakes, and there were seisches [sic], over on Lake Michigan, of 30 feet high. There have been sashes [sic], historically, which have been 30 feet, 40 feet high. There have been recent seisches [sic], over near Cleveland area, that actually came up and pulled people into the water.
It does happen. We would like to reflect back in 1972, when the Davis-Besse was underwater for nearly a month. But what Im guaranteed, there is an elevation of 591, and the lake knows when to stop, and it does not come over that elevation. So the whole of flooding has been inadequately addressed, and has been swept under the rug.
Response: These comments refer to onsite flooding which is outside of the scope of the Davis-Besse license renewal. Onsite flooding is an issue related to current operation. In response to the Fukushima accident in 2011, the NRC requested nuclear power plant licensees to review their design basis with regard to flooding, seismic, tsunami and other external hazards. Work on this is ongoing, and further information can be found at:
http://www.nrc.gov/reactors/operating/ops-experience/japan-dashboard.html.
A.3.10 Postulated Accidents & SAMA (PA)
Comment 2c-1: The results of the evaluation of 167 severe accident mitigation alternatives or SAMA candidates for Davis Besse indicated no enhancements to be potentially cost beneficial for implementation at Davis-Besse and none will be implemented at Davis Besse. Of the 167 safety measures considered, 107 were eliminated based only on a quantitative cost-benefit analysis. That is, 107 recognized possible safety enhancements for continuing operations another 20 years will not be done, or required, because ... they are not cost effective. These safety features range from hardened containment vent filters to fire and flood safety measures.
All 107 safety enhancement actions were considered too expensive by both FENOC and the NRC. My comments today will try to focus on the quantitative data used to make these decisions, but the knowledge or qualitative data that is known leads to a discussion of ethical decisions that need to be made by regulators. Should safety features be required even if they are expensive? Seat belts were made mandatory to save lives and unleaded fuel was made mandatory for clean air even though they would add to the final cost to consumers. Which, if not all of Davis Besses SAMA considerations should be implemented regardless of cost?
Response: The Severe Accident Mitigation Alternatives (SAMA) analysis is an evaluation of alternatives that have the potential to reduce the risk of a severe accident. Design-basis accidents (DBA) are accidents that the plant can withstand during normal and abnormal transients, without undue hazard to the health and safety of the public. A severe accident is more severe than a DBA because it could result in substantial damage to the reactor core, whether or not there are serious offsite consequences. The SAMA analysis considers if there A-269
Appendix A are plant changes (i.e., hardware, procedures, and training) that have the potential to reduce the risk of a severe accident.
A SAMA evaluation is usually a four-step approach:
- 1. Quantify the level of risk associated with potential reactor accidents, using the plant-specific probabilistic risk assessment (PRA) and other risk models.
- 2. Examine the major risk contributors and identify possible ways (the identified SAMAs) of reducing the risk.
- 3. Estimate the benefits and costs associated with each SAMA.
- 4. Determine if the benefit of the SAMA is greater than the cost.
During the evaluation, identified SAMAs may be eliminated from further consideration because the SAMA has already been implemented, is not applicable to the plant, has an estimated implementation cost that exceeds the dollar value for eliminating all severe accident risk at the plant, is related to a non-risk significant system and has a very low benefit, or is similar in nature and could be combined with another SAMA candidate.
Chapter 5 and Appendix F of the SEIS describes FENOCs analysis for identifying SAMAs.
After a thorough review of FENOCs SAMA evaluation, the staff found that FENOC used sound methods to evaluate and screen the SAMAs. No new information is provided in this comment, and no revisions to the SEIS were made.
Comment 2c-2: In order for cost-benefit calculations to be performed all costs and benefits must be expressed in a common measure, dollars, including things not bought and sold on markets, and to which dollar prices are therefore not attached. The most dramatic example of such things is human life itself. Many of the other benefits achieved or preserved by environmental policy - such as peace and quiet, fresh-smelling air, clean water, spectacular vistas and the environment we share with other biological species - are not traded on markets either. The Nuclear Regulatory Commission (NRC) uses a dollar figure for the value of human life that is 1/2 to 1/3 the value used by other federal agencies - $3 million dollars is used by the NRC to calculate these cost-benefit analyses.
Comment 2c-3: In sharp contrast the Nuclear Regulatory Commission (NRC) uses a dollar figure for the value of human life that is roughly one third of the value used by other federal agencies- $3 million dollars. The $3 million dollar price tag can be found in the NRC regulation, NUREG-1530 section 6.6, written 2 decades ago in 1995. The regulation then proffers a discussion (since not every one dies and that they may only get cancer) a conversion factor is set at $2100 per person-rem exposure to radionuclides which is then further discounted to
$2000 per person-rem in section 8.
Comment 2c-4: It would be in the best interest of the environment and for human life itself that the Davis Besse DGEIS as well as all other nuclear power plant EISs be put on hold for revisions to the NRC VSL figures and SAMA cost analysis procedures which are expected to be revised by the end of 2014.
Response: These comments are related to the dollar amount used to assess the value of a human life. Reassessment of NRCs Dollar per Person-Rem Conversion Factor Policy, NUREG-1530, (ADAMS Accession No. ML063470485) provides guidance for monetizing the health detriment resulting from radiation exposure that is used by the NRC in evaluating whether the benefits of a proposed regulatory action exceed the costs. The NRC uses the dollar per person-rem conversion in cost-benefit analyses to determine the monetary valuation A-270
Appendix A of the consequences associated with radiological exposure and establishes the factor by multiplying a Value of Statistical Life (VSL) and a cancer coefficient. The concept of VSL is used widely throughout the Federal government to monetize the health benefits of a safety regulation. Used in this manner, VSL (and therefore the associated dollar per person-rem conversion factor) corresponds to societys willingness to pay for small reductions in a particular mortality risk. In other words, VSL is not a measurement or valuation of a human life and does not suggest that any individuals life can be expressed in monetary terms. The sole purpose of VSL (and therefore the associated dollar per person-rem conversion factor) is to help describe better the likely benefits of a regulatory action. of SECY-12-0110, Consideration of Economic Consequences with the U.S. Nuclear Regulatory Commissions Regulatory Framework, (ADAMS Accession No. ML12173A478) describes the NRCs approach to research and publish a revised conversion factor policy in the form of a NUREG. These actions and plans were updated in SECY-14-0002, Plan for Updating the U.S. Nuclear Regulatory Commissions Cost-Benefit Guidance, (ADAMS Accession No. ML13274A495). Per Commission direction provided in SRM-SECY-12-0110, the staff continues its work on determining an updated dollar per person-rem conversion factor as well as a methodology for systematically updating it in the future. Through interagency meetings, the staff is considering the VSL knowledge developed by other Federal agencies. The staff plans to engage external stakeholders and seek approval from the Commission prior to finalizing NUREG-1530. No new information was provided by these comments, and therefore, the SEIS was not revised.
Comment 17b-1: For example, the agency estimates in Appendix F (Section F.2.1) that the frequency of a core damaging accident is once every hundred thousand years. This fanciful estimate comes despite the fact that there have been numerous core damaging accidents within the last fifty years, including Enrico Fermi 1, Three Mile Island, Chernobyl, and the three nuclear meltdowns at Fukushima. A more accurate estimate, based on actual real world experience, is that nuclear plant meltdowns occur approximately once every 10 years.
Comment 17b-4: Numerous other tornadoes have touched down in the area surrounding Davis-Besse since its construction. Tornado frequency is influenced by topography. Low, flat areas like the area where DB is located are more prone to tornadoes. Also, the frequency of severe weather events such as tornadoes is predicted to increase as a result of climate change.
An estimate based on reality and real world experience suggests that the odds that Davis-Besse could be hit by an F4 or higher tornado during the period it would operate if its liscence [sic]
were renewed are much higher than 1 in 100,000. Oklahoma City, Harvest, Alabama, and Cordell, Kansas have all experienced multiple tornado strikes in the same location.
Response: The core damage frequency (CDF) used in the Davis-Besse severe accident mitigation analysis (SAMA) is based on the examination of site-specific identified accident scenarios, statistical evidence, and models at the component level. The determination of CDF takes into account the current state of knowledge as informed by science, engineering, and operating experience including lessons learned from past incidents. As evidenced by the distribution of CDF values among the U.S. nuclear fleet, individual plant designs can vary by a significant degree. Basing CDF on global statistical estimates ignores the variations in plant design, variations in operating procedures and variations in regulatory requirements. In addition, basing CDF on global statistical estimates ignores the lessons learned from past accidents including both design and procedure changes.
The NRC staff disagrees that the applicants SAMA analysis is inadequate because the CDF is not estimated generically from direct experience. The SAMA analysis for license renewal is a A-271
Appendix A Category 2 issue, which means that it should be evaluated on a site-specific basis. The applicant calculates the CDF using a plant-specific probabilistic risk assessment (PRA) model, using plant-specific fault trees, event trees, and reliability information, and which has been subject to independent peer review. This approach is consistent with the current guidance for preparing a SAMA analysis provided in Revision A of Nuclear Energy Institute (NEI) 05-01, Severe Accident Mitigation Alternatives (SAMA) Analysis, which has been endorsed by the NRC staff for use in SAMA analysis. This document provides the applicant guidance to use the plant-specific PRA model. Based on this site-specific information, the applicant estimates the severe accident risk and evaluates the economic impacts of a severe accident. No new information was provided in these comments, and no changes were made to the SEIS.
Comment 17b-2: Not surprisingly, the factors that led to NRCs incorrect estimate are also wildly wrong. Tornadoes, floods and other external events are estimated to occur, cumulatively, once every 100,000 years. On page F11, the NRC States, Based on this result, the applicant concluded that these other external hazards would be negligible contributors to overall core damage and did not consider any plant-specific SAMAs for these events. However, Davis-Besse has already been hit by a tornado. On June 24, 1998 the plant was struck by an F2 tornado. Contrary to the estimates of the NRC, this does not mean that we are good for another 100,000 years. Instead, it demonstrates that Davis-Besse is in a location that is uniquely prone to tornadoes. In fact Lake High School, less than 25 miles from Davis-Besse, was destroyed by an F4 tornado on June 5, 2010. The applicant (FENOC), is clearly wrong and it is the responsibility of the NRC to reject incorrect assertions on relicensing applications.
Tornadoes are a site specific risk for the Davis-Besse nuclear plant. The questions that need to be answered in regard to this are not When will DB be hit by another tornado? but What happens if Davis-Besse is hit by an F4 tornado, as Lake High School was?
Comment 17b-5: Similarly, flooding is estimated to occur only once every 100,000 years. But the Davis-Besse site was flooded by a seiche in November of 1972, before the plant was operational. DB is uniquely vulnerable to seiche events because of its location on Lake Erie.
While the plant does have some protective measures in place, the size and extent of those measures have been limited by the costs involved, just as the tsunami barriers were at the Fukushima nuclear plants. The NRCs four step process to judge whether or not a risk such as flooding needs to be mitigated starts with an estimation of the risk involved. This estimate has been demonstrated to be incorrect. Therefore all the other steps in the process have also produced incorrect results.
Comment 19c-1: The Sierra Club does not agree with the NRC assessment. The NRC has wholly failed to acknowledge public concern, as well as hard science, about the dangers of current and future radioactive contamination of Lake Erie, including the risks of catastrophic accident. The NRC has given unsubstantiated and inaccurate estimations of the risk of nuclear accident, flood, tornado and loss of external power. The NRC estimates in Appendix F that the frequency of a core damaging accident is once every 100,000 years, in spite of the fact that for Fermi 1, Three Mile Island, Chernobyl, and Fukushima the actual frequency has been proven to be far higher.
Response: The design basis for Davis-Besse includes criteria for protection against natural phenomena as documented in the Final Safety Analysis Report (FSAR). In accordance with NRC requirements, the design basis must include appropriate consideration of the most severe of the natural phenomena that have been historically reported for the nuclear power plant site and surrounding area.
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Appendix A The Davis-Besse SAMA analysis incorporated an estimate of CDF from High winds, tornadoes, external Floods, and Other external events (HFO) of 1.0x105. This value does not imply that tornadoes, floods, and other external events are estimated to occur, cumulatively, once every 100,000 years. Rather the HFO CDF is an estimate of the probability of the occurrence of an HFO as an initiating event that, in combination with a succession of component and/or system failures, eventually leads to core damage. Regarding consideration of tornadoes specifically, the Davis-Besse PRA model includes tornado initiating events for each of the six tornado intensity classes F0 through F5, each of which contributes high wind effects to the estimated CDF based on analysis of the plant design features.
No new information was provided in these comments, and no changes were made to the SEIS.
Comment 17b-6: One of those steps, the cost/benefit analysis, prioritizes profitability for FENOC over the public health and safety. If FENOC determines that it costs too much to mitigate or eliminate a risk, they will not do it. However, with the chances of those risks being estimated as miniscule, almost no mitigation can be justified through a cost/benefit analysis.
Turbine room flooding, for example, is estimated at once every 10 million years. No mitigation measures could be justified for something that happens so rarely. However, the Fort Calhoun nuclear plant experienced turbine room flooding in July of 2011. Clearly, it happens more frequently than once every 10 million years.
Response: The licensing basis for Davis-Besse is based on the reasonable assurance of adequate protection as documented in the Final Safety Analysis Report (FSAR). The FSAR design-basis accident analyses do not include cost benefit analyses. Rather these analyses are deterministic in nature and must meet defined regulatory acceptance criteria in order to demonstrate reasonable assurance of adequate protection.
A SAMA analysis is a systematic search for potentially cost beneficial enhancements to further reduce nuclear power plant risk. The first step of a SAMA evaluation is to identify and characterize the leading contributors to CDF and offsite risk based on a plant-specific risk study.
Table F-1 from Appendix F of NUREG-1437, Supplement 52, titled, Davis-Besse Core Damage Frequency for Internal Events, indicates that flooding in the turbine building is estimated to contribute approximately 1% to the estimated CDF from internal events. The CDF for flooding in the turbine building is estimated to be 8.8x108 per year. This value is not an estimate of the frequency of the turbine building flooding but rather an estimate of the probability of the occurrence of turbine building flooding as an initiating event that, in combination with a succession of component and/or system failures, eventually leads to core damage.
No new information was provided in these comments, and no changes were made to the SEIS.
Comment 32a-3: FENOCs SAMA analyses assume a safe, sound Shield Building capable of performing its designed containment function. However, the severe cracking known since October 2011, combined with wall gaps in resealed access openings in 2002 and 2011, seriously undermine any such optimistic assumptions. As Intervenors SAMA contentions have challenged since the beginning of this license extension application proceeding, FENOCs SAMA analyses need fundamental re-evaluation. NRCs draft EIS does not adequately address these needed SAMA re-evaluations, if it addresses them at all.
Comment 32b-2: Intervenors urge that their cracked concrete containment and Severe Accident Mitigation Alternatives (SAMA) contentions are inextricably interlinked because A-273
Appendix A FENOC assumes a functioning shield building in its SAMA analyses. Given the severe cracking and other degradation of the shield building, that assumption no longer holds water.
Response: These comments contend that the SAMA analysis is no longer valid because of the cracks that have been discovered in the concrete shield building. The SAMA analysis is a probability-weighted assessment of the benefits and costs of mitigation alternatives. In particular, the analysis evaluates the degree to which specific additional mitigation measures (e.g., new plant procedures or new hardware) may reduce the riskby reducing the probability or the consequencesof the accident scenarios evaluated. A specific mitigation alternative might reduce risk by, for example, reducing the estimated frequency of core damage or estimated frequency of containment failure in a particular accident sequence. If the cost of implementing a particular SAMA is greater than its associated benefit, the SAMA would not be considered cost-beneficial. SAMAs, in short, are rooted in a cost-benefit assessment.
As a result of the cracks discovered in the shield building, the licensee has had to demonstrate that the shield building maintains sufficient structural capacity to perform its design functions if subjected to a postulated design-basis earthquake, tornado wind, or tornado-generated missiles. The NRC staff continues to review and evaluate the licensees actions regarding the cracks as current operations and as part of the safety review for license renewal.
No new information was provided in these comments, and no changes were made to the SEIS.
Comment 32d-4: The litany of serious close calls listed above could have led to loss-of-coolant in the Davis-Besse atomic reactors core, meltdown, and a catastrophic radioactivity release on the Great Lakes shoreline, between Toledo and Cleveland. How bad might that have been in terms of casualties and property damage? The 1982 NRC and -Sandia National Lab report, Calculation of Reactor Accident Consequences, or CRAC-2, found that a major radioactivity release from Davis-Besse could cause 1,400 peak early fatalities, 73,000 peak early injuries, and 10,000 peak cancer deaths. An $84 billion figure for property damage was given.
However, population growth in the past 28 years must be accounted for, which would likely make such casualty numbers even worse today. And when adjusted for inflation to present day dollar values, property damages could now top $185 billion. And it has recently been revealed that NRC, EPA, and the Federal Emergency Management Agency (FEMA) disagree about which agency would lead the longer term clean up after a major radioactivity release, and where the funding would come from, calling into question disaster planning and severe accident mitigation analysis upon which Davis-Besses 20 year license extension approval by NRC would be based.
Response: This comment questions who will lead and who will fund the cleanup at a nuclear power plant in the event of an accident with significant amounts of radioactive material released offsite. With regards to the finding, funding to clean up after a major release of radioactivity would be as established by the Price-Anderson Act which became law on September 2, 1957.
The Price-Anderson Act covers liability claims of members of the public for personal injury and property damage caused by a nuclear accident at a commercial nuclear power plant. The liability limit for a nuclear accident has increased over time to an insurance pool of more than
$12 billion. Owners of nuclear power plants pay an annual premium of $375 million in private insurance for offsite liability coverage for each reactor site. If the cost of cleanup of the accident exceeds the $375 million, then each utility would be assessed a prorated share of the excess amount, up to $121 million per reactor. After this money is depleted, then Congress will determine whether additional disaster relief is required. NRC regulations (10 CFR 50.54(w))
require licensees to maintain a minimum of $1.06 billion in onsite property insurance at each A-274
Appendix A reactor site. This requirement was added after the accident at Three Mile Island to ensure that licensees would be able to cover cleanup costs resulting from a nuclear accident.
With regards to who leads the federal response, President Obama signed Presidential Policy Directive (PPD)-8: National Preparedness in March 2011 to enhance the Nations ability to prepare for and respond to the threats that pose the greatest danger to the United States.
PPD-8 required the development of a National Planning System that integrates planning across all levels of government and with the private and non-profit sector to provide an agile and flexible approach to prevent, protect, mitigate, respond, and recover from threats that pose the greatest risk to the Nation, including severe accidents at nuclear power facilities. National Planning Frameworks that describe the key roles and responsibilities for delivering the capability to prevent, protect, mitigate, respond, and recover from serious threats are part of the National Planning System.
The National Recovery Framework (NRF) is the guide to how the Nation responds to all types of disasters and emergencies. The NRF uses the concepts identified in the National Incident Management System (NIMS) to align key roles and responsibilities. NIMS is a guide for how departments and agencies at all levels of government, nongovernmental organizations, and the private sector work together to manage incidents. In July 2015, the State of South Carolina is sponsoring the Southern Exposure 2015 Exercise which is designed to test and analyze the ability of State, Federal, and local governments, to respond to and recover from an emergency at a nuclear power plant. The Southern Exposure 2015 Exercise will coincide with the H.B. Robinson Nuclear Power Plants biennial emergency preparedness exercise. The State of South Carolina, with a number of local governments and Federal agencies, such as NRC, U.S. Department of Energy, Federal Emergency Management Agency, and U.S. Department of Agriculture, will work together during a radiological release incident and afterwards during recovery activities.
The Nuclear/Radiological Incident Annex (NRIA) to the NRF describes the policies, situations, concepts of operations, and responsibilities of the Federal departments and agencies governing the immediate response and short-term recovery activities for incidents involving release of radioactive materials to address the consequences of the event. The purpose of this annex is to:
Define the roles and responsibilities of Federal agencies in responding to the unique characteristics of different categories of nuclear/radiological incidents.
Discuss the specific authorities, capabilities, and assets the Federal Government has for responding to nuclear/radiological incidents that are not otherwise described in the NRF.
Discuss the integration of the concept of operations with other elements of the NRF, including the unique organization, notification, and activation processes and specialized incident-related actions.
Provide guidelines for notification, coordination, and leadership of Federal activities.
Because there are several categories of potential incidents and impacted entities, this annex identifies different Federal agencies as coordinating agencies and cooperating agencies and associated strategic concepts of operations based on the authorities, responsibilities, and A-275
Appendix A capabilities of those departments or agencies. In addition, this annex describes how other Federal departments and agencies support the Department of Homeland Security (DHS) when DHS leads a large-scale multiagency Federal response.
This comment provided no new information and, therefore, no changes were made to the SEIS.
Comment 32e-2: FENOC recently admitted five major errors in its Severe Accident Mitigation Alternatives (SAMA) analyses, submitted with its Environmental Report in its license extension application. These include: An inaccurate land area conversion factor for acres to hectares was used; Dollar values for Ohio farmland and non-farmland used as inputs to the MELCOR Accident Consequence Code System (MACCS2) software used in support of the SAMA Analysis were not appropriate; The escalation of decontamination costs used in the SAMA Analysis was not performed per the guidance of Nuclear Energy Institute (NEI) 05-01 Severe Accident Mitigation Alternatives (SAMA) Analysis Guidance Document, November 2005, using the consumer price index; Use of core inventory isotopic activity instead of isotopic mass in the Modular Accident Analysis Program (MAAP) software code runs did not reflect updated industry guidance; The wind direction from the Davis-Besse Meteorological Tower was not converted from the blowing from direction to the blowing toward direction for use in the SAMA Analysis calculations. The data from the Davis-Besse Meteorological Tower is received in the blowing from direction. However, the MACCS2 software requires wind direction data inputs to be provided in the blowing toward direction. The data conversion was not performed properly.
Each of these mistakes could well mean that predictions of casualties and property damage resulting from a catastrophic radioactivity release at Davis-Besse have been dangerously under-estimated by FENOC itself, a point the environmental coalition has already alleged for two years.
Response: On August 27, 2010, FENOC submitted a license renewal application, which included a SAMA analysis as part of the Environmental Report. The NRC staff had reviewed the SAMA analysis submitted with the license renewal application and, by letter dated April 20, 2011 (ML110910566), sent a request for additional information (RAI) on the original SAMA analysis. FENOC provided responses to the RAI on June 24, 2011 (ML11180A233).
In January 2012, FENOC notified the NRC staff that four errors had been identified in the SAMA analysis that was submitted as part of the August 2010 license renewal application. FENOC redid the SAMA analysis, correcting those four errors. During the review of the corrected draft, an additional error was discovered. The five errors were corrected, and a corrected SAMA analysis was submitted to the NRC on July 16, 2012 (ML12200A024). FENOC also reviewed the responses to the April 2011 RAI and discovered that a number of the RAI responses needed to be revised based on the corrected SAMA analysis. The corrected RAI responses were submitted as part of the July 16, 2012, submittal. The NRC staff reviewed FENOCs corrected SAMA analysis and concluded that the methods used and the implementation of the methods was sound. The staffs evaluation of the updated SAMA evaluation is documented in Chapter 5 and Appendix F of the SEIS.
This comment provided no new information and, therefore, no changes were made to the SEIS.
A.3.11 Radioactive & Non-Radioactive Waste (RW)
Comment 14a-2: The problem is, is that table S-3, that is -- appears in the NRC regulations, contain a discussion of the nuclear fuel waste disposition cycle. And it assumes that there will be, essentially, perfect containment.
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Appendix A Comment 14a-4: The problem is that Table S-3 presumes that a repository built in salt formations is going to be stable and that, that presumption, that assumption may be about to be undermined for all time.
Comment 14a-3: But the point that the intervenors, in Davis-Besse, are here to make tonight, is that there is serious, recent, new information that calls into question table S-3, the very assumption on which plants like Davis-Besse are allowed, originally, to be licensed and allowed to be, to have their licenses renewed.
That the assumption being we can take care of the waste problem, it will be contained, there wont be forever problems posed to our childrens childrens, childrens children.
Comment 14b-3: I understand that there is an ongoing rulemaking proceeding over waste confidence, but the point the Intervenors in the Davis-Besse license renewal case are here to make to you, tonight, is that there is serious recent new information that calls into question the Table S-3 assumptions that allowed Davis-Besse to be licensed in the first place, much less granted an extension. The NEPA document for the LRA cannot be considered thorough and fully disclosing without scientific reconsideration of the assumption that the dangerous garbage from nuclear fissioning will not pose horrific hazards to less-informed and more vulnerable populations in the poorer which are likely to be found in the, overpopulated world of the future.
Response: These comments refer to Table S-3 in 10 CFR Part 51, Table of Uranium Fuel Cycle Environmental Data. Environmental impacts associated with the uranium fuel cycle as they apply to license renewal are discussed in Section 4.12.1 of the 2013 GEIS (ML13106A241). The discussion in the GEIS encompasses the applicability and adequacy of Table S-3 in 10 CFR Part 51.51. The conclusion is that the assumptions and methodology used in preparing Table S-3 were conservative enough that the impacts described by the use of Table S-3 would still be bounding for the purposes of discussing the impacts associated with the uranium fuel cycle as applied to license renewal. No new information was provided in this comment, and no changes to the SEIS were made.
Comment 14b-2: Intervenors in the NRCs pending waste confidence decisionmaking process have warned, authoritatively, of the dangers of storing high-level radioactive waste in salt formations.
Comment 18a-9: To generate one more ounce of nuclear waste is immoral, because we do not know what to do with what we have. All we have gotten was a Waste Confidence, a con game, we will figure out what to do with it later.
Comment 18b-6: To generate one more ounce of nuclear waste is immoral, because we do not know what to do with what we have. All we have gotten was a Waste Confidence, a con game, we will figure out what to do with it later. Now, many people look at Yucca Mountain, what a failure Yucca Mountain was. Yucca Mountain is a tremendous success because for 27 years it kept the lie alive, that you knew what to do with it, you dont. You are just kicking it down the road, it is immoral what you are doing. It is now known you dont know what to do with it. And I would argue that the Nuremberg principles do apply here, today, in the actions that decisionmakers make going forward. Because it is not based on science.
Comment 19a-3: The NRC must also address the most serious issue of nuclear reactors outside of an accident, or meltdown, which is of course, the radioactive waste.
Comment 19a-4: So the NRC must address the environmental impact of Davis-Besses waste, for the next few hundred generations. And the whole business of when the Waste Confidence A-277
Appendix A was overturned, by the Court, that meant it should be overturned, they should drop it, they should start looking at the waste.
Comment 19a-6: The Sierra Club, we have signed on to the principles for safeguarding nuclear waste at reactors. So what that, what those organizations that have signed on to that have, what it has said, it must be stored as close, as safely possible, to the site of generation.
Comment 19a-7: It cant be left on Prairie Island, in the middle of the Mississippi River. You know, those places, it must be moved off of there. But it cant, at the same time, it cant be moved out to Nevada, because that increases the risk of accidents along the way. And the waste must not be put where it cannot be retrieved, and resealed. So what we are talking about is a rolling custody of the waste for generations to come.
Comment 19c-9: The NRC has failed to address the most serious issue of nuclear reactors, outside of an accident or meltdown, which is the generation of hundreds of tons of highly radioactive waste. Waste that will be around far longer than FirstEnergy or the United States government, or anything resembling the civilization that we have today. Kicking the radioactive can down the road - saddling future generations with the problems and the expense of isolating our generations nuclear waste, is irresponsible at best and criminal at worst. The NRC should include in their assessment the environmental impact of Davis-Besses waste for the next few hundred generations.
Comment 21-1: I have had the same objection, the entire time, since before they built it, what are you going to do with the waste?
Comment 21-2: I live in Michigan now, but my water comes from Toledo, which comes from Lake Erie. Im concerned that we have storage that is going to stay at this plant forever.
Comment 29-3: NRC should consider the cost of storing, guarding, and monitoring the nuclear waste generated by another 20 years of Russian Roulette type operation of and at Davis Besse, Comment 30-1: Davis Besse creates nuclear waste. There is no solution to the safe storage of nuclear waste. It remains toxic for longer than anyone can guarantee its safe storage. There is no way to dispose of it that would not endanger the environment sooner or later. When businesses pollute, they should be shut down.
Comment 31-2: I am particularly concerned about the pollution produced by nuclear waste produced by the plant and potential impact of continued accumulating pollution on the health of my family, especially my grandchildren.
Comment 32d-2: Davis-Besses indoor pool for storing high-level radioactive wastes was packed to the gills by the mid-1990s, at which point it proposed loading horizontal outdoor bunkers (unfortified) of concrete and steel - dry storage casks - to serve as overflow parking. NRC identified serious problems with 3 of the NUHOMS dry storage casks, manufactured by Vectra Technologies (later taken over by Transnuclear, Inc., a subsidiary of the French government owned nuclear giant Cogema, now called Areva) fully loaded with irradiated nuclear fuel at Davis-Besse. The casks were discovered to have been built below technical specifications: the aggregate used to fabricate the casks outer concrete walls -
essential for radiation shielding -- was poor quality, and the steel alloy walls of the inner metallic canisters actually containing the irradiated nuclear fuel were ground too thin along the weld lines, in violation of technical specifications. The Toledo Coalition for Safe Energy challenged the safety and quality assurance of this proposal in 1994, but was overruled by NRC, which allowed loading of casks to begin in 1995. These faulty casks remain fully loaded with high-level radioactive waste onsite at Davis-Besse to this day, 15 years later.
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Appendix A The vast majority of Davis-Besses irradiated nuclear fuel is still stored in its pool - vulnerable to cooling water drain downs or boil offs due to accident (such as heavy load drops), natural disaster (such as tornadoes), or intentional terrorist attacks. Without cooling water, wastes in the pool could catch fire within hours, resulting in 25,000 latent cancer deaths, due to large amounts of such hazardous radioactive isotopes as Cesium-137 escaping in the smoke and blowing downwind, depositing lethal fallout as far away as 500 miles. However, as time goes on, more and more dry casks are being loaded with older irradiated nuclear fuel at Davis-Besse, in order to free up room in the storage pool for the hellishly hot and radioactive rods just removed from the operating reactor core during re-fueling outages.
Dry casks themselves are vulnerable to accidents, are not designed to withstand terrorist attacks, and will eventually degrade with exposure to the elements and need to be unloaded and replaced with new containers. NRC recently updated its Nuclear Waste Confidence Findings and Rule, asserting that the nations spent nuclear fuel can be safely stored for at least 60 years beyond the licensed life of any reactor and that sufficient repository capacity will be available when necessary. NRCs confidence in the opening of a repository is suspect:
President Obama has cancelled the proposed Yucca Mountain, Nevada repository, the only deep geologic dumpsite to be studied for high-level radioactive waste disposal in the U.S. for the past 23 years. NRC is thus perpetrating a con game, on the American people, and blocking any consideration of irradiated nuclear fuel generation risks in new reactor combined construction and operating license application proceedings, as well as in old reactor license extension proceedings, such as the one now underway at Davis-Besse.
Thus, NRC has already blessed high-level radioactive wastes remaining at Davis-Besse for a century, until 2077. If NRC rubberstamps a 20 year license extension, the irradiated nuclear fuel could remain onsite until 2097. However, the NRC Commissioners have also directed the NRC staff to conduct additional analysis for [even] longer-term storage, ordering staff to submit a plan to the Commission for the long-term rulemaking by the end of the calendar year [2010].
Thus, NRC could soon approve irradiated nuclear fuel remaining at Davis-Besse - on the shoreline of the Great Lakes, 20% of the worlds surface fresh water, and drinking supply for 40 million people -- for centuries into the future, despite the safety, security, health, and environmental risks.
High-level radioactive wastes are one of the most hazardous substances ever generated by humankind. While electricity is but a fleeting byproduct, irradiated nuclear fuel will remain deadly and need to be isolated from the living environment forevermore. Without radiation shielding, it can deliver a lethal dose of gamma radiation in seconds or minutes, even decades after removal from the reactor. Alpha particle emitters, however, such as Plutonium-239 -- a microscopic speck of which, if inhaled, could initiate lung cancer -- will remain hazardous for hundreds of thousands of years. Other radioactive isotopes will remain deadly far longer -
Iodine-129, for example, has a 157 million year hazardous persistence.
Response: These comments are all related to the long-term storage of nuclear waste and the Continued Storage Rule. The License Renewal Generic Environmental Impact Statement (GEIS); NUREG-1437 addresses the onsite storage of SNF during the 20-year license renewal period. The GEIS concluded that the impact of onsite storage of SNF during the 20-year license renewal term would be SMALL and that the issue was generic to all nuclear power plants. The Davis-Besse SEIS discussion in Chapter 6 tiers off the GEISs discussion and conclusion. The NRC identified no new and significant information related to the storage of SNF during the 20-year license renewal period during its independent review of FENOCs ER, the scoping process, or the site audit. Therefore, the NRC staff concluded that there would be no impact during the license renewal term beyond those discussed in the GEIS.
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Appendix A For the period beyond the licensed life for reactor operations, on August 26, 2014, the Commission approved a revised rule at 10 CFR 51.23 and associated Generic Environmental Impact Statement for Continued Storage of Spent Nuclear Fuel (NUREG-2157, ADAMS Accession No. ML14188B749). Subsequently, on September 19, 2014, the NRC published the revised rule (79 FR 56238) in the Federal Register along with NUREG-2157 (79 FR 56263).
The revised rule adopts the generic impact determinations made in NUREG-2157 and codifies the NRCs generic determinations regarding the environmental impacts of continued storage of spent nuclear fuel beyond a reactors operating license (i.e., those impacts that could occur as a result of the storage of spent nuclear fuel at at-reactor or away-from-reactor sites after a reactors licensed life for operation and until a permanent repository becomes available).
Under 10 CFR 51.23, the impact determinations in NUREG-2157 regarding continued storage are deemed incorporated into the NRCs environmental impact statements for reactor and independent spent fuel storage installation (ISFSI) licenses. NUREG-2157 supports the revised rule and includes, among other things, the staffs analyses related to the particular deficiencies identified by the D.C. Circuit in the vacated Waste Confidence decision and rule. The NRC staffs consideration of the issues identified by the D.C. Circuit was aided considerably by the publics extensive participation in the process, including comments received during scoping, on the draft NUREG-2157 and revised rule, and participation in nationwide public meetings, among other things. The information in NUREG-2157 was developed using an open and public process and the findings in NUREG-2157 are codified by rule in 10 CFR 51.23.
In CLI-14-08 (ADAMS Accession No. ML14252A721), the Commission held that the revised 10 CFR 51.23 and associated NUREG-2157 cure the deficiencies identified by the court in New York and stated that the rule satisfies the NRCs NEPA obligations with respect to continued storage for initial, renewed, and amended licenses. Because the impact determinations in NUREG-2157 regarding continued storage are deemed incorporated into this Davis-Besse FSEIS, Chapter 6 of this FSEIS now contains an analysis for the generic issues of Onsite storage of spent nuclear fuel and Offsite radiological impacts of spent nuclear fuel and high-level waste disposal that satisfies NEPA. As the Commission noted in CLI-14-08, the NRC staff must account for these environmental impacts before finalizing its licensing decision in this proceeding. The NRC staff accounted for the impacts determined in NUREG-2157 and incorporated the impacts into Chapter 6 of this FSEIS.
The revised Continued Storage rule does not require any changes to the management (i.e., handling, storage, and disposition) of SNF at a reactor site. As previously stated, the revised 10 CFR 51.23 documents the environmental impacts of continued storage of SNF.
Therefore, there are no potential changes in direct, indirect, and cumulative impacts that result from the revised rule.
The comments provide no new and significant information for this environmental review (as specified in 10 CFR 51.95(c)(3)) and are not evaluated. However, as stated above, the NRC staff revised Chapter 6 of this FSEIS to incorporate the revised 10 CFR 51.23 rule and NUREG-2157 to address the environmental impacts associated with the continued storage of spent nuclear fuel.
Comment 14a-1: It is our opinion that circumstances, in recent weeks, which have happened in a comparative obscure media environment, have seriously undermined the assumptions that have given rise to the GEIS conclusion, the Waste Confidence conclusion, that nuclear power plants, like Davis-Besse, can continue in operation, generating incredibly lethal waste products from fissioning, and that there would be adequate measures to contain the dangers from that waste for the forever period of time that it will be necessary to do so. On February 4th, 2014, A-280
Appendix A the assumptions of very low probability crumbled at the Energy Departments Waste Isolation Pilot Plant, which is, the short name is WIPP, W-I-P-P, near Carlsbad, New Mexico.
Comment 14b-1: It is our opinion that circumstances in recent weeks in New Mexico have seriously undermined the assumptions that have given rise to the generic conclusion that nuclear power plants like Davis-Besse can be allowed to continue in operation, generate incredibly lethal waste products from fissioning, and that there will be adequate measures in place to keep those deadly genies bottled up for the necessary tens or hundreds of thousands of years.
Response: These two comments are out of scope of the Davis-Besse license renewal but are related to radioactive waste storage. On Friday, February 14, 2014, there was an accident at the Department of Energy (DOE) Waste Isolation Pilot Plant (WIPP) in Carlsbad, New Mexico, which resulted in the release of americium and plutonium from one or more of the transuranic (TRU) waste containers inside the facility. The release was detected by a continuous air monitor that is positioned underground. Some of the material released was directed through high-efficiency particulate air (HEPA) filters. However, a measureable amount of the radioactive material bypassed the HEPA filters and was released directly to the environment from an exhaust duct. Twenty-one individuals initially tested positive for low levels of americium and plutonium. On February 27, 2014, DOE appointed an Accident Investigation Board to investigate the radiological release. In April 2014, DOE released, Accident Investigation Report, Phase 1: Radiological Release Event at the Waste Isolation Pilot Plant on February 14, 2014. This Phase 1 report focused on mechanisms of the radioactive material releases and corrective actions needed so that this type of release would not happen again.
Phase 2 will focus on determining the direct cause of the accident. Information on the accident at WIPP can be found at: http://www.wipp.energy.gov/wipprecovery/accident_desc.html. These comments provided no new information. Therefore, the SEIS was not revised as a result of these comments.
A.3.12 Support of License Renewal (SL)
Comment 3a-1: Continued, long-term operation, of the plant will allow the Davis-Besse Nuclear Power Station, to maintain its commitment to education in Ottawa County, and beyond, both through annual tax contributions and the public outreach activities conducted by its dedicated professionals. This is an invaluable contribution to our communities that will benefit students for generations to come.
Comment 3b-1: I know I speak for educators across northwest Ohio when I say that Davis-Besse serves an important role supporting the educational backbone of our communities.
In fact the plant provides more than 5.8 million dollars, locally, in annual property taxes which provide a direct and substantial benefit to our school district.
Comment 4-1: And it would also be devastating, I believe, to Ottawa County. IBEW 1413 believes that the approval of the additional 20 year license for Davis-Besse is not an option, but a must. The Draft Environmental Impact Statement supports this position and indicates that the impact, from extending the life of the plant is minimal, at most.
Comment 5-1: Our nuclear energy facilities provide substantial economic benefits to the state, and the local community, including high paying jobs, and tax revenue, that help to fund local services, and help to keep property taxes much lower than they otherwise would be.
Comment 6-1: And I think it is imperative that you go along with this process. Local 245 supports the approval of the license renewal, and we ask for your approval, also.
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Appendix A Comment 7-1: Davis-Besse has provided a clean and safe place for our associates to work, and provide for their families, while providing reliable power for our communities. And I strongly support the extension of the operating license.
Comment 8-1: Im here today to support the license renewal application that will allow Davis-Besse to operate through 2037.
Comment 9-1: In fact, we believe it is necessary to preserve the economic stability of our area with the renewal. Livelihoods and jobs depend on affordable energy. Davis-Besse provides that as a resource, and we encourage the NRC to work with First Energy to renew the license.
Comment 10a-1: Because of First Energys high standards, and commitment to excellence, in the nuclear industry, we feel that an extension of the existing license is a positive step forward and should be granted to First Energy.
Comment 10b-1: Because of First Energys highest standards, and a commitment to excellence in the nuclear industry, we feel that an extension of this licensing is a positive step forward, and it should be granted to First Energy. Thank you.
Comment 12-1: Today I would like to focus my comments on the jobs aspect. Without license renewal northwest Ohio would suffer economically, with the loss of more than 700 stable, well-paying jobs.
Comment 13-1: In closing, nuclear power must continue to produce safe, reliable, electricity as a part of our countrys diverse energy portfolio. I strongly support the issuance of an additional 20 year operating license for Davis-Besse which will afford our region continued production of reliable power. This is vital to maintaining a business friendly environment, not just in Ottawa County, but in supporting the prosperity of northwest Ohio.
Response: These comments are in support of Davis-Besses license renewal and will not be addressed further. The comments provide no new information, and the SEIS has not been revised as a result of these comments.
A.3.13 Terrestrial Resources (TR)
Comment 1-1: The biggest impact, I would believe, would the aviary resources, because they are going to have the quickest emission, and quickest exposure to the facility, here, if there is a leakage or a release of radiation, because they are going to be airborne. And we are on the Black Swamp, which is one of the biggest flyways in North America. I mean, North America, South America, the butterflies come through here, the birds come through here, many, many other organisms come here.
Comment 2a-2: Davis-Besse rests on the crossroads of two major migration pathways, both east and west, from the Atlantic to the Pacific, and from the North Pole to the South Pole. Some of these new identified species are migratory.
Response: As part of the license renewal review, the staff considered impacts to both State-and Federally-listed species. In 2010, the NRC staff initiated consultation with U.S. Fish and Wildlife Service (FWS) and National Marine Fisheries Service (NMFS) regarding the presence of threatened and endangered species in the vicinity of Davis-Besse. By letter dated December 21, 2010, NMFS informed staff that there were no species listed under the jurisdiction of NMFS to occur in the vicinity of Davis-Besse.
In Section 2.2.8.4 of the SEIS, the NRC staff identified the eastern pondmussel as occurring in Ottawa County, and therefore, conclusions regarding impacts to aquatic resources in SEIS A-282
Appendix A Section 4.6 and protected species and habitats in SEIS Section 4.8 are inclusive of this species.
The rayed bean, which is a Federally endangered species, does not occur in Ottawa County according to U.S. Fish and Wildlife (FWS) records. During Endangered Species Act section 7 consultation between the NRC and FWS, the FWS did not identify the rayed bean as being potentially affected by the proposed license renewal. For these reasons, the NRC did not consider this species in the SEIS. The comment provides no new and significant information, and the NRC staff did not revise the SEIS as a result of this comment.
Comment 17b-11: In addition to impacts on humans, essential information on the impact on the flora and fauna of the study area has been omitted. There is extensive description an quantification of the birds in the area, for example, and a very brief mention is made of ways that birds could be impacted by Davis-Besses cooling towers is listed, but a detailed discussion of the severity of that impact is omitted. A 2009 study done by Benjamin K. Sovacool entitled, Contextualizing avian mortality: A preliminary appraisal of bird and bat fatalities from wind power, fossil-fuel, and nuclear electricity presented to the Energy Governance Program, Centre on Asia and Globalisation, Lee Kuan Yew School of Public Policy, National University of Singapore, Singapore 259772, Singapore and found online at:
http://www.nukefree.org/news/avianmortalityfromwindpower,fossil-fuel,andnuclearelectricity suggests that Davis Besse could be killing 3,000 to 5,000 birds every year. Thus, avian impacts should be reclassified as LARGE.
Response: Section 4.3.5.2 of the 1996 Generic Environmental Impact Statement for License Renewal of Nuclear Plants (GEIS; NUREG-1437) addressed the potential for birds to collide with cooling towers. After reviewing plant-specific analyses, including a study conducted at Davis-Besse from 1972-1979, the NRC concluded that avian mortality resulting from collisions of birds with cooling towers is a generic (Category 1) issue and would be of SMALL significance for all plants during the license renewal term because it is unlikely that losses of birds from collisions would threaten the stability of local populations or result in a noticeable impairment of the function of a species within local ecosystems. In the 2013 GEIS, the NRC reconsidered whether the finding of SMALL remained valid. The NRC combined the issue of bird collisions with cooling towers and bird collisions with transmission lines into one issue (bird collisions with plant structures and transmission lines) and considered findings in past license renewal reviews as well as new studies or information on the potential effects of bird collisions. The NRC concluded that this issue should remain a Category 1 issue with a conclusion of SMALL. During the NRCs review of the Davis-Besse license renewal application, the staff did not identify any new and significant information that would call into question this finding, and thus, the conclusion of SMALL remains appropriate for this issue.
The 2009 Sovacool article referenced by the commenter mentions the 1972-1979 study conducted at Davis-Besse. The article provides no new or significant information about bird mortality at Davis-Besse that was not already considered in the 1996 GEIS, the 2013 GEIS, or the Davis-Besse SEIS. The NRC staff did not revise the SEIS as a result of this comment.
Endangered Species Comment 2a-1: I want to ask, first, about the slide on the threatened and endangered species.
What date did the Ohio DNR provide that information to you? Do you know the date that that information was provided? You have listed four species. Today there are actually six endangered species in Ottawa County and there is, actually, evidence of two more. With A-283
Appendix A this new information I believe a Generic Environmental Impact Statement would not be adequate.
Comment 2b-1: In addition to surveying the property for birds, insects, turtles, and snakes, the group also sampled Lake Erie for aquatic critters including fish and mussels. Assisted by University of Toledo graduate student Todd Crail, the Young Birders Club was able to document the state endangered Eastern Pond Mussel and the Rayed Bean Mussel, a species that is currently being considered for the United States Endangered Species List.
Response: As part of the license renewal review, the staff considered impacts to both State-and Federally-listed species. In 2010, the NRC staff initiated consultation with U.S. Fish and Wildlife Service (FWS) and National Marine Fisheries Service (NMFS) regarding the presence of threatened and endangered species in the vicinity of Davis-Besse. By letter dated December 21, 2010, NMFS informed staff that there were no species listed under the jurisdiction of NMFS to occur in the vicinity of Davis-Besse.
In Section 2.2.8.4 of the SEIS, the NRC staff identified the eastern pondmussel as occurring in Ottawa County, and therefore, conclusions regarding impacts to aquatic resources in SEIS Section 4.6 and protected species and habitats in SEIS Section 4.8 are inclusive of this species.
The rayed bean, which is a Federally endangered species, does not occur in Ottawa County according to U.S. Fish and Wildlife (FWS) records. During Endangered Species Act section 7 consultation between the NRC and FWS, the FWS did not identify the rayed bean as being potentially affected by the proposed license renewal. For these reasons, the NRC did not consider this species in the SEIS. The comment provides no new and significant information, and the NRC staff did not revise the SEIS as a result of this comment.
Comment 25-2: Section 3.2.1, Terrestrial Resources - Refurbishment Impacts, details several refurbishment activities, including two permanent storage facilities, one permanent multi-story office building, and several temporary facilities. The temporary facilities may include a permanent base concrete pad. The Draft SEIS states that all land disturbed for construction and refurbishment-related activities will be previously disturbed land, such as mowed areas, parking lots, or other paved surfaces. These activities will lead to an increase in impervious surfaces. As discussed in section 4.15.3, Cumulative Impacts on Aquatic Resources, urbanization and shoreline development are major stressors on the health of Lake Erie.
Avoiding impacts to wetlands and reducing the amount of impervious surfaces along the lake help reduce this stress.
Recommendations: EPA has several recommendations regarding the construction of the permanent and temporary facilities on the Davis-Besse site. EPA encourages the applicant to site and organize construction projects to minimize impacts to surrounding habitats. It is unclear if the permanent base concrete pad for temporary facilities is even necessary, since it is only under consideration at this time. Any unnecessary permanent, impervious areas are discouraged. EPA recommends staggering construction schedules of the new facilities so that no additional habitat is directly disturbed. This could mean having one temporary laydown area that services the construction of new permanent facilities one at a time, reducing the amount of disturbed habitat. Any new buildings and surrounding areas should be designed to Leadership in Energy and Environmental Design (LEED) standards. If LEED standards are pursued, this information should be included in the Final SEIS. Any potential use of Energy Star appliances, EPAs WaterSense program, EPAs GreenScapes program, or other similar programs should be identified in the Final SEIS. These are important elements of reducing the overall environmental impact of the proposed project.
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Appendix A Response: The refurbishment activities discussed in Chapter 3 of the SEIS have been completed. Additionally, these recommendations are outside of the statutory authority granted the NRC by the Atomic Energy Act of 1954, as amended. Nevertheless, the NRC has included EPAs recommendations for ways to further mitigate environmental impacts during refurbishment in Section 3.2.1 of the SEIS.
A.4 Comment Letter and Meeting Transcripts for the Draft Supplemental Environmental Impact Statement The following pages contain the comments, identified by commenter designation and comment number, from letters and the transcripts from the public meetings on the draft supplemental EIS.
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APPENDIX B NATIONAL ENVIRONMENTAL POLICY ACT ISSUES FOR LICENSE RENEWAL OF NUCLEAR POWER PLANTS
B.NATIONAL ENVIRONMENTAL POLICY ACT ISSUES FOR LICENSE RENEWAL OF NUCLEAR POWER PLANTS NUREG-1437, Generic Environmental Impact Statement for License Renewal of Nuclear Power Plants (referred to as the GEIS), document the results of the U.S. Nuclear Regulatory Commission (NRC) staffs (staffs) systematic approach to evaluating the environmental impacts of renewing the licenses of individual nuclear power plants. The GEIS was originally published in 1996 and Addendum 1 to the GEIS, which only addresses transportation issues, was published in 1999. Of the 92 total environmental issues that the staff identified in the 1996 GEIS, the staff determined that 69 are generic to all plants (Category 1), while 21 issues must be discussed on a site-specific basis (Category 2). Two other issues, environmental justice and the chronic effects of electromagnetic fields, are uncategorized and must be evaluated on a site-specific basis.
Table B-1 in this appendix lists all 92 environmental issues, including the possible environmental significance (SMALL, MODERATE, LARGE, or uncategorized) as appropriate.
This table is provided in Chapter 9 of the 1996 GEIS.
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 (10 CFR) Part 51, Environmental protection regulations for domestic licensing and related regulatory functions.
Specifically, 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. A revised GEIS (NRC 2013b), which updates the 1996 GEIS, provides the technical basis for the final rule. The revised GEIS specifically supports the revised list of NEPA issues and associated environmental impact findings for license renewal contained in Table B-1 in Appendix B to Subpart A of the revised 10 CFR Part 51. The revised GEIS and final rule reflect lessons learned and knowledge gained during previous license renewal environmental reviews.
In addition, public comments received on the draft revised GEIS and rule and during previous license renewal environmental reviews were reexamined to validate existing environmental issues and identify new ones.
This SEIS, which discusses the environmental impacts associated with Davis-Besse license renewal, is reviewed against the criteria from the 1996 GEIS. However, new issues identified, or recategorized, in the 2013 GEIS are also included in this SEIS. The new Category 1 issues identified in the 2013 GEIS which are discussed and evaluated in this SEIS are geology and soils, exposure of terrestrial organisms to radionuclides, exposure of aquatic organisms to radionuclides, human health impact from chemicals, and physical occupational hazards. New Category 2 issues that are addressed in this SEIS are radionuclides released to groundwater, effects on terrestrial resources (non-cooling system impacts), minority and low-income populations (i.e., environmental justice), and cumulative impacts.
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Appendix B Table B-1. Generic Summary Findings on NEPA Issues for License Renewal of Nuclear Power Plants Type of Issue Finding Issue Surface water quality, hydrology, and use Impacts of SMALL. Impacts are expected to be negligible during refurbishment on Generic refurbishment because best management practices are expected to surface water be employed to control soil erosion and spills.
quality Impacts of SMALL. Water use during refurbishment will not increase refurbishment on Generic appreciably or will be reduced during plant outage.
surface water use Altered current SMALL. Altered current patterns have not been found to be a patterns at intake Generic problem at operating nuclear power plants and are not expected to and discharge be a problem during the license renewal term.
structures SMALL. Salinity gradients have not been found to be a problem at Altered salinity Generic operating nuclear power plants and are not expected to be a gradients problem during the license renewal term.
Altered thermal SMALL. Generally, lake stratification has not been found to be a stratification of Generic problem at operating nuclear power plants and is not expected to lakes be a problem during the license renewal term.
Temperature SMALL. These effects have not been found to be a problem at effects on Generic operating nuclear power plants and are not expected to be a sediment transport problem during the license renewal term.
capacity SMALL. Scouring has not been found to be a problem at most Scouring caused operating nuclear power plants and has caused only localized by discharged Generic effects at a few plants. It is not expected to be a problem during the cooling water license renewal term.
SMALL. Eutrophication has not been found to be a problem at Eutrophication Generic operating nuclear power plants and is not expected to be a problem during the license renewal term.
Discharge of SMALL. Effects are not a concern among regulatory and resource chlorine or other Generic agencies, and are not expected to be a problem during the license biocides renewal term.
Discharge of SMALL. Effects are readily controlled through National Pollutant sanitary wastes Discharge Elimination System (NPDES) permit and periodic Generic and minor modifications, if needed, and are not expected to be a problem chemical spills during the license renewal term.
SMALL. These discharges have not been found to be a problem at Discharge of other operating nuclear power plants with cooling-tower-based heat metals in Generic dissipation systems and have been satisfactorily mitigated at other wastewater plants. They are not expected to be a problem during the license renewal term.
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Appendix B Type of Issue Finding Issue Water use SMALL. These conflicts have not been found to be a problem at conflicts (plants Generic operating nuclear power plants with once-through heat dissipation with once-through systems.
cooling systems)
Water use conflicts (plants SMALL OR MODERATE. The issue has been a concern at nuclear with cooling ponds power plants with cooling ponds and at plants with cooling towers.
or cooling towers Site-specific Impacts on instream and riparian communities near these plants using makeup could be of moderate significance in some situations. See water from a small § 51.53(c)(3)(ii)(A).
river with low flow)
Aquatic ecology SMALL. During plant shutdown and refurbishment, there will be negligible effects on aquatic biota because of a reduction of Refurbishment Generic entrainment and impingement of organisms or a reduced release of chemicals.
SMALL. Accumulation of contaminants has been a concern at a Accumulation of few nuclear power plants but has been satisfactorily mitigated by contaminants in Generic replacing copper alloy condenser tubes with those of another metal.
sediments or biota It is not expected to be a problem during the license renewal term.
Entrainment of SMALL. Entrainment of phytoplankton and zooplankton has not phytoplankton and Generic been found to be a problem at operating nuclear power plants and zooplankton is not expected to be a problem during the license renewal term.
SMALL. Cold shock has been satisfactorily mitigated at operating nuclear plants with once-through cooling systems, has not endangered fish populations, or been found to be a problem at Cold shock Generic operating nuclear power plants with cooling towers or cooling ponds, and is not expected to be a problem during the license renewal term.
Thermal plume SMALL. Thermal plumes have not been found to be a problem at barrier to migrating Generic operating nuclear power plants and are not expected to be a fish problem during the license renewal term.
SMALL. Thermal discharge may have localized effects but is not Distribution of Generic expected to affect the larger geographical distribution of aquatic aquatic organisms organisms.
SMALL. Premature emergence has been found to be a localized Premature effect at some operating nuclear power plants but has not been a emergence of Generic problem and is not expected to be a problem during the license aquatic insects renewal term.
SMALL. Gas supersaturation was a concern at a small number of Gas operating nuclear power plants with once-through cooling systems supersaturation but has been satisfactorily mitigated. It has not been found to be a Generic (gas bubble problem at operating nuclear power plants with cooling towers or disease) cooling ponds and is not expected to be a problem during the license renewal term.
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Appendix B Type of Issue Finding Issue SMALL. Low dissolved oxygen has been a concern at one nuclear power plant with a once-through cooling system but has been Low dissolved effectively mitigated. It has not been found to be a problem at oxygen in the Generic operating nuclear power plants with cooling towers or cooling ponds discharge and is not expected to be a problem during the license renewal term.
Losses from predation, parasitism, and SMALL. These types of losses have not been found to be a disease among Generic problem at operating nuclear power plants and are not expected to organisms be a problem during the license renewal term.
exposed to sublethal stresses SMALL. Stimulation of nuisance organisms has been satisfactorily Stimulation of mitigated at the single nuclear power plant with a once-through nuisance cooling system where previously it was a problem. It has not been Generic organisms found to be a problem at operating nuclear power plants with (e.g., shipworms) cooling towers or cooling ponds and is not expected to be a problem during the license renewal term.
Aquatic ecology (for plants with once-through and cooling-pond heat dissipation systems)
SMALL, MODERATE, OR LARGE. The impacts of entrainment are small at many plants but may be moderate or even large at a few plants with once-through and cooling-pond cooling systems.
Entrainment of fish Further, ongoing efforts in the vicinity of these plants to restore fish and shellfish in Site-specific populations may increase the numbers of fish susceptible to intake early life stages effects during the license renewal period, such that entrainment studies conducted in support of the original license may no longer be valid. See § 51.53(c)(3)(ii)(B).
SMALL, MODERATE, OR LARGE. The impacts of impingement Impingement of are small at many plants but may be moderate or even large at a Site-specific fish and shellfish few plants with once-through and cooling-pond cooling systems.
See § 51.53(c)(3)(ii)(B).
SMALL, MODERATE, OR LARGE. Because of continuing concerns about heat shock and the possible need to modify thermal Heat shock Site-specific discharges in response to changing environmental conditions, the impacts may be of moderate or large significance at some plants.
See § 51.53(c)(3)(ii)(B).
Aquatic ecology (for plants with cooling-tower-based heat dissipation systems)
Entrainment of fish SMALL. Entrainment of fish has not been found to be a problem at and shellfish in Generic operating nuclear power plants with this type of cooling system and early life stages is not expected to be a problem during the license renewal term.
SMALL. The impingement has not been found to be a problem at Impingement of Generic operating nuclear power plants with this type of cooling system and fish and shellfish is not expected to be a problem during the license renewal term.
SMALL. Heat shock has not been found to be a problem at Heat shock Generic operating nuclear power plants with this type of cooling system and is not expected to be a problem during the license renewal term.
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Appendix B Type of Issue Finding Issue Groundwater use and quality SMALL. Extensive dewatering during the original construction on Impacts of some sites will not be repeated during refurbishment on any sites.
refurbishment on Generic Any plant wastes produced during refurbishment will be handled in groundwater use the same manner as in current operating practices and are not and quality expected to be a problem during the license renewal term.
Groundwater use conflicts (potable and service water; SMALL. Plants using less than 100 gpm are not expected to cause Generic plants that use any groundwater use conflicts.
<100 gallons per minute (gpm)
Groundwater use conflicts (potable SMALL, MODERATE, OR LARGE. Plants that use more than and service water, Site-specific 100 gpm may cause groundwater use conflicts with nearby and dewatering groundwater users. See § 51.53(c)(3)(ii)(C).
plants that use
>100 gpm)
Groundwater use conflicts (plants SMALL, MODERATE, OR LARGE. Water use conflicts may result using cooling from surface water withdrawals from small water bodies during low towers Site-specific flow conditions which may affect aquifer recharge, especially if withdrawing other groundwater or upstream surface water users come online makeup water before the time of license renewal. See § 51.53(c)(3)(ii)(A).
from a small river)
SMALL, MODERATE, OR LARGE. Ranney wells can result in Groundwater use potential groundwater depression beyond the site boundary.
conflicts (Ranney Site-specific Impacts of large groundwater withdrawal for cooling tower makeup wells) at nuclear power plants using Ranney wells must be evaluated at the time of application for license renewal. See § 51.53(c)(3)(ii)(C).
SMALL. Groundwater quality at river sites may be degraded by Groundwater induced infiltration of poor-quality river water into an aquifer that quality supplies large quantities of reactor cooling water. However, the Generic degradation lower quality infiltrating water would not preclude the current uses (Ranney wells) of groundwater and is not expected to be a problem during the license renewal term.
Groundwater quality SMALL. Nuclear power plants do not contribute significantly to degradation Generic saltwater intrusion.
(saltwater intrusion)
Groundwater quality SMALL. Sites with closed-cycle cooling ponds may degrade degradation Generic groundwater quality. Because water in salt marshes is brackish, (cooling ponds in this is not a concern for plants located in salt marshes.
salt marshes)
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Appendix B Type of Issue Finding Issue Groundwater SMALL, MODERATE, OR LARGE. Sites with closed-cycle cooling quality ponds may degrade groundwater quality. For plants located inland, degradation Site-specific the quality of the groundwater in the vicinity of the ponds must be (cooling ponds at shown to be adequate to allow continuation of current uses. See inland sites) § 51.53(c)(3)(ii)(D).
Terrestrial ecology SMALL, MODERATE, OR LARGE. Refurbishment impacts are insignificant if no loss of important plant and animal habitat occurs.
Refurbishment However, it cannot be known whether important plant and animal Site-specific impacts communities may be affected until the specific proposal is presented with the license renewal application. See
§ 51.53(c)(3)(ii)(E).
Cooling tower SMALL. Impacts from salt drift, icing, fogging, or increased impacts on crops humidity associated with cooling tower operation have not been Generic and ornamental found to be a problem at operating nuclear power plants and are vegetation not expected to be a problem during the license renewal term.
SMALL. Impacts from salt drift, icing, fogging, or increased Cooling tower humidity associated with cooling tower operation have not been impacts on native Generic found to be a problem at operating nuclear power plants and are plants not expected to be a problem during the license renewal term.
SMALL. These collisions have not been found to be a problem at Bird collisions with Generic operating nuclear power plants and are not expected to be a cooling towers problem during the license renewal term.
Cooling pond impacts on SMALL. Impacts of cooling ponds on terrestrial ecological Generic terrestrial resources are considered to be of small significance at all sites.
resources Power line right of way (ROW) management SMALL. The impacts of ROW maintenance on wildlife are Generic (cutting and expected to be of small significance at all sites.
herbicide application)
Bird collisions with SMALL. Impacts are expected to be of small significance at all Generic power lines sites.
Impacts of SMALL. No significant impacts of electromagnetic fields on electromagnetic Generic terrestrial flora and fauna have been identified. Such effects are fields on flora and not expected to be a problem during the license renewal term.
fauna SMALL. Periodic vegetation control is necessary in forested Floodplains and wetlands underneath power lines and can be achieved with minimal wetland on power Generic damage to the wetland. No significant impact is expected at any line ROW nuclear power plant during the license renewal term.
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Appendix B Type of Issue Finding Issue Threatened and endangered species SMALL, MODERATE, OR LARGE. Generally, plant refurbishment and continued operation are not expected to adversely affect Threatened or threatened or endangered species. However, consultation with endangered Site-specific appropriate agencies would be needed at the time of license species renewal to determine whether or not threatened or endangered species are present and whether or not they would be adversely affected. See § 51.53(c)(3)(ii)(E).
Air quality SMALL, MODERATE, OR LARGE. Air quality impacts from plant refurbishment associated with license renewal are expected to be Air quality during small. However, vehicle exhaust emissions could be cause for refurbishment concern at locations in or near nonattainment or maintenance (non-attainment Site-specific areas. The significance of the potential impact cannot be and maintenance determined without considering the compliance status of each site areas) and the number of workers expected to be employed during the outage. See § 51.53(c)(3)(ii)(F).
Air quality effects SMALL. Production of ozone and oxides of nitrogen is insignificant of transmission Generic and does not contribute measurably to ambient levels of these lines gases.
Land use SMALL. Projected onsite land use changes required during refurbishment and the renewal period would be a small fraction of Onsite land use Generic any nuclear power plant site and would involve land that is controlled by the applicant.
SMALL. Ongoing use of power line ROWs would continue with no Power line ROW Generic change in restrictions. The effects of these restrictions are of small significance.
Human health Radiation SMALL. During refurbishment, the gaseous effluents would result exposures to the in doses that are similar to those from current operation. Applicable Generic public during regulatory dose limits to the public are not expected to be refurbishment exceeded.
SMALL. Occupational doses from refurbishment are expected to Occupational be within the range of annual average collective doses experienced radiation Generic for pressurized-water reactors and boiling-water reactors.
exposures during Occupational mortality risk from all causes including radiation is in refurbishment the mid-range for industrial settings.
Microbiological SMALL. Occupational health impacts are expected to be controlled organisms Generic by continued application of accepted industrial hygiene practices to (occupational minimize exposure to workers.
health)
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Appendix B Type of Issue Finding Issue Microbiological organisms (public health) (plants SMALL, MODERATE, OR LARGE. These organisms are not using lakes or expected to be a problem at most operating plants except possibly canals, or cooling Site-specific at plants using cooling ponds, lakes, or canals that discharge to towers or cooling small rivers. Without site-specific data, it is not possible to predict ponds that the effects generically. See § 51.53(c)(3)(ii)(G).
discharge to a small river)
SMALL. Noise has not been found to be a problem at operating Noise Generic plants and is not expected to be a problem at any plant during the license renewal term.
SMALL, MODERATE, OR LARGE. Electrical shock resulting from direct access to energized conductors or from induced charges in Electromagnetic metallic structures have not been found to be a problem at most fields - acute Site-specific operating plants and generally are not expected to be a problem effects (electric during the license renewal term. However, site-specific review is shock) required to determine the significance of the electric shock potential at the site. See § 51.53(c)(3)(ii)(H).
UNCERTAIN. Biological and physical studies of 60-hertz (Hz)
Electromagnetic electromagnetic fields have not found consistent evidence linking fields - chronic Uncategorized harmful effects with field exposures. However, research is effects continuing in this area and a consensus scientific view has not been reached.
Radiation exposures to SMALL. Radiation doses to the public will continue at current levels Generic public (license associated with normal operations.
renewal term)
Occupational SMALL. Projected maximum occupational doses during the license radiation renewal term are within the range of doses experienced during Generic exposures (license normal operations and normal maintenance outages, and would be renewal term) well below regulatory limits.
Socioeconomic impacts SMALL, MODERATE, OR LARGE. Housing impacts are expected to be of small significance at plants located in a medium or high population area and not in an area where growth control measures that limit housing development are in effect. Moderate or large Housing impacts Site-specific housing impacts of the workforce associated with refurbishment may be associated with plants located in sparsely populated areas or in areas with growth control measures that limit housing development. See § 51.53(c)(3)(ii)(I).
Public services:
public safety, SMALL. Impacts to public safety, social services, and tourism and social services, Generic recreation are expected to be of small significance at all sites.
and tourism and recreation B-8
Appendix B Type of Issue Finding Issue SMALL OR MODERATE. An increased problem with water Public services: shortages at some sites may lead to impacts of moderate Site-specific public utilities significance on public water supply availability. See
§ 51.53(c)(3)(ii)(I).
SMALL, MODERATE, OR LARGE. Most sites would experience Public services:
impacts of small significance but larger impacts are possible education Site-specific depending on site- and project-specific factors. See (refurbishment)
§ 51.53(c)(3)(ii)(I).
Public services:
education (license Generic SMALL. Only impacts of small significance are expected.
renewal term)
Offsite land use SMALL OR MODERATE. Impacts may be of moderate significance Site-specific (refurbishment) at plants in low population areas. See § 51.53(c)(3)(ii)(I).
Offsite land use SMALL, MODERATE, OR LARGE. Significant changes in land use (license renewal Site-specific may be associated with population and tax revenue changes term) resulting from license renewal. See § 51.53(c)(3)(ii)(I).
SMALL, MODERATE, OR LARGE. Transportation impacts (level of service) of highway traffic generated during plant refurbishment and during the term of the renewed license are generally expected to be Public services:
Site-specific of small significance. However, the increase in traffic associated transportation with the additional workers and the local road and traffic control conditions may lead to impacts of moderate or large significance at some sites. See § 51.53(c)(3)(ii)(J).
SMALL, MODERATE, OR LARGE. Generally, plant refurbishment and continued operation are expected to have no more than small Historic and adverse impacts on historic and archaeological resources.
archaeological Site-specific However, the National Historic Preservation Act requires the resources Federal agency to consult with the State Historic Preservation Officer to determine whether or not there are properties present that require protection. See § 51.53(c)(3)(ii)(K).
Aesthetic impacts Generic SMALL. No significant impacts are expected during refurbishment.
(refurbishment)
Aesthetic impacts SMALL. No significant impacts are expected during the license (license renewal Generic renewal term.
term)
Aesthetic impacts of transmission SMALL. No significant impacts are expected during the license Generic lines (license renewal term.
renewal term)
Postulated accidents Design basis SMALL. The staff has concluded that the environmental impacts of Generic accidents design-basis accidents are of small significance for all plants.
B-9
Appendix B Type of Issue Finding Issue SMALL. The probability weighted consequences of atmospheric releases, fallout onto open bodies of water, releases to groundwater, and societal and economic impacts from severe Severe accidents Site-specific accidents are small for all plants. However, alternatives to mitigate severe accidents must be considered for all plants that have not considered such alternatives. See § 51.53(c)(3)(ii)(L).
Uranium fuel cycle and waste management Offsite radiological SMALL. Offsite impacts of the uranium fuel cycle have been impacts (individual considered by the Commission in Table S-3 of this part. Based on effects from other Generic information in the GEIS, impacts on individuals from radioactive than the disposal gaseous and liquid releases including radon-222 and of spent fuel and technetium-99 are small.
high level waste)
The 100-year environmental dose commitment to the U.S. population from the fuel cycle, high level waste, and spent fuel disposal excepted, is calculated to be about 14,800 person rem, or 12 cancer fatalities, for each additional 20-year power reactor operating term. Much of this, especially the contribution of radon releases from mines and tailing piles, consists of tiny doses summed over large populations. This same dose calculation can theoretically be extended to include many tiny doses over additional thousands of years as well as doses outside the United States.
The result of such a calculation would be thousands of cancer fatalities from the fuel cycle, but this result assumes that even tiny doses have some statistical adverse health effect which will not ever be mitigated (for example no cancer cure in the next thousand years), and that these doses projected over thousands of years are Offsite radiological meaningful; however, these assumptions are questionable. In impacts (collective Generic particular, science cannot rule out the possibility that there will be effects) no cancer fatalities from these tiny doses. For perspective, the doses are very small fractions of regulatory limits, and even smaller fractions of natural background exposure to the same populations.
Nevertheless, despite all the uncertainty, some judgment as to the regulatory NEPA implications of these matters should be made and it makes no sense to repeat the same judgment in every case.
Even taking the uncertainties into account, the Commission concludes that these impacts are acceptable in that these impacts would not be sufficiently large to require the NEPA conclusion, for any plant, that the option of extended operation under 10 CFR Part 54 should be eliminated. Accordingly, while the Commission has not assigned a single level of significance for the collective effects of the fuel cycle, this issue is considered Category 1 (Generic).
B-10
Appendix B Type of Issue Finding Issue For the high level waste and spent fuel disposal component of the fuel cycle, there are no current regulatory limits for offsite releases of radionuclides for the current candidate repository site. However, if it is assumed that limits are developed along the lines of the 1995 National Academy of Sciences (NAS) report, Technical Bases for Yucca Mountain Standards, and that in accordance with the Commissions Waste Confidence Decision, 10 CFR 51.23, a repository can and likely will be developed at some site which will comply with such limits, peak doses to virtually all individuals will be 100 millirem per year or less. However, while the Commission has reasonable confidence that these assumptions will prove correct, there is considerable uncertainty since the limits are yet to be developed, no repository application has been completed or reviewed, and uncertainty is inherent in the models used to evaluate possible pathways to the human environment. The NAS report indicated that 100 millirem per year should be considered as a starting point for limits for individual doses, but notes that some measure of consensus exists among national and international bodies that the limits should be a fraction of the 100 millirem per year. The lifetime individual risk from 100 millirem annual dose limit
-3 is about 3x10 .
Estimating cumulative doses to populations over thousands of years is more problematic. The likelihood and consequences of events that could seriously compromise the integrity of a deep Offsite radiological geologic repository were evaluated by the Department of Energy in impacts (spent fuel the Final Environmental Impact Statement: Management of Generic Commercially Generated Radioactive Waste, October 1980. The and high level waste disposal) evaluation estimated the 70-year whole-body dose commitment to the maximum individual and to the regional population resulting from several modes of breaching a reference repository in the year of closure, after 1,000 years, after 100,000 years, and after 100,000,000 years. Subsequently, the NRC and other federal agencies have expended considerable effort to develop models for the design and for the licensing of a high level waste repository, especially for the candidate repository at Yucca Mountain. More meaningful estimates of doses to population may be possible in the future as more is understood about the performance of the proposed Yucca Mountain repository. Such estimates would involve very great uncertainty, especially with respect to cumulative population doses over thousands of years. The standard proposed by the NAS is a limit on maximum individual dose. The relationship of potential new regulatory requirements, based on the NAS report, and cumulative population impacts has not been determined, although the report articulates the view that protection of individuals will adequately protect the population for a repository at Yucca Mountain. However, the EPAs generic repository standards in 40 CFR Part 191 generally provide an indication of the order of magnitude of cumulative risk to population that could result from the licensing of a Yucca Mountain repository, assuming the ultimate standards will be within the range of standards now under consideration. The standards in 40 CFR Part 191 protect the population by imposing the amount of radioactive material released over 10,000 years. The cumulative release limits are based on the B-11
Appendix B Type of Issue Finding Issue EPAs population impact goal of 1,000 premature cancer deaths worldwide for a 100,000 metric ton (MT) repository.
Nevertheless, despite all the uncertainty, some judgment as to the regulatory NEPA implications of these matters should be made and Offsite radiological it makes no sense to repeat the same judgment in every case.
impacts (spent fuel Even taking the uncertainties into account, the Commission and high level concludes that these impacts are acceptable in that these impacts waste disposal) would not be sufficiently large to require the NEPA conclusion, for (cont.) any plant, that the option of extended operation under 10 CFR Part 54 should be eliminated. Accordingly, while the Commission has not assigned a single level of significance for the impacts of spent fuel and high level waste disposal, this issue is considered in Category 1 (Generic).
Nonradiological SMALL. The nonradiological impacts of the uranium fuel cycle impacts of the Generic resulting from the renewal of an operating license for any plant are uranium fuel cycle found to be small.
SMALL. The comprehensive regulatory controls that are in place and the low public doses being achieved at reactors ensure that the radiological impacts to the environment will remain small during the term of a renewed license. The maximum additional onsite land that may be required for low-level waste storage during the term of a renewed license and associated impacts will be small.
Low-level waste storage and Generic Nonradiological impacts on air and water will be negligible. The disposal radiological and nonradiological environmental impacts of long-term disposal of low-level waste from any individual plant at licensed sites are small. In addition, the Commission concludes that there is reasonable assurance that sufficient low-level waste disposal capacity will be made available when needed for facilities to be decommissioned consistent with NRC decommissioning requirements.
SMALL. The comprehensive regulatory controls and the facilities and procedures that are in place ensure proper handling and storage, as well as negligible doses and exposure to toxic materials for the public and the environment at all plants. License renewal will not increase the small, continuing risk to human health and the Mixed waste environment posed by mixed waste at all plants. The radiological storage and Generic and nonradiological environmental impacts of long-term disposal of disposal mixed waste from any individual plant at licensed sites are small. In addition, the Commission concludes that there is reasonable assurance that sufficient mixed waste disposal capacity will be made available when needed for facilities to be decommissioned consistent with NRC decommissioning requirements.
SMALL. The expected increase in the volume of spent fuel from an additional 20 years of operation can be safely accommodated on Onsite spent fuel Generic site with small environmental effects through dry or pool storage at all plants if a permanent repository or monitored retrievable storage is not available.
SMALL. No changes to generating systems are anticipated for Nonradiological Generic license renewal. Facilities and procedures are in place to ensure waste continued proper handling and disposal at all plants.
B-12
Appendix B Type of Issue Finding Issue SMALL. The impacts of transporting spent fuel enriched up to 5 percent uranium-235 with average burnup for the peak rod to current levels approved by NRC up to 62,000 megawatt days per metric-ton uranium (MWd/MTU)and the cumulative impacts of transporting high-level waste to a single repository, such as Yucca Mountain, Nevada are found to be consistent with the impact values Transportation Generic contained in 10 CFR 51.52(c), Summary Table S Environmental Impact of Transportation of Fuel and Waste to and from One Light-Water-Cooled Nuclear Power Reactor. If fuel enrichment or burnup conditions are not met, the applicant must submit an assessment of the implications for the environmental impact values reported in § 51.52.
Decommissioning SMALL. Doses to the public will be well below applicable regulatory standards regardless of which decommissioning method Radiation doses Generic is used. Occupational doses would increase no more than 1 man-rem caused by buildup of long-lived radionuclides during the license renewal term.
SMALL. Decommissioning at the end of a 20-year license renewal Waste period would generate no more solid wastes than at the end of the Generic management current license term. No increase in the quantities of Class C or greater than Class C wastes would be expected.
SMALL. Air quality impacts of decommissioning are expected to be Air quality Generic negligible either at the end of the current operating term or at the end of the license renewal term.
SMALL. The potential for significant water quality impacts from erosion or spills is no greater whether decommissioning occurs Water quality Generic after a 20-year license renewal period or after the original 40-year operation period, and measures are readily available to avoid such impacts.
SMALL. Decommissioning after either the initial operating period or Ecological Generic after a 20-year license renewal period is not expected to have any resources direct ecological impacts.
SMALL. Decommissioning would have some short-term socioeconomic impacts. The impacts would not be increased by Socioeconomic Generic delaying decommissioning until the end of a 20-year relicense impacts period, but they might be decreased by population and economic growth.
Environmental justice Environmental NONE. The need for and the content of an analysis of Uncategorized justice environmental justice will be addressed in plant-specific reviews.
Source: 61 FR 28467, June 5, 1996 B-13
APPENDIX C APPLICABLE REGULATIONS, LAWS, AND AGREEMENTS
C.APPLICABLE REGULATIONS, LAWS, AND AGREEMENTS The Atomic Energy Act of 1954 (AEA) authorizes states to establish programs to assume U.S. Nuclear Regulatory Commission (NRC) regulatory authority for certain activities. For example, in accordance with Section 274 of the AEA, as amended, beginning on August 31, 1999, the State of Ohio assumed regulatory responsibility over the following:
byproduct materials as defined in Section 11e.(1) of the Act; byproduct materials as defined in Section 11e.(2) of the Act; source materials; special nuclear materials in quantities not sufficient to form a critical mass; the regulation of the land disposal of byproduct, source, or special nuclear waste materials received from other persons; and the evaluation of radiation safety information on sealed sources or devices containing byproduct, source, or special nuclear materials and the registration of the sealed sources or devices for distribution, as provided for in regulations or orders of the NRC.
The Ohio Agreement State Program is administered by the Bureau of Radiation Protection in the Ohio Department of Health.
In addition to implementing some Federal programs, state legislatures develop their own laws.
State statutes supplement as well as implement Federal laws for protection of air, water quality, and groundwater. State legislation may address Solid Waste Management Programs, locally rare or endangered species, and historic and cultural resources.
In addition, the Clean Water Act (CWA) allows for primary enforcement and administration through state agencies, provided the state program is at least as stringent as the Federal program and conforms to the CWA and delegation of authority for the Federal National Pollutant Discharge Elimination System (NPDES) Program from the Environmental Protection Agency (EPA) to the state. The primary mechanism to control water pollution is the requirement that direct dischargers to obtain an NPDES permit or in the case of states where the authority has been delegated from the EPA, a State Pollutant Discharge Elimination System (SPDES) permit, pursuant to the CWA.
One important difference between Federal regulations and certain state regulations is the definition of waters regulated by the state. Certain state regulations may include underground waters while the CWA only regulates surface waters.
C.1 Federal & State Environmental Requirements Certain environmental requirements, including some discussed earlier, may have been delegated to state authorities for implementation, enforcement, or oversight. Table C-1 provides a list of representative state environmental requirements that may affect license renewal applications (LRAs) for nuclear power plants.
C-1
Appendix C Table C-1. Federal and State Environmental Requirements Davis-Besse Nuclear Power Station, Unit No. 1 (Davis-Besse) is subject to numerous state requirements regarding their environmental program. Those requirements are briefly described below.
Agency Law/Regulation Requirements Environmental Protection Regulations for Domestic Title 10 of the Code of Licensing and Related Regulatory Functions. This part NRC Federal Regulations contains environmental protection regulations applicable to (CFR) Part 51 the NRCs domestic licensing and related regulatory functions.
Requirements for Renewal of Operating Licenses for Nuclear Power Plants. This part focuses on managing adverse effects of aging rather than identification of all aging NRC 10 CFR Part 54 mechanisms. The rule is intended to ensure that important systems, structures, and components (SSCs) will continue to perform their intended function in the period of extended operation.
Regulations promulgated by the NRC pursuant to the Atomic Energy Act of 1954, as amended (68 Stat. 919), and Title II of the Energy Reorganization Act of 1974 (88 Stat. 1242), to provide for the licensing of production and utilization facilities. This part also gives notice to all NRC 10 CFR Part 50 persons who knowingly provide to any licensee, applicant, contractor, or subcontractor, components, equipment, materials, or other goods or services, that relate to a licensees or applicants activities subject to this part, that they may be individually subject to NRC enforcement action for violation of § 50.5.
Air quality protection Ambient Air Quality & Primary ambient air quality standards define levels of air Emergency Episode quality, which are necessary, with an adequate margin of Ohio EPA, Standards safety, to protect the public health. Secondary ambient air Division of Air quality standards define levels of air quality, which are Pollution Control Ohio Administrative necessary to protect the public welfare from any known or Code Chapter 3745-25 anticipated adverse effects of a pollutant.
This chapter provides requirements for installation, Permits to Install New modification, and operation of new and existing air Ohio EPA, Sources of Pollution contaminant sources at facilities that are not subject to Division of Air Chapter 3745-77 of the Administrative Code. This chapter Pollution Control Ohio Administrative also provides requirements for installation and modification Code Chapter 3745-31 of air contaminant sources at facilities that are, or will be, subject to Chapter 3745-77 of the Administrative Code.
The Clean Air Act (CAA) is the law that defines EPAs responsibilities for protecting and improving the nations air Clean Air Act (CAA) quality and the stratospheric ozone layer. The CAA EPA (42 U.S.C. § 7401 requires EPA to set National ambient air quality standards et seq.) for six common air pollutantsparticle pollution (often referred to as particulate matter), ground-level ozone, carbon monoxide, sulfur oxides, nitrogen oxides, and lead.
C-2
Appendix C Agency Law/Regulation Requirements Coastal zone protection The Congress finds and declares that it is the National policy to do the following:
- to preserve, protect, develop, and where possible, to restore or enhance, the resources of the Nations coastal Coastal Zone zone for this and succeeding generations and U.S. Department Management Act of
- to encourage and assist the states to effectively exercise of Commerce 1972 their responsibilities in the coastal zone through the (16 U.S.C. § 1451-1464) development and implementation of management programs to achieve wise use of the land and water resources of the coastal zone, giving full consideration to ecological, cultural, historic, and esthetic values as well as the needs for compatible economic development.
Ohio Department of Natural Ohio Coastal In an effort to balance diverse economic and environmental Resources Management Program interests, the Ohio Coastal Management Program sets forth Office of Coastal Ohio Administrative the guidelines for use of Ohios coastal resources to ensure Zone Code Chapter 1506 their continued benefit for this and future generations.
Management Water resources protection The NPDES permit is required for plant industrial, sanitary, Clean Water Act (CWA) and storm water discharges to waters of the state. The EPA (33 U.S.C. § 1251 NPDES permit requires the compliance of each point source et seq.) with authorized discharge levels, monitoring requirements, and other appropriate requirements.
Section 401 Water Quality Certification of the CWA requires a Section 401 water quality certification and payment of Section 401 of the CWA EPA applicable fees before the issuance of a Federal permit or (33 U.S.C. § 1341) license to conduct any activity that may result in any discharge to waters of the state.
Section 404 of the CWA established a program to regulate the discharge of dredged and fill material into waters of the U.S., including wetlands. The U.S. Army Corps of Engineers (USACE) and the EPA jointly administer this Section 404 of the CWA program. Under the 404 Program, no discharge of dredged EPA (33 U.S.C. § 1344) or fill material is allowed if a practicable alternative exists that is less damaging to the aquatic environment or if the Nations waters would be significantly degraded. A Federal permit is required to discharge dredged or fill material into wetlands and waters of the U.S.
Comprehensive Environmental Response, Section 101 of CERCLA requires a permit to cover EPA Compensation, and consumptive water use over 20,000 gallons per day (over a Liability Act (CERCLA) 30-day average) of surface and ground water.
(42 U.S.C. § 9601 et seq.)
C-3
Appendix C Agency Law/Regulation Requirements This act created the national wild and scenic rivers system, Wild and Scenic River established to protect the environmental values of free EPA Act (16 U.S.C. §1271 flowing streams from degradation by impacting activities et seq.)
including water resources projects.
Floodplain Executive Order (No. 11988.
May 24, 1977, 42 Federal Register Both Executive Orders require Federal agencies to consider (FR) 26951) and the impacts of their actions on floodplains and wetlands EPA Wetlands Executive through existing review procedures such as the National Order Environmental Policy Act of 1969 (NEPA).
(No. 11990.
May 24, 1977, 42 FR 26961)
Waste management & pollution prevention Before a material can be classified as a hazardous waste, it must first be a solid waste as defined under the RCRA.
Hazardous waste is classified under Subtitle C of the Resource Conservation RCRA. All applicable generators of hazardous waste and Recovery Act regulations are contained in 40 CFR Parts 261 and 262.
Parts 261.5(a) and 261.5(e) contain requirements for (42 U.S.C. § 6901 conditionally-exempt small-quantity generators (CESQGs).
et seq.)
Part 262.34(d) contains requirements for small-quantity generators (SQGs). Parts 262 and 261.5(e) contain requirements for large-quantity generators (LQGs).
This act formally established a National policy to prevent or Pollution Prevention Act reduce pollution at its source whenever feasible. It provides EPA (42 U.S.C. § 13101 funds for state and local pollution prevention programs et seq.) through a grant program to promote the use of pollution prevention techniques by business.
Emergency planning & response The intent of section 112(r) of the CAA is to prevent Risk Management accidental releases to the air and mitigate the Ohio EPA, Program consequences of releases that do occur by focusing on Division of Air prevention measures on chemicals that pose the greatest Pollution Control Ohio Administrative risk to the public and the environment. Under these Code Chapter 3745-104 requirements, industry has an obligation to prevent accidents and operate safely.
C-4
Appendix C Agency Law/Regulation Requirements The Emergency Planning and Community Right-to-Know Act (EPCRA) was passed by Congress in 1986. EPCRA was included as Title III of the Superfund Amendments and Reauthorization Act (SARA) and is sometimes referred to as Emergency Planning SARA Title III. EPCRA provides for the collection and Ohio EPA, and Preparedness availability of information regarding the use, storage, Division of Air Ohio Administrative production, and release of hazardous chemicals to the Pollution Control Code public and emergency responders in your communities.
Chapter 1301:7-7-04 The law promotes a working relationship among Government at all levels, business and community leaders, environmental and other public interest organizations, and individual citizens to improve hazard communications and emergency planning.
Toxic Release Inventory These rules establish reporting requirements and schedules Ohio EPA, Rules for each toxic chemical known to be manufactured Division of Air (including imported), processed, or otherwise used in Pollution Control Ohio Administrative excess of an applicable threshold quantity. It applies only to Code Chapter 3745-100 facilities of a certain classification.
Biotic resources protection Endangered Species U.S. Fish & This act forbids any Government agency, corporation, or Act (ESA)
Wildlife Services citizen from taking (harming or killing) endangered animals (16 U.S.C. § 1531 (FWS) without an Endangered Species Permit.
et seq.)
To minimize adverse impacts of proposed actions on fish and wildlife resources and habitat, this act requires that Fish and Wildlife Federal agencies consult Government agencies regarding Coordination Act FWS activities that affect, control, or modify waters of any stream (16 U.S.C. § 661 or bodies of water. It also requires that justifiable means et seq.)
and measures be used in modifying plans to protect fish and wildlife in these waters.
A person that proposes to engage in an activity that involves Ohio EPA, General and individual the filling of an isolated wetland shall apply to the director Division of Surface Isolated wetland permits for coverage under a general state-isolated wetland permit WaterIsolated or shall apply for an individual state-isolated wetland permit.
Wetland Ohio Administrative No person shall engage in the filling of an isolated wetland Permitting Code Chapter 6111.021 unless authorized to do so by a general or individual state-isolated wetland permit.
Cultural resources protection National Historic Advisory Council Preservation Act This act directs Federal agencies to consider the impact of on Historic (NHPA) their actions on historic properties. The NHPA also Preservation (16 U.S.C. § 470 encourages state and local preservation societies.
(ACHP) et seq.)
Ohio Historic Preservation Historical Society These are guidelines for archaeological investigations on Office Ohio Administrative public land, archaeological preserves, and sites listed in the Ohio Historical Code Chapter 149-1-02 state registry of archaeological landmarks.
Society C-5
Appendix C C.2 Operating Permits and Other Requirements Several operating permit applications may be prepared and submitted, and regulatory approval or permits or both would be received prior to license renewal approval by the NRC. Table C-2 lists representative Federal, state, and local permits.
C-6
Appendix C Table C-2. Federal, State, and Local Permits and Other Requirements Davis-Besse is subject to other requirements regarding various aspects of their environmental program. Those requirements are briefly described below.
License, Permit, or Responsible Other Required Authority Relevance & Status Agency Approval Operation of Davis-Besse AEA Permit Number: NPF-3 License to operate NRC (42 U.S.C. 2011, et seq.) 10 CFR 50.10 Issued: 04/22/1977 Expires: 04/22/2017 Use of Radioactive waste cask Certificate Number: 1004 Issued: 01/23/1995 Expires: 01/31/2015 Storage of spent nuclear fuel & high-level NRC 10 CFR Part 72 Certificate Number 1004 is in timely renewal in accordance with the requirements in radioactive waste 10 CFR 2.109. Because the Certificate holder filed an application to renew this certificate more than 30 days before the expiration date, the certificate will not be deemed to have expired until the application has been finally determined.
Air quality protection Operation of station auxiliary boiler CAA, 40 U.S.C. 1857 Ohio EPA, et seq.; Ohio Air Facility ID #: 0362000091 Permit to operate an air Division of Air Pollution Control Act Permit Number: P0110436 containment source Pollution Control (Ohio Administrative Issued: 02/28/2013 Code Chapter 3745-31)
Expires: 02/28/2023 Water resources protection CWA (33 U.S.C. 1251 Construction of Switchyard project et seq.); and control-discharge of storm water Ohio EPA, 40 CFR Part 122 in Ottawa County, Carroll Township NPDES Division of Ohio Permit No. 2GC02563*AG Surface Water Ohio Water Pollution Control Act (Ohio Issued: 12/21/2009 Revised Code 6111) Expires: Upon Project Completion Treatment of wastewater and CWA (33 U.S.C. 1251 effluent discharge to surface et seq.); receiving waters (Toussaint River Ohio EPA, 40 CFR Part 122 and Lake Erie)
NPDES Division of Ohio Permit Number: 21B00011*JD Surface Water Ohio Water Pollution Control Act (Ohio Issued: 07/01/2011 Revised Code 6111) Expires: 04/30/2016 (every 5 years)
C-7
Appendix C License, Permit, or Responsible Other Required Authority Relevance & Status Agency Approval Ohio Withdrawal and use of more than Department of 100,000 gallons of water daily from Water withdrawal and Natural all sources Ohio Revised Code use registration and file Resources, Registration # 00598 Section 1521.16 annual report Division of Water Issued: 01/01/1990 Resources Expires: Indefinite Waste management and pollution prevention Generation and accumulation of RCRA, as amended hazardous waste Notification of regulated EPA ID# OHD000720508 EPA (42 U.S.C. s/s 321 waste activity et seq. (1976) Issued: ---
Expires: Indefinite Ohio EPA, Generation. Accumulation and Division of Ohio Administrative offsite disposal of hazardous waste Report of regulated EPA ID# OHD000720508 Hazardous Code waste activity Waste Chapter 3745-52-41 Issued: Annual Reporting Management Expires: Indefinite Emergency planning and response Hazardous Materials Transportation Act Transportation of hazardous (HMTA) materials (49 U.S.C. 1501 U.S. et seq.); AEA, as Permit Number:
Hazardous material 052112 020 004UW Department of amended registration Transportation (42 U.S.C. 2011 Issued: 05/22/2012 et seq.); Expires: 06/30/2015 49 CFR Parts 107 (Renewed Triennially)
Subpart G, 172, 173, 174, 177, and 397 Shipment of radioactive material to a Tennessee licensed disposal-processing facility Department of within the State of Tennessee License to deliver Tennessee Code Tennessee Delivery License Environment radioactive waste Annotated 68-202-206 # T-OH003-15 and Conservation Issued: Annually Expires: 12/31/2015 Shipment of radioactive material to a South Carolina South Carolina licensed disposal-processing facility Department of Radioactive Waste within the State of South Carolina License to deliver Health and Transportation and Permit Number: 0054-34-15-X radioactive waste Environmental Disposal Act No. 429 of Control 1980 Issued: 12/5/2014 Expires: 12/31/2015 C-8
Appendix C License, Permit, or Responsible Other Required Authority Relevance & Status Agency Approval Registration of underground diesel Ohio storage tanks T00001, T00002, and Department of T00003 Underground storage Ohio Administrative Commerce, Facility # 62000072 tank registration Code 1301: 7-9-04 Division of State Fire Marshal Issued: Annually Expires: 06/30/2015 Human health Operation of X-ray generation Ohio Administrative Equipment Ohio X-ray generating Code 3701:1-38-03(C); Registration # 17-M-07181-005 Department of equipment registration Ohio Revised Code Health Issued: Biennially 3748.06 and 3748.07 Expires: 05/31/2016 Biotic resource protection Ohio Collection of wildlife specimens for Department of Radiological Environmental Scientific Collection Natural Ohio Revised Code Monitoring Program (REMP)
Permit Resources, Section 1531.08 Permit Number: 15-112 Division of Issued: 03/16/2014 Wildlife Expires: 03/15/2015 C-9
APPENDIX D CONSULTATION CORRESPONDENCE
D.CONSULTATION CORRESPONDENCE The Endangered Species Act of 1973, as amended; the Magnuson-Stevens Fisheries Management Act of 1996, as amended; and the National Historic Preservation Act of 1966 require that Federal agencies consult with applicable state and Federal agencies and groups prior to taking action that may affect threatened and endangered species, essential fish habitat, or historic and archaeological resources, respectively. This appendix contains consultation documentation.
D-1
Appendix D Table D-1. Consultation Correspondence Author Recipient Date of Letter NRC Advisory Council on Historic Preservation November 22, 2010 (David J. Wrona, Chief) (Mr. Reid Nelson, Director) (ML102980140)
NRC Ohio Department of Natural Resources November 22, 2010 (David J. Wrona, Chief) (David Graham, Chief) (ML102980688)
Ohio Department of Natural Resources NRC November 23, 2010 (Brian Mitch, Environmental Review (David J. Wrona, Chief) (ML102980430)
Manager)
NRC Delaware Nation November 23, 2010 (David J. Wrona, Chief) (Edgar L. French) (ML103000164)
NRC Forest County Potawatomi Community November 23, 2010 (David J. Wrona, Chief) (Harold G. Frank) (ML103000164)
NRC Hannahville Indian Community Council November 23, 2010 (David J. Wrona, Chief) (Kenneth Meshigaud) (ML103000164)
NRC Miami Tribe of Oklahoma November 23, 2010 (David J. Wrona, Chief) (Floyd E. Leonard) (ML103000164)
NRC Shawnee Tribe November 23, 2010 (David J. Wrona, Chief) (Ron Sparkman) (ML103000164)
NRC Wyandotte Nation November 23, 2010 (David J. Wrona, Chief) (Leaford Bearskin) (ML103000164)
NRC Peoria Tribe of Indians of Oklahoma November 23, 2010 (David J. Wrona, Chief) (John P. Froman) (ML103000164)
NRC Ottawa Tribe of Oklahoma November 23, 2010 (David J. Wrona, Chief) (Charles Todd) (ML103000164)
National Oceanic and Atmospheric NRC Administration (NOAA) National Marine December 6, 2010 (David J. Wrona, Chief) Fisheries Service (NMFS) (ML102980692)
(Patricia Kurkul, Regional Administrator)
NRC Ohio Historic Preservation Office December 7, 2010 (David J. Wrona, Chief) (Mark Epstein) (ML102980687)
Peoria Tribe of Indians of Oklahoma December 8, 2010 Chief, Rules and Directives Branch (John P. Froman) (ML103570365)
U.S. Fish and Wildlife Service (FWS) NRC December 16, 2010 (Mary M. Knapp, Field Supervisor) (Cindy Bladey, Chief) (ML110060289)
NOAA NMFS NRC December 21, 2010 (Mary A. Colligan, Assistant Regional (David J. Wrona, Chief) (ML110140230)
Administrator)
NRC FWS June 1, 2011 (David J. Wrona, Chief) (Mary Knapp, Field Supervisor) (ML11131A176)
NRC Delaware Nation February 26, 2014 (David J. Wrona, Chief) (C.J. Watkins)
NRC Forest County Potawatomi Community February 26, 2014 (David J. Wrona, Chief) (Harold G. Frank)
D-2
Appendix D Author Recipient Date of Letter NRC Hannahville Indian Community Council February 26, 2014 (David J. Wrona, Chief) (Kenneth Meshigaud)
NRC Miami Tribe of Oklahoma February 26, 2014 (David J. Wrona, Chief) (Douglas Lankford)
NRC Shawnee Tribe February 26, 2014 (David J. Wrona, Chief) (Ron Sparkman)
NRC Wyandotte Nation February 26, 2014 (David J. Wrona, Chief) (Billy Friend)
NRC Peoria Tribe of Indians of Oklahoma February 26, 2014 (David J. Wrona, Chief) (John P. Froman)
NRC Ottawa Tribe of Oklahoma February 26, 2014 (David J. Wrona, Chief) (Ethel Cook)
NRC FWS February 27, 2014 (David J. Wrona, Chief) (Tom Melius, Midwest Regional Director) (ML13177A030)
NRC FWS April 29, 2014 (Briana Grange, Biologist) (Mary Knapp, Field Supervisor) (ML14167A080)
FWS NRC May 2, 2014 (Jennifer Finfera, Wildlife Biologist) (Briana A. Grange, Biologist) (ML14167A081)
NRC FWS May 2, 2014 (Briana A. Grange, Biologist) (Jennifer Finfera, Wildlife Biologist) (ML14167A082)
FWS NRC May 4, 2014 (Jennifer Finfera, Wildlife Biologist) (Briana A. Grange, Biologist) (ML14167A084)
FWS NRC May 5, 2014 (Jennifer Finfera, Wildlife Biologist) (Briana A. Grange, Biologist) (ML14167A085)
NRC FWS May 5, 2014 (Briana A. Grange, Biologist) (Jennifer Finfera, Wildlife Biologist) (ML14167A086)
FWS NRC May 5, 2014 (Jennifer Finfera, Wildlife Biologist) (Briana A. Grange, Biologist) (ML14167A087)
NRC FWS May 6, 2014 (Briana A. Grange, Biologist) (Jennifer Finfera, Wildlife Biologist) (ML14139A000)
FWS NRC May 6, 2014 (Jennifer Finfera, Wildlife Biologist) (Briana A. Grange, Biologist) (ML14167A088)
FWS NRC May 27, 2014 (Jennifer Finfera, Wildlife Biologist) (Briana A. Grange, Biologist) (ML14167A089)
NRC FWS June 12, 2014 (Briana A. Grange, Biologist) (Jennifer Finfera, Wildlife Biologist) (ML14167A091)
FWS NRC June 16, 2014 (Jennifer Finfera, Wildlife Biologist) (Briana A. Grange, Biologist) (ML14168A614)
NRC FWS June 17, 2014 (Briana A. Grange, Biologist) (Jennifer Finfera, Wildlife Biologist) (ML14168A616)
D-3
Appendix D Author Recipient Date of Letter FWS NRC (Tom Melius, Midwest Regional Director, September 15, 2014 (David J. Wrona, Chief) Mary Knapp, Field Supervisor, and (ML14246A119)
Jennifer Finfera, Wildlife Biologist)
FWS NRC September 30, 2014 (Forest Clark, Acting Field Supervisor) (David J. Wrona, Chief) (ML14296A559)
D-4
APPENDIX E CHRONOLOGY OF ENVIRONMENTAL REVIEW CORRESPONDENCE
E.CHRONOLOGY OF ENVIRONMENTAL REVIEW CORRESPONDENCE This appendix contains a chronological listing of correspondence between the U.S. Nuclear Regulatory Commission (NRC) and external parties as part of its environmental review for Davis-Besse Nuclear Power Station, Unit 1. All documents, with the exception of those containing proprietary information are available electronically from the NRCs Public Electronic Reading Room found on the Internet at the following Web address:
http://www.nrc.gov/reading-rm.html. From this site, the public can gain access to the NRCs Agencywide Documents Access and Management Systems (ADAMS), which provides text and image files of NRCs public documents. The ADAMS accession number for each document is included below.
E-1
Appendix E August 27, 2010 Letter from Barry S. Allen, Davis-Besse Nuclear Power Station, Unit 1, Docket No. 50-346, License Number NPF-3, License Renewal Application and Ohio Coastal Management Program Consistency Certification (ADAMS Accession No. ML102450565)
September 14, 2010 Letter to Deborah Rossman, Director, Ida Rupp Public Library Maintenance of Reference Materials at the Ida Rupp Public Library in Regards to the Review of the Davis-Besse Nuclear Power Station, Unit 1, License Renewal Application (ADAMS Accession No. ML102450342)
September 14, 2010 Letter to Mr. Clyde Scoles, Director, Toledo-Lucas County Public Library, Maintenance of Reference Materials at the Toledo-Lucas County Public Library in Regards to the Review of the Davis-Besse Nuclear Power Station, Unit 1, License Renewal Application (ADAMS Accession No. ML1024507070)
September 17, 2010 Letter to Barry S. Allen, Receipt and Availability of the License Renewal Application for the Davis-Besse Nuclear Power Station, Unit 1 (ADAMS Accession No. ML102300325)
September 20, 2010 Press Release: NRC Announces Availability of License Renewal Application for Davis-Besse Nuclear Plant (ADAMS Accession No. ML102630380)
September 24, 2010 E-mail from Megan Seymore, Wildlife Biologist, U.S. Fish and Wildlife Service, to Richard Bulavinetz, NRC, titled Davis-Besse Transmission line corridor (ADAMS Accession No. 103630080)
October 12, 2010 Memorandum to David Wrona, NRC, from Andy Imboden, NRC, Acceptance of License Renewal Application, Davis-Besse Nuclear Power Station, Unit 1 (ADAMS Accession No. ML102850303)
October 18, 2010 Letter to Barry S. Allen, Determination of Acceptability and Sufficiency for Docketing, and Opportunity for a Hearing Regarding the Application from FirstEnergy Nuclear Operating Company, for renewal of the Operating License for the Davis-Besse Nuclear Power Station, Unit 1 (ADAMS Accession No. ML102710584)
October 20, 2010 Letter to Barry S. Allen, Notice of Intent to Prepare an Environmental Impact Statement and Conduct Scoping Process for License Renewal for the Davis-Besse Nuclear Power Station, Unit 1 (ADAMS Accession No. ML102700603)
October 22, 2010 Memorandum to David J. Wrona, NRC, from Paula Cooper, NRC, and Brian Harris, NRC, Forthcoming Meeting to Discuss the License Renewal Process and Environmental Scoping for Davis-Besse Nuclear Power Station License Renewal Application Review (ADAMS Accession No. ML102870261)
October 26, 2010 Press Release: NRC Announces Opportunity for Hearing on Application to Renew Operating License For Davis-Besse Nuclear Power Plant (ADAMS Accession No. ML102990387)
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Appendix E October 28, 2010 Press Release: NRC to Conduct Environmental Scoping Meeting as Part of the License Renewal Application for Davis-Besse:
Meeting November 4 (ADAMS Accession No. ML103010069)
November 4, 2010 Transcript Davis-Besse License Renewal Public Meeting Afternoon Session, pages 1-46 (ADAMS Accession No. 110140231)
November 4, 2010 Transcript Davis-Besse License Renewal Public MeetingEvening Session, pages 1-37 (ADAMS Accession No. 110140232)
November 22, 2010 Letter from NRC to Reid Nelson, Director, Advisory Council on Historic Preservation (ACHP) Davis-Besse Nuclear Power Station, Unit 1, License Renewal Application Review (ADAMS Accession No. ML102980140)
November 22, 2010 Letter to David Graham, Chief, Division of Wildlife, Ohio Department of Natural Resources (OHDNR), Request for List of Protected Species Within the Area Under Evaluation for the Davis-Besse Nuclear Power Station License Renewal Application Review (ADAMS Accession No. ML102980688)
November 23, 2010 Letter to Brian Mitch, Environmental Review Manager, OHDNR, Request for List of Protected Species Within the Area Under Evaluation for the Davis-Besse Nuclear Power Station License Renewal Application Review (ADAMS Accession No. ML102980430)
November 23, 2010 Letter to Edgar L, French, Delaware Nation, Request for Scoping Comments Concerning the Davis-Besse Nuclear Power Plant, Unit 1, License Renewal Application Review (ADAMS Accession No. ML103000164)
November 23, 2010 Letter to Harold G. Frank, Forest County Potawatomi Community, Request for Scoping Comments Concerning the Davis-Besse Nuclear Power Plant, Unit 1, License Renewal Application Review (ADAMS Accession No. ML103000164)
November 23, 2010 Letter to Kenneth Meshigaud, Hannahville Indian Community Council, Request for Scoping Comments Concerning the Davis-Besse Nuclear Power Plant, Unit 1, License Renewal Application Review (ADAMS Accession No. ML103000164)
November 23, 2010 Letter to Floyd E. Leonard, Miami Tribe of Oklahoma, Request for Scoping Comments Concerning the Davis-Besse Nuclear Power Plant, Unit 1, License Renewal Application Review (ADAMS Accession No. ML103000164)
November 23, 2010 Letter to Ron Sparkman, Shawnee Tribe, Request for Scoping Comments Concerning the Davis-Besse Nuclear Power Plant, Unit 1, License Renewal Application Review (ADAMS Accession No. ML103000164)
E-3
Appendix E November 23, 2010 Letter to Leaford Bearskin, Wyandotte Nation, Request for Scoping Comments Concerning the Davis-Besse Nuclear Power Plant, Unit 1, License Renewal Application Review (ADAMS Accession No. ML103000164)
November 23, 2010 Letter to John P. Froman, Peoria Tribe of Indians of Oklahoma, Request for Scoping Comments Concerning the Davis-Besse Nuclear Power Plant, Unit 1, License Renewal Application Review (ADAMS Accession No. ML103000164)
November 23, 2010 Letter to Charles Todd, Ottawa Tribe of Oklahoma, Request for Scoping Comments Concerning the Davis-Besse Nuclear Power Plant, Unit 1, License Renewal Application Review (ADAMS Accession No. ML103000164)
December 6, 2010 Letter from NRC to Patricia Kurkul, National Oceanic and Atmospheric Administration Fisheries Service (NOAA), Request for List of Protected Species Within the Area Under Evaluation for the Davis-Besse Nuclear Power Station License Renewal Application Review (ADAMS Accession No. ML102980692)
December 7, 2010 Letter from NRC to Mark Epstein, Ohio State Historic Preservation Officer, Davis-Besse Nuclear Power Station, Unit 1, License Renewal Application Review (ADAMS Accession No. ML102980687)
December 11, 2010 Video Recording of Public Comments on the NRC Relicensing of the Davis-Besse Nuclear Plant in Columbus, Ohio (ADAMS Accession No. ML11348A013)
December 16, 2010 Letter from Mary Knapp, United States Department of the Interior, Fish and Wildlife Services, Docket ID NRD-2010-0298 (ADAMS Accession No. ML110060289)
December 18, 2010 Transcript and Video Recording of the Peoples Hearing on Davis-Besse Relicensing (ADAMS Accession No. ML11209C080)
December 21, 2010 Letter from Mary A. Colligan, NOAA, Re: Davis-Besse Nuclear Power Station (ADAMS Accession No. ML110140230)
December 28, 2010 Letter to Barry S. Allen, Schedule for the Conduct of Review of the Davis-Besse Nuclear Power Station, Unit 1, License Renewal Application (ADAMS Accession No. ML103430580)
February 2, 2011 E-mail to Laura Bonneau, FWS, Educational Program (ADAMS Accession No. ML11236A085)
February 9, 2011 E-mail from Laura Bonneau, FWS, Educational Program (ADAMS Accession No. ML11235A564)
February 10, 2011 E-mail to Laura Bonneau, FWS, Educational Program (ADAMS Accession No. ML11236A083)
February 10, 2011 E-mail from Laura Bonneau, FWS, Educational Program (ADAMS Accession No. ML11235A558)
E-4
Appendix E February 15, 2011 E-mail to Mary Knapp, FWS, for invitation to the license renewal environmental audit (ADAMS Accession No. ML11236A075)
February 15, 2011 E-mail from Mary Knapp, FWS, in response to audit invitation (ADAMS Accession No. ML11235A748)
February 15, 2011 E-mail to Brain Mitch, OHDNR, for invitation to the License renewal environmental audit (ADAMS Accession No. ML11236A077)
February 15, 2011 E-mail to Dave Snyder, OHPO, for invitation to the license renewal environmental audit (ADAMS Accession No. ML11236A079)
February 23, 2011 Letter to Barry S. Allen, Requests for Additional Information (RAIs) for the Review of the Davis-Besse Nuclear Power Station, Unit 1, License Renewal Application (ADAMS Accession No. ML110130494)
February 28, 2011 Letter to Barry S. Allen, Environmental Site Audit Regarding Davis-Besse Nuclear Power Station, Unit 1, License Renewal Application (ADAMS Accession No. ML110190113)
March 4, 2011 E-mail to Mary Knapp, FWS, to provide environmental audit schedule (ADAMS Accession No. ML11236A069)
March 4, 2011 E-mail to Mark Epstein, OHPO, for invitation to the license renewal environmental audit (ADAMS Accession No. ML11236A071)
March 4, 2011 E-mail from Dave Snyder, OHPO, in response to audit invitation (ADAMS Accession No. ML11236A071)
March 4, 2011 E-mail to Dave Snyder, OHPO, for scheduling of Audit telephone conference (ADAMS Accession No. ML11236A073)
March 8, 2011 E-mail from Laura Bonneau, FWS, for confirmation of audit activities (ADAMS Accession No. ML11235A556 )
March 8, 2011 E-mail to Dave Snyder, OHPO, to provide audit-related conference call information (ADAMS Accession No. ML11236A067)
March 9, 2011 E-mail to Laura Bonneau, FWS, to provide audit-related conference call information and scheduling (ADAMS Accession No. ML11236A065 )
March 14, 2011 E-mail to Megan Seymour, FWS, to provide update on transmission line mapping (ADAMS Accession No. ML1107303280)
March 23, 2011 Letter from Barry S. Allen, Davis-Besse Nuclear Power Station, Unit 1, Docket No. 50-346, License Number NPF-3, Reply to RAI for the Review of the Davis-Besse Nuclear Power Station, Unit 1, License Renewal Application (TAC No. ME4640) (ADAMS Accession No. ML110880058)
May 27, 2011 RAI responses from applicant, Davis-Besse Nuclear Power Station, Unit 1, Docket No. 50-346, License Number NPF-3, Reply to RAIs for the Review of the Davis-Besse Nuclear Power Station, Unit 1, License Renewal Application (TAC No. ME4613)
Environmental Report (ADAMS Accession No. ML11193A093)
E-5
Appendix E April 20, 2011 Letter to Barry S. Allen, RAI for the Review of the Davis-Besse Nuclear Power Station, Unit 1, License Renewal Application (ADAMS Accession No. ML110910566)
April 26, 2011 Letter to Barry S. Allen, RAI for the Review of the Davis-Besse Nuclear Power Station, Unit 1, License Renewal Application (ADAMS Accession No. ML11094A099)
June 1, 2011 Letter to Mary Knapp, FWS, Request for Lost of Federally Protected Species and Important Habitats within the Area Under Evaluation for the Davis-Besse Nuclear Power Station License Renewal Application Review (ADAMS Accession No. ML11131A176)
June 3, 2011 Summary of site audit to support review of LRA of Davis-Besse Nuclear Power Station, Unit 1 (ADAMS Accession No. ML110820276)
June 24, 2011 Letter from Kendall W. Byrd, Davis-Besse Nuclear Power Station, Unit 1, Docket No. 50-346, License Number NPF-3, Reply to RAI for the Review of the Davis-Besse Nuclear Power Station, Unit 1, License Renewal Application (TAC No. ME4613) Environmental Report Severe Accident Mitigation Alternatives Analysis and License Renewal Application Amendment No.1 (ADAMS Accession No. ML11180A233)
July 11, 2011 Letter from Kendall W. Byrd, Davis-Besse Nuclear Power Station, Unit 1, Docket No. 50-346, License Number NPF-3, Ohio Department of Natural Resources, Office of Coastal Management Concurrence with Federal Consistency Certification Related to the Review of the Davis-Besse Nuclear Power Station, Unit 1, License Renewal Application Environmental Report (TAC No. ME4613)
(ADAMS Accession No. ML11195A146)
August 1, 2011 Summary of scoping meeting held in support of the environmental review for the Davis-Besse Nuclear Power Station, Unit 1, LRA (ADAMS Accession No. ML11173A200)
August 15, 2011 Memorandum from John Parillo, NRC, to Travis L. Tate, Branch Chief, NRC, RAI Response Clarifications from Davis-Besse Nuclear Power Station in Support of License Renewal Application (TAC No. ME4613) (ADAMS Accession No. ML112270139)
August 31, 2011 Memorandum from Travis L. Tate, Branch Chief, NRC, to David J.
Wrona, Branch Chief, NRC, Evaluation of Severe Accident Mitigation Alternatives for Davis-Besse Nuclear Power Station (TAC No. ME4613) (ADAMS Accession No. ML112300844)
September 1, 2011 Letter from Barry S. Allen, Davis-Besse Nuclear Power Station, Unit 1, Docket No. 50-346, License Number NPF-3, Reply to Supplemental RAI for the Review of the Davis-Besse Nuclear Power Station, Unit 1, License Renewal Application (TAC No. ME4613) Environmental Report Severe Accident Mitigation Alternatives Analysis (ADAMS Accession No. ML11250A068)
E-6
Appendix E September 19, 2011 Letter from Kendall W. Byrd, Davis-Besse Nuclear Power Station, Unit 1, Docket No. 50-346, License Number NPF-3, License Renewal Application Amendment No. 16, Supplemental Information for the Review of the Davis-Besse Nuclear Power Station, Unit 1, License Renewal Application Environmental Report (TAC No. ME4613) (ADAMS Accession No. ML11266A062)
September 19, 2011 Letter from Kendall W. Byrd, Davis-Besse Nuclear Power Station, Unit 1, Docket No. 50-346, License Number NPF-3, License Renewal Application Amendment No. 17, Supplemental Information for the Review of the Davis-Besse Nuclear Power Station, Unit 1, License Renewal Application Environmental Report (TAC No. ME4613) (ADAMS Accession No. ML11266A009)
October 31, 2011 Letter to Barry S. Allen, Schedule Revision for the Environmental and Safety Review of the Davis-Besse Nuclear Power Station, Unit 1, License Renewal Application (ADAMS Accession No. ML11256A164)
July 16, 2012 Letter from John C. Dominy, Davis-Besse Nuclear Power Station, Unit 1, Docket No. 50-346, License Number NPF-3, Correction of Errors in the Davis-Besse Nuclear Power Station, Unit No. 1 License Renewal Application (TAC No. ME4613) Environmental Report Severe Accident Mitigation Alternatives Analysis, and License Renewal Application Amendment No. 29 (ADAMS Accession No. ML12200A024)
July 31, 2013 Letter to Barry S. Allen, Schedule Revision for the Environmental and Safety Review of the Davis-Besse Nuclear Power Station, Unit 1, License Renewal Application (ADAMS Accession No. ML13205A036)
October 9, 2013 Letter to Raymond A. Lieb, Schedule Revision for the Safety Review of the Davis-Besse Nuclear Power Station, Unit 1, License Renewal Application (ADAMS Accession No. ML13281A845)
November 6, 2013 Letter to Raymond A. Lieb, Schedule Revision for the Environmental Review of the Davis-Besse Nuclear Power Station, Unit 1, License Renewal Application (ADAMS Accession No. ML13302C207)
January 30, 2014 Letter to Raymond A. Lieb, Schedule Revision for the Environmental Review of the Davis-Besse Nuclear Power Station, Unit 1, License Renewal Application (ADAMS Accession No. ML14027A217)
February 24, 2014 Letter to Raymond A. Lieb, Notice of Availability of the Draft Plant-Specific Supplement 52 to the Generic Environmental Impact Statement for License Renewal of Nuclear Plants Regarding Davis-Besse Nuclear Power Station, Unit 1 (ADAMS Accession No. ML14050A078)
E-7
Appendix E March 6, 2014 Letter to Kenneth Westlake, Notice of Availabiltiy of the Draft Plant-Specific Supplement 52 to the Generic Environmental Impact Statement for License Renewal of Nuclear Plants Regarding Davis-Besse Nuclear Power Station, Unit 1 (ADAMS Accession No. ML14057A422)
March 13, 2014 Press Release-14-09: NRC Seeks Public Comment on Draft Environmental Report for Davis-Besse Nuclear Plant License Renewal - Meetings Scheduled for March 25 (ADAMS Accession No. ML14073A645)
September 30, 2014 Letter to Raymond A. Lieb, Schedule Revision for the Review of the Davis-Besse Nuclear Power Station, Unit 1, License Renewal Application (ADAMS Accession No. ML14267A303)
November 28, 2014 Letter to Raymond A. Lieb, Schedule Revision for the Review of the Davis-Besse Nuclear Power Station, Unit 1, License Renewal Application (ADAMS Accession No. ML14329A479)
January 2015 Letter to Raymond A. Lieb, Schedule Revision for the Review of the Davis-Besse Nuclear Power Station, Unit 1, License Renewal Application (ADAMS Accession No. ML15022A253)
February 27, 2015 Letter to Raymond A. Lieb, Schedule Revision and Project Manager Change for the Review of the Davis-Besse Nuclear Power Station, Unit 1, License Renewal Application (ADAMS Accession No. ML15054A534)
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APPENDIX F U.S. NUCLEAR REGULATORY COMMISSION STAFF EVALUATION OF SEVERE ACCIDENT MITIGATION ALTERNATIVES FOR DAVIS-BESSE NUCLEAR POWER STATION IN SUPPORT OF LICENSE RENEWAL APPLICATION REVIEW
F.U.S. NUCLEAR REGULATORY COMMISSION STAFF EVALUATION OF SEVERE ACCIDENT MITIGATION ALTERNATIVES FOR DAVIS-BESSE NUCLEAR POWER STATION IN SUPPORT OF LICENSE RENEWAL APPLICATION REVIEW F.1 Introduction FirstEnergy Nuclear Operating Company (FENOC), on behalf of FirstEnergy Nuclear Generation Corporation, submitted to the U.S. Nuclear Regulatory Commission (NRC) an assessment of severe accident mitigation alternatives (SAMAs) for the Davis-Besse Nuclear Power Station, Unit 1 (Davis-Besse) as part of the Environmental Report (ER) (FENOC 2010).
This assessment was based on the most recent Davis-Besse probabilistic risk assessment (PRA) available at that time, a plant-specific offsite consequence analysis performed using the MELCOR Accident Consequence Code System 2 (MACCS2) computer code (NRC 1998a), and insights from the Davis-Besse individual plant examination (IPE) (Centerior Energy 1993) and individual plant examination of external events (IPEEE) (Centerior Energy 1996). In identifying and evaluating potential SAMAs, FENOC considered SAMA candidates that addressed the major contributors to core damage frequency (CDF) and large early release frequency (LERF) at Davis-Besse, as well as SAMA candidates for other operating plants that have submitted license renewal applications (LRAs). FENOC identified 168 potential SAMA candidates. The SAMA candidates were reduced to 15 by eliminating SAMAs that are not applicable for one or more of the following reasons:
The SAMA has design differences or has already been implemented at Davis-Besse.
The SAMA is not applicable to Davis-Besse.
The SAMA has estimated implementation costs that would exceed the dollar value associated with eliminating all severe accident risk at Davis-Besse.
The SAMA is related to a non-risk significant system and, therefore, has a very low benefit.
The SAMA is similar in nature and could be combined with another SAMA candidate.
FENOC assessed the costs and benefits associated with each of these 15 potential SAMAs and concluded in the ER that one of the candidate SAMAs evaluated is potentially cost-beneficial.
Based on a review of the SAMA assessment, the NRC issued a request for additional information (RAI) to FENOC by letter dated April 20, 2011 (NRC 2011a). Key questions concerned the following:
additional details regarding the plant-specific PRA model and changes to CDF and LERF since the IPE, additional information on the internal and external reviews of the PRA model performed since the IPE, the process used to map Level 1 PRA results into the Level 2 analysis and group containment event tree (CET) end states into release categories, justification for the multiplier used for external events, F-1
Appendix F population assumptions used in the Level 3 analysis, the use of importance analysis in identifying plant-specific SAMA candidates, and further information on the cost-benefit analysis of several specific candidate SAMAs and low-cost alternatives.
FENOC submitted additional information to the NRC by letter dated June 24, 2011 (FENOC 2011). FENOC also provided clarifications to the RAI responses via e-mail on July 18 and July 27, 2011 (NRC 2011b). In response to the RAIs, FENOC provided the following information:
identification of key factors for a significant change in CDF associated with particular version of the Davis-Besse PRA model, clarification of the scope of the peer reviews and the status of peer review findings, description of the process for mapping Level 1 results into the Level 2 analysis and for assigning CET sequences to release categories, a revised SAMA analysis reflecting a higher maximum benefit, higher external events multiplier, and the 95th percentile CDF, clarification of the sensitivity analysis, an assessment of SAMAs previously found to be potentially cost beneficial for Babcock and Wilcox (B&W) plants, additional rationale for not identifying SAMAs for many of the basic events on the risk importance lists, additional rationale for considering SAMAs related to improved procedures or training or automated functions that would eliminate high risk operator error, an assessment of SAMAs subsumed by other more costly SAMAs, and additional information regarding several specific SAMAs.
Subsequent to the RAI responses, FENOC submitted a supplement to the ER that corrected the following five errors in the SAMA assessment (FENOC 2012a):
(1) An inaccurate land area conversion factor for acres to hectares was used.
(2) Dollar values for Ohio farmland and non-farmland were selected from Ohio Department of Taxation tax assessment values instead of appraised values.
(3) The escalation of decontamination costs was not performed in accordance with approved guidance.
(4) Core inventory isotopic activity was used instead of isotopic mass in the Modular Accident Analysis Program (MAAP) software code runs in contrast to updated industry guidance.
(5) The wind direction from the Davis-Besse Meteorological Tower was not converted from the blowing from direction to the blowing toward direction for use in the SAMA Analysis calculations.
F-2
Appendix F Based on a review of this updated SAMA assessment, the NRC held a conference call with FENOC on September 25, 2012, to clarify the decontamination cost escalation factor used in the assessment and the updated release category results (FENOC 2012b).
FENOCs response to the RAIs, as well as FENOCs response to the ER supplement clarification questions, addressed all the concerns raised by the NRC staff.
An assessment of SAMAs for Davis-Besse is presented below.
F.2 Estimate of Risk for Davis-Besse FENOCs estimates of offsite risk at Davis-Besse are summarized in Section F.2.1. The summary is followed by the NRC staffs review of FENOCs risk estimates in Section F.2.2.
F.2.1 FENOCs Risk Estimates Two distinct analyses are combined to form the basis for the risk estimates used in the SAMA analysis; the Davis-Besse Level 1 and 2 PRA model, which is an updated version of the IPE (Centerior Energy 1993), and a supplemental analysis of offsite consequences and economic impacts (essentially a Level 3 PRA model) developed specifically for the SAMA analysis. The SAMA analysis is based on the most recent Davis-Besse Level 1 and Level 2 PRA model available at the time of the ER, which is referred to as SAMA Analysis Model, and is a special update of the Davis-Besse Revision 4 PRA to support the SAMA evaluation. The scope of this Davis-Besse PRA does not include external events.
The Davis-Besse CDF is approximately 9.8x10-6 per year for internal events using a truncation value of 5x10-13 per year. This CDF includes contributions from internal flooding and high winds (not including tornado-generated missiles). When determined from the sum of the CET sequences, or Level 2 model, the release frequency (from all release categories including intact containment, early and late releases) is approximately 1.0x10-5 per year using a truncation value of 5x10-13 per year. The latter value was used as the baseline CDF in the SAMA evaluations. The CDF is based on the risk assessment for internally initiated events, which includes internal flooding. FENOC did not explicitly include the contribution from external events in the Davis-Besse PRA risk estimates; however, it did account for the potential risk reduction benefits associated with external events by multiplying the estimated benefits for internal events by a factor of 3.0. As a result of NRC review, FENOC revised the external events multiplier to a factor of 4.6. This is discussed further in Sections F.2.2 and F.6.2.
The breakdown of CDF by initiating event is provided in Table F-1. As shown in this table, loss of offsite power (LOOP), loss of component cooling water (CCW), and reactor or turbine trips are the dominant contributors to the CDF. Anticipated transient without scram (ATWS) sequences are modeled as a failure to trip after an initiating event; ATWS sequences contribute approximately 1 percent to CDF. Station blackout (SBO) sequences involve a LOOP (as the initiating event or following an initiating event), along with subsequent failure of power to both safety buses, (i.e., a loss of both emergency diesel generators (EDGs) and the SBO diesel generator); SBO sequences contribute approximately 5 percent to CDF and are dominated by sequences initiated by a LOOP.
F-3
Appendix F Table F-1. Davis-Besse Core Damage Frequency for Internal Events (a) (d) (d)
Initiating Event CDF (per year) % Contribution to CDF
-6 LOOP 1.9x10 19
-6 Loss of CCW pump(s) 1.7x10 18
-6 Reactor or turbine trip 1.3x10 13
-7 Steam generator tube rupture (SGTR) 6.2x10 6
-7 Loss of main feedwater 5.7x10 6 (b) -7 Main feedwater flow control 5.1x10 5
-7 Reactor vessel (RV) rupture 5.0x10 5
-7 Small loss-of-coolant accident (LOCA) 4.3x10 4
-7 Flooding in CCW pump room 2.0x10 2
-7 Medium LOCA 1.5x10 2
-7 Loss of service water pump room ventilation 1.3x10 1
-7 Loss of direct current (DC) power from Bus d2p 1.1x10 1
-8 Flooding in turbine building 8.8x10 1 Loss of non-nuclear instrumentation cabinets 1-4 (NNIX) -8 8.2x10 1 DC power supply (c) -6 Other 1.5x10 15
-6 Total CDF (internal events) 9.8x10 100 (a) -13 This table is based on model quantification using 5x10 per year truncation.
(b)
In response to an NRC staff RAI, FENOC explains that T2A-1 and T2B-1 are main feedwater flow control valve initiators, and T2A-2 and T2B-2 are the associated flow controller initiators. These four initiators combined form the main feedwater flow control initiator (FENOC 2011).
(c)
This is calculated from information in ER Table E.3-1.
(d)
Column totals may be different due to round off.
The Level 2 PRA model that forms the basis for the SAMA evaluation represents a complete revision of the original IPE Level 2 model. The current Level 2 model uses a single CET containing both phenomenological and systemic events. The Level 1 core damage sequences are grouped into core damage bins according to similarities in their impact on containment response. The core damage bins, together with the states of containment systems comprise the plant damage states (PDSs), which provide the interface between the Level 1 analysis and Level 2 CET analysis. The CET probabilistically evaluates the progression of the damaged core with respect to release to the environment. CET nodes are evaluated using supporting fault trees and logic rules. The CET end states are then examined for considerations of timing and magnitude of release and assigned to release categories.
The result of the Level 2 PRA is a set of 34 specific release categories, also referred to as source term categories, with their respective frequency and release characteristics. The results of this analysis for Davis-Besse are provided in Table E.3-13 of Appendix E to the ER (FENOC 2010). The frequency of each release category was obtained by summing the frequency of the individual accident progression CET endpoints assigned to each release category. Source terms were developed for each of the 34 release categories using the results F-4
Appendix F of Modular Accident Analysis Program (MAAP) Version 4.0.6 computer code calculations based on characteristics that determine the timing and magnitude of the release, whether or not the containment remains intact, and isotopic composition of the release material (FENOC 2010).
The offsite consequences and economic impact analyses use the MACCS2 code to determine the offsite risk impacts on the surrounding environment and public. Inputs for these analyses include plant-specific and site-specific input values for core radionuclide inventory, source term and release characteristics, site meteorological data, projected population distribution within a 50-mi (80-km) radius for the year 2040, emergency response evacuation planning, and economic parameters. The core radionuclide inventory corresponds to the end-of-cycle values for Davis-Besse operating at 2,827 megawatt thermal (MWt), which bounds the currently approved power level. The magnitude of the onsite impacts (in terms of cleanup and decontamination costs and occupational dose) is based on information provided in NUREG/BR-0184, Regulatory Analysis Technical Evaluation Handbook (NRC 1997a).
In response to an NRC staff RAI, FENOC estimated the dose to the population within 50 mi (80 km) of the Davis-Besse site to be approximately 0.0212 person-sievert (Sv)
(2.12 person-rem) per year (FENOC 2012a). The breakdown of the total population dose by containment release mode is summarized in Table F-2. SGTR and interfacing system LOCA (ISLOCA), both containment bypass events, dominate the population dose risk at Davis-Besse.
Table F-2. Breakdown of Population Dose by Containment Release Mode (a,b) (c,d) (d)
Containment release mode Population Dose (person-rem per year) % Contribution SGT 1.35 64 ISLOCA 0.35 17 Large containment isolation failure 0.02 1 Small containment isolation failure 0.06 3 Large early release 0.03 1 Sidewall failure (early) 0.03 1 Late containment failure 0.06 3 Basemat failure 0.21 10 No containment failure 0.02 1 Total 2.12 100 (a) -13 This table is based on model quantification using 5x10 per year truncation.
(b)
Estimated population doses calculated from revised information provided in Table E.3-21 of response to NRC staff RAI 4.b (FENOC 2011).
(c)
One person-rem = 0.01 person-Sv.
(d)
Column totals may be different due to round off.
F.2.2 Review of FENOCs Risk Estimates FENOCs determination of offsite risk at Davis-Besse is based on the following major elements of analysis:
F-5
Appendix F the Level 1 and 2 risk models that form the bases for the 1993 IPE submittal (Centerior Energy 1993) and the external event analyses of the 1996 IPEEE submittal (Centerior Energy 1996);
the major modifications to the IPE model that have been incorporated in the Davis-Besse PRA, including a complete revision of the Level 2 risk model; and the MACCS2 analyses performed to translate fission product source terms and release frequencies from the Level 2 PRA model into offsite consequence measures.
Each of these analyses was reviewed to determine the acceptability of the Davis-Besse risk estimates for the SAMA analysis, as summarized below.
The NRC staffs review of the Davis-Besse IPE is described in a safety evaluation report (SER)
(NRC 1996). Based on the review of the original IPE submittal and responses to RAIs, the NRC staff concluded that the IPE submittal met the intent of generic letter (GL) 88-20, Individual Plant Examination for Severe Accident Vulnerabilities (NRC 1988); that is, the applicants IPE process is capable of identifying the most likely severe accidents and severe accident vulnerabilities. Although no vulnerabilities were identified in the IPE, 11 improvements to the plant or procedures were identified. These improvements have been either implemented at the site or included in the SAMA evaluation process (FENOC 2010). These improvements are discussed in Section F.3.2.
There have been five revisions to the IPE model between the 1993 IPE submittal and the model used for the SAMA analysis. A listing of the major changes in each revision of the PRA was provided by FENOC in Section E.3.1.1.2 of the ER (FENOC 2010) and in response to an NRC staff RAI (FENOC 2011). The revisions to the IPE are summarized in Table F-3. FENOC clarified that the large decrease in CDF between Revision 0 and Revision 1 is primarily due to reduction in transient frequencies for reactor or turbine trips and loss of main feedwater.
Additionally, the sizeable decrease between Revision 3 and Revision 4 was primarily due to update of data and an increase in the time operators have to trip the reactor cooling pumps following loss of seal cooling. A comparison of the internal events CDF between the 1993 IPE and the SAMA analysis model indicates a decrease of approximately 85 percent (from 6.6x10-5 per year to 9.8x10-6 per year).
F-6
Appendix F Table F-3. Davis-Besse Probabilistic Risk Assessment Historical Summary PRA Version Summary of Changes From Prior Model CDF (per year)
-5 1993 IPE Submittal 6.6x10
- Performed plant-specific update of failure rates, unavailability, common cause, initiating event frequency, and human reliability analysis (HRA)
Revision 0
- Made modifications to reflect plant and procedure changes including adding 1.4x10
-5 Revision 1 the SBO diesel generator (DG), removal of a startup feed pump, -5 1.6x10 Revision 2 improvements to CCW and service water system modeling, update of SGTR -5 emergency response modeling, and internal flooding modeling 1.7x10 1999
- Improved model documentation to comply with draft PRA standard requirements
- Added explicit LERF model
- Addressed all Level B peer review findings
- Improved model quantification logistics including reducing truncation limit to
-10 2.0x10
- Deleted ISLOCA sequence judged not credible and RV rupture as negligible Revision 3
- Added conditional probability that reactor will trip due to loss of 4160 Volt -5 1.3x10 5/2001 Bus C or D
- Revised logic for loss of start-up feedwater due to circulating water flooding
- Revised success criteria for large and medium LOCAs to one of two core flood tanks
- Improved model documentation to comply with draft PRA standard requirements
- Updated model for new PRA software
- Increased available response time following loss of CCW for manual tripping Revision 4 of Reactor Coolant Pumps (RCPs) from 10 minutes to 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> -6 4.7x10 9/2007
- Added tornado initiating events, excluding consideration of missile generation
- Performed module management changes
-13
- Reduced truncation limit to 5.0x10 F-7
Appendix F PRA Version Summary of Changes From Prior Model CDF (per year)
- Reviewed and updated all system fault trees for system dependencies
- Added RV rupture initiating event
- Changed success criteria in case of a large LOCA back to two core flood tanks
- Made model improvements to CCW and service water models to correct errors
- Adjusted system fault trees to and reflect simultaneous alignments using split fraction
- Revised common cause failure modeling to use of multiple greek letter SAMA analysis approach model 9.8x10
-6
- Removed modules from fault trees
- Added fire modeling functionality in preparation for performing a National Fire Protection Association (NFPA) 805 analysis
- Improved modeling with respect to success gates and mutually exclusive terms
- Adapted a two-step quantification approach to facilitate incorporation of recovery events The CDF value from the 1993 Davis-Besse IPE (6.6x10-5 per year) is near the higher end of the range of the CDF values reported in the IPEs for B&W plants. Figure 11.6 of NUREG-1560 shows that the IPE-based internal events CDF for these plants range from about 1x10-5 per year to 7x10-5 per year, with an average CDF for the group of 3x10-5 per year (NRC 1997b). It is recognized that other plants have updated the values for CDF subsequent to the IPE submittals to reflect modeling and hardware changes. The internal events CDF result for Davis-Besse used for the SAMA analysis (9.8x10-6 per year, including internal flooding) is comparable to that for other plants of similar vintage and characteristics.
The NRC staff considered the peer reviews performed for the Davis-Besse PRA and the potential impact of the review findings on the SAMA evaluation. In the ER (FENOC 2010) and in response to an NRC staff RAI (FENOC 2011), FENOC describes a B&W owners group peer review performed from 1999 through 2000 on internal events and LERF and a gap self assessment performed by a team of industry peers and internal staff using the 2005 American Society of Mechanical Engineers (ASME) PRA standard (ASME 2005). The owners group peer review identified no Level A (important and necessary to address before the next regular PRA update) and 18 Level B (important and necessary to address, but disposition may be deferred until the next PRA update) facts and observations (F&Os). FENOC clarifies that 13 of these open findings were closed prior to implementation of the mitigating systems performance index (MSPI) document, four were closed in the SAMA analysis model, and the remaining F&O is essentially addressed by the SAMA evaluation. This last finding recommended additional sensitivity studies be performed to study the sensitivity of results to modeling PRA assumptions.
The SAMA evaluation includes an importance analysis of basic and initiating events as well as a Level 3 parameter sensitivity analysis, and, in response to an NRC staff RAI, FENOC provided the results of an uncertainty analysis (further discussed in Section F.6.1). Therefore, further insights gained from an additional sensitivity analysis would not be expected to yield significant new insights. FENOC explained in the ER and in an RAI response that the gap self-assessment covered Level 1 and LERF elements excluding internal flooding and high F-8
Appendix F winds, and that it focused on identifying gaps to meeting Capability Category II of the ASME PRA standard (ASME 2005). There were four Level A findings and 23 Level B findings from this gap self-assessment. FENOC summarized these findings, and the model changes made to address the findings in Section E.3.1.1.2 of the ER (FENOC 2010), and stated in the RAI response that all of the Level A and B findings are addressed in the SAMA analysis model.
In response to an NRC staff RAI (FENOC 2011), FENOC describes the quality control process used at Davis-Besse for the development and maintenance of the PRA. An operating manual related to the PRA Program and a business practice document related to PRA model management both identify requirements for maintaining and updating the PRA models and applications in accordance with regulatory guide (RG) 1.200, An Approach for Determining the Technical Adequacy of Probabilistic Risk Assessment Results for Risk-Informed Activities (NRC 2007) and ensure that the PRA models are current with the changes to the plant. These control documents cover updates; identifying, tracking, and disposition of plant changes; personnel qualification; self-assessment; PRA software and computer control including software quality assurance; and PRA records and documentation. The NRC staff considers FENOCs quality control process to be of sufficient quality to support the SAMA evaluation.
The NRC staff asked FENOC to identify any changes to the plant, including physical and procedural modifications, since the July 2009 SAMA analysis model that could have a significant impact on the results of the SAMA analysis (NRC 2011a). In response to the RAI, FENOC stated that while there have been some plant changes since the SAMA analysis model, no changes have been identified that would have a significant impact on the SAMA evaluation (FENOC 2011). Furthermore, FENOC states that plant procedures for managing the PRA model specify that plant changes are to be evaluated to determine if they would cause a change of greater than 10 percent CDF, or greater than 20 percent LERF; and there have been no changes that meet these criteria.
Given that the Davis-Besse internal events PRA model has been peer-reviewed and the peer review findings were all addressed, and that FENOC has satisfactorily addressed NRC staff questions regarding the PRA, the NRC staff concludes that the internal events Level 1 PRA model is of sufficient quality to support the SAMA evaluation.
As indicated above, the current Davis-Besse PRA does not include external events. In the absence of such an analysis, FENOC used the Davis-Besse IPEEE to identify the highest risk accident sequences and the potential means of reducing the risk posed by those sequences, as discussed below and in Section F.3.2.
FENOC submitted the Davis-Besse IPEEE in February 1996 (Centerior Energy 1996) in response to Supplement 4 of GL 88-20 (NRC 1991). This submittal included a seismic margins analysis, an internal fire PRA, and an evaluation of high winds, external flooding, and other hazards. While no fundamental weaknesses or vulnerabilities to severe accident risk in regard to the external events were identified, a limited set of plant improvements based on an external events finding was identified and is discussed below. In a letter dated February 8, 2001, the NRC staff concluded that the submittal met the intent of Supplement 4 to GL 88-20, and the applicants IPEEE process is capable of identifying the most likely severe accidents and severe accident vulnerabilities (NRC 2001).
The seismic portion of the IPEEE consisted of a reduced-scope seismic evaluation using the EPRI methodology (EPRI 1991) for seismic margins assessment (SMA), with enhancements specified in NUREG-1407 (NRC 1991), in conjunction with the Seismic Qualification Users Group (SQUG) methodology (SQUG 1992). This method is qualitative and does not provide numerical estimates of the CDF contributions from seismic initiators (EPRI 1991). FENOC indicates in the ER that the SMA has not been updated since the IPEEE. Although the size of F-9
Appendix F an earthquake is usually reported in terms of Richter magnitude, ground-shaking forces are most commonly reported in units of acceleration as a fraction of the force (acceleration) of gravity (g). For the IPEEE seismic assessment, Davis-Besse was categorized as a 0.3 g focused-scope plant per NUREG-1407; however, the applicant performed a 0.15 g reduced scope SMA based on a perceived lower seismic risk at Davis-Besse. The applicant judged seismic risk to be lower at Davis-Besse based on its review of revised Lawrence Livermore National Laboratory (LLNL) seismic hazard curves (NRC 1994a), its review of information notice (IN) 94-32, Revised Seismic Hazard Estimates (NRC 1994b), and its commitment to address the outliers identified by the walkdowns for the Unresolved Safety Issue (USI) A-46 Program.
The SMA determined that the lowest high confidence in low probability of failure (HCLPF) value for the components evaluated was 0.26 g. In the letter dated February 8, 2001, the staff concluded that the aspects of seismic events were adequately addressed, based upon the seismic screening review performed by Brookhaven National Laboratory, staffs screening review, and the licensees responses to additional information (NRC 2001).
The NRC staff asked about whether plant improvements had been made to the five structures and components, four masonry walls, and borated water storage tank (BWST) roof determined to have an HCLPF value of less than 0.3 g in the IPEEE (NRC 2011a). In response to the RAI, FENOC stated that plant improvements had been performed for the four components involving masonry walls and that no modifications have been made to the BWST roof. Updated analyses were performed to ensure allowable stresses and design-basis requirements for masonry structures were met (FENOC 2011). In a followup clarification to the RAI responses, FENOC further explained that a SAMA candidate already identified and evaluated in the ER meets the intent of improving the seismic capacity of the BWST roof. This is further discussed in Section F.3.2.
The Davis-Besse IPEEE seismic evaluation identified one unresolved outlier remaining from implementation of the USI A-46 Program. The one unresolved outlier was the identification of two flammable compressed gas bottles with inadequate seismic mounting. This is further discussed in Section F.3.2. The USI A-46 SER for Davis-Besse indicates that the licensee completed the resolution of all outliers (NRC 2000).
To provide additional insight into the appropriate seismic CDF to use for the SAMA evaluation, the NRC staff used NRC information notice (IN) 2010-18, generic issue 199, Implications of Updated Probabilistic Seismic Hazard Estimates in Central and Eastern United States on existing Plants, which informs applicants that updated seismic data and models show increased seismic hazard estimates for some plants. The NRC report cited in the IN estimates the seismic CDF for Davis-Besse to be between 6.7x10-7 and 6.7x10-6 per year, using 2008 U.S. Geological Survey (USGS) seismic hazard curves. Since FENOC did not provide a seismic CDF contribution in the ER, the NRC staff used a seismic CDF of 6.7x10-6 per year to assess the appropriateness of the external event multiplier used in the SAMA evaluation. The multiplier is further discussed later in this section.
The Davis-Besse IPEEE fire analysis employed a combination of the EPRI fire-induced vulnerability evaluation (FIVE) methodology (EPRI 1993) and PRA analysis. Since the FIVE methodology allowed only a few of the Davis-Besse fire compartments to be screened, modification of the FIVE process was employed to include more detailed analysis of affected circuits, improved fire initiation frequency quantification, inclusion of fire effects evaluations, and crediting fire prevention and suppression. These enhancements were primarily based on guidance from the EPRI Fire PRA Implementation Guide (EPRI 1995). In the first phase, initial qualitative and quantitative screening was used to identify potentially risk significant fire compartments. Safe shutdown equipment was identified, and the routing of the associated supporting electrical cables was determined and qualitatively evaluated to ascertain if there F-10
Appendix F were any plant locations that could be screened out due to the absence of safe shutdown equipment or cables. Fire barriers were evaluated to ensure that any screened out compartments could not cause a fire in an adjacent compartment. The results of the fire compartment interaction analysis were used in the detailed fire analyses of each compartment.
The second phase considered equipment failures beyond those caused by the fire. Using the PRA, plant areas with a fire-induced CDF below 1.0x10-6 per year were screened from further evaluation. The third phase involved detailed fire analysis of the unscreened compartments using guidance from the Fire PRA Implementation Guide (EPRI 1995), detailed evaluation of the potential for fire damage due to specific fires within an area, and detailed evaluation of the function of specific safe shutdown equipment cables. In this phase, fire frequencies were adjusted to remove some of the conservatism in the frequencies for specific fire initiation sources. This included applying severity factors for certain fixed sources of ignition and crediting early suppression of welding-related fires based on historical fire events data, crediting early suppression of other transient fires based on the presence of an automatic fire detection system in the fire compartment, crediting restrictions on the quantity of transient combustibles and the use of approved storage containers for transient combustibles, crediting the frequency of inspections to verify compliance with the requirements for control of transient combustibles, and eliminating conduits and cable trays that were determined to not be credibly damaged by a fire based on its distance from the ignition source. Based on these results, the fire-induced equipment failure list was modified and more compartments were screened.
FENOC stated that the fire PRA has not been updated since the IPEEE. In Section 3.1.2.1 of the ER, FENOC provides the fire CDF for the four areas having a CDF greater than the screening criteria of 1.0x10-6 per year. In response to an NRC staff RAI, FENOC acknowledges that IPEEE Table 4.2.3.2 (Centerior Energy 1996) provides the CDF for 15 fire compartments that were screened out prior to detailed analysis. The NRC IPEEE SER presents the total CDF of these screened out fire compartments to be 3.8x10-6 per year. This CDF, and those for each of the four fire zones have a CDF greater than 1.0x10-6 per year, are presented in Table F-4.
The total fire CDF, determined from summing the values in Table F-4, is 2.9x10-5 per year.
Table F-4. Davis-Besse Fire Zones and Their Contribution to Fire Core Damage Frequency Fire Zone Fire Zone Description CDF (per year)
-6 Q.01 High voltage switchgear Room B 8.2x10
-6 S.01 High voltage switchgear Room A 6.5x10
-6 X.01 Low voltage switchgear room 5.9x10
-6 FF.01 Control room cabinets 4.3x10 (a) -6 Other 3.8x10
-5 Total Fire CDF (all fire zones) 2.9x10 (a)
From the IPEEE SER (NRC 2001).
The NRC staff inquired about additional measures that FENOC had already taken to reduce fire risk since the IPEEE for the four dominant fire areas identified in ER Section E.3.1.2.1 (NRC 2011a). FENOC provided a description of a software tool implemented after issuance of the IPEEE for managing fire risk. This tool tracks inoperable or degraded fire protection features and manages combustible loads and travel paths. This software is maintained by the F-11
Appendix F site fire marshal and controlled by a set of operational procedures. FENOC also provided a SAMA evaluation of these four dominate fire areas, which is discussed further in Section F.3.2.
Considering the above discussion, and the actions taken by FENOC to reduce fire risk since the IPEEE, NRC staff concludes that the fire CDF of 2.9x10-5 per year is reasonable for the SAMA analysis.
The Davis-Besse IPEEE analysis of HFO events (high winds, tornadoes, external floods, and other external events) followed the screening and evaluation approaches specified in Supplement 4 to GL 88-20 (NRC 1991) and did not identify any sequences or vulnerabilities that exceeded the 1.0x10-6 per year criterion (FENOC 2001). Based on this result, the applicant concluded that these other external hazards would be negligible contributors to overall core damage and did not consider any plant-specific SAMAs for these events. However, the applicant did note that the updated safety analysis report and the control room habitability study did not accurately reflect the current chemicals stored onsite. This is discussed further in Section F.3.2.
Based on the aforementioned results, including the NRC staff assessment of the Davis-Besse seismic CDF, the external events CDF is approximately 3.6 times the internal events CDF (based on a seismic CDF of 6.7x10-6 per year, a fire CDF of 2.9x10-5 per year, and an internal events CDF of 9.8x10-6 per year). The NRC staff requested FENOC increase the internal events benefits from a factor of 3 to 3.6 to account for the seismic hazard and for the CDF associated with screened fire compartments (NRC 2011a). In response to the RAI, FENOC chose to provide a revised SAMA evaluation using an external events multiplier of 4.6 resulting in a total multiplier of 5.6 ((2.9x10-5+6.7x10-6+1.0x10-5)/(1.0x10-5)+1)) to account for external events, which assumes a seismic CDF of 6.7x10-6 per year, a fire CDF of 2.9x10-5 per year, and an HFO CDF of 1.0x10-5 per year (FENOC 2011). This is discussed further in Section F.6.2.
The NRC staff reviewed the general process used by FENOC to translate the results of the Level 1 PRA into containment releases, as well as the results of the Level 2 analysis, as described in the ER and in response to NRC staff RAIs (FENOC 2010, 2011. The Level 2 model is completely revised from the model used in the IPE and reflects the Davis-Besse plant as designed and operated as of September 2009. In response to NRC RAIs, FENOC explains that one of the most significant changes in the Level 2 model was the increase in level detail reflected in the PDSs and the manner in which their frequency is calculated. To better define the status of containment systems to support CET quantification, 14 PDSs were added.
Another important change was developing a probability distribution for containment failure as a function of internal pressure. The Level 1 core damage sequences are grouped into core damage bins according to similarities in their impact on containment response. The core damage bins, together with the states of containment systems, comprise the nearly 500 PDSs that provide the interface between the Level 1 analysis and Level 2 CET analysis.
Each PDS is analyzed through the Level 2 CET to evaluate the phenomenological progression of the sequence. The current Level 2 model uses a single CET containing both phenomenological and systemic events. In response to an NRC staff RAI, FENOC clarified that the Davis-Besse CET was developed from a B&W owners group generic CET and refined to address phenomena that could impact reactor cooling system integrity, containment response, and release from containment. The CET end states are assigned to one of nine general and 34 specific release categories based on characteristics that determine the timing and magnitude of the release, whether or not the containment remains intact, and isotopic composition of the release material (FENOC 2010). The frequency of each release category was obtained by summing the frequency of the individual accident progression CET endpoints binned into the release category.
F-12
Appendix F Source term release fractions were developed for each of the 34 release categories based on the results of plant-specific calculations using the MAAP Version 4.0.6. A separate MAAP calculation was performed for each of the 34 release categories. The 2012 SAMA supplement provided updated MAAP results to correct an error in the ER MAAP results (FENOC 2012a).
The release categories and their release characteristics and frequencies are presented in Table E.3-13 of the 2012 SAMA supplement (FENOC 2012a) and Table E.3-20 of Appendix E to the ER (FENOC 2010) as corrected in the 2012 SAMA supplement (FENOC 2012a). The updated baseline dose risk and offsite economic risk from the 2012 SAMA supplement were used in the SAMA evaluation (FENOC 2012a).
The total Level 2 release frequency, based on the sum of CET sequences, is 1.0x10-5 per year, which is 2 percent higher than the Level 1 internal events CDF of 9.8x10-6 per year. This is due to the additional systems included in the Level 2 PRA models and to the presence of minimal cutsets that do not represent viable event sequences. The NRC staff considers that use of the release frequency, rather than the Level 1 CDF, will have a negligible impact as it is very small in comparison to the external events multiplier. The NRC staff asked FENOC to identify the release categories that comprise the LERF and to confirm that these contribute to the LERF importance analysis listing presented in Table E.3-4 (NRC 2011a). In response to the RAI, FENOC identified the release categories comprising LERF and provided a new LERF importance listing based on a re-review and identification of a few minor discrepancies. ER Table E.5-3 was revised to correct the identified discrepancies. This is discussed further in Section F.3.2.
The NRC staffs review of the Level 2 IPE concluded that it addressed the most important severe accident phenomena normally associated with large, dry containments, and it identified no significant problems or errors (NRC 1996). The revisions to the Level 2 model since the IPE, to update the methodology and to address peer review recommendations, are described in Section E.3.2.2 of the ER and in response to NRC staff RAIs (FENOC 2011). The Level 2 PRA model was included in the B&W owners group peer review mentioned previously. All peer review findings have been addressed and are considered closed. The NRC staff asked FENOC about the implementation status of suggested plant improvements made in the IPE back-end analysis and asked FENOC to identify and evaluate SAMA candidates for those that have not been implemented (NRC 2011a). In response to the RAI, FENOC states that each of the suggested improvements has been implemented (FENOC 2011). This is discussed further in Section F.3.2.
Based on the following information, the NRC staff concludes that the Level 2 PRA provides an acceptable basis for evaluating the benefits associated with various SAMAs:
the NRC staffs review of the Level 2 methodology, the fact that FENOC adequately addressed NRC staff RAIs, the fact that the Level 2 PRA model was reviewed as part the 1999 owners group peer review of the LERF analysis, and the 2008 gap self-assessment.
In response to NRC staff RAIs, FENOC explains that the reactor core radionuclide inventory used in the consequence analysis corresponds to the end-of-cycle values for Davis-Besse operating at 2,827 MWt, which incorporates a 2 percent uncertainty in core power. In Section 3.1.2 of the ER, it is stated that the operating license and technical specifications were amended in 2008 to allow an increase in rated thermal power from 2,772 MWt to 2,817 MWt.
F-13
Appendix F The reactor core radionuclide inventory assumes a 2 percent uncertainty margin; therefore, it bounds the uprated power level. The core radionuclide inventory is provided in Table E.3-17 of Appendix E of the ER (FENOC 2010). The ER noted that the description of plant facilities and operations and associated impact evaluations in this ER, therefore, assume operation at 2,827 MWt.
The NRC staff reviewed the process used by FENOC to extend the containment performance (Level 2) portion of the PRA to an assessment of offsite consequences (Level 3). This included consideration of the source terms used to characterize fission product releases for the applicable containment release categories and the major input assumptions used in the offsite consequence analyses. Version 1.12 of the MACCS2 code was used to estimate offsite consequences. Plant-specific input to the code includes the source terms for each release category and the reactor core radionuclide inventory (both discussed above), site-specific meteorological data, projected population distribution within a 50-mi (80-km) radius for the year 2040, emergency evacuation planning, and economic parameters including agricultural production. This information is provided in Section 3.0 of Attachment E to the ER (FENOC 2010), as corrected in the 2012 SAMA supplement for four errors in the MACCS2 input data (FENOC 2012a).
Releases were modeled as occurring at four different elevations, specific to each of the MAAP cases. These heights were ground level, 2.13 meters (m), 18.44 m, or 45.42 m. Building wake effects were modeled assuming a building width of 44 m and height of 73 m. The release energy varied from 265 watts (ambient) to 97 megawatts (MW). These are documented in Table E.3-13 of the ER by release category (FENOC 2010). In response to an NRC staff RAI, FENOC identified the heat release for each release category for sensitivity case A1 (FENOC 2012a). A sensitivity study, Case A1, was performed on the methodology used to calculate the release energy, which resulted in a higher release energy for each release category. In the sensitivity study, the energy of release was obtained from MAAP by multiplying the mass flow rate times the enthalpy of the release gas. The results showed a decrease in population dose risk of 3.3 percent and in offsite economic cost risk of 5.3 percent (FENOC 2012a). This result is expected since a higher energy release will both increase the radioactive decay period of the plume and increase the extent of dispersion of the plume. Since a higher energy release results in decreased population dose and offsite economic cost risk, the NRC staff concludes that the release parameters used are acceptable for the purposes of the SAMA evaluation.
FENOC used site-specific meteorological data for the year 2006 as input to the MACCS2 code.
Meteorological data included wind speed, wind direction, delta-temperature, and precipitation for each hour of the year. Wind speed and direction are collected from various levels at a 100-m primary tower and a nearby 10-m backup tower. The 100-m tower also measures differential temperatures at several levels to determine atmospheric stability. The development of the meteorological data is discussed in Sections 2.10 and E.3.4 of the ER (FENOC 2010). Data from 2006 through 2008 were considered, but the 2006 data were chosen because they were the most complete data set. Data from year 2008 were considered unusable as they contained too many missing long sequences of unusable data. A sensitivity study, Case M1, was performed using year 2007 data. The results showed a decrease in population dose risk of 0.5 percent and an increase in offsite economic cost risk of 1.1 percent (FENOC 2012a). The NRC staff notes that these results are consistent with previous SAMA analyses that have shown little sensitivity to year-to-year differences in meteorological data.
Missing data were estimated using data substitution methods (FENOC 2011). The 100-m tower measures differential temperatures at several levels to determine atmospheric stability. Mixing heights, which are presented in Table E.3-12 of the ER, were specified for a.m. and p.m. hours F-14
Appendix F and are based on Environmental Protection Agency (EPA) data (EPA 1972). A sensitivity study, Case A2, was performed assuming more extreme values of the meteorological boundary parameters (e.g., stability class, rainfall, wind speed). This resulted in no change in the population dose risk or offsite economic cost risk (FENOC 2012a). The NRC staff concludes that the use of the 2006 meteorological data in the SAMA analysis is reasonable.
The population distribution the applicant used as input to the MACCS2 analysis was estimated for the year 2040 using year 2000 census data as accessed by SECPOP2000 (NRC 2003). In response to an NRC staff RAI, FENOC identified that known code errors in SECPOP2000 did not apply as only the SECPOP2000 population data were used (FENOC 2011). All other site file parameters were developed independently. The year 2040 is 3 years beyond the renewed license year 2037. The baseline population was determined for each of 160 sectors, consisting of the 16 directions for each of 10 concentric distance rings with outer radii at 1, 2, 3, 4, 5, 10, 20, 30, 40 and 50 mi surrounding the site. County population growth estimates were applied to year 2000 census data to develop year 2040 population distribution.
In response to an NRC staff RAI, FENOC revised the Level 3 PRA to include that portion of the Canadian population located within the 50-mi radius SAMA analysis region (FENOC 2011).
SECPOP2000 contains only United States population data, and the Canadian population was not included in the Level 3 assessment. The year 2000 population from SECPOP2000 and Table 2.6-1 of the ER, which contains the population for Ontario, Canada from the 2001 Canadian census, were used to revise the total population within the 50-mi radius of Davis-Besse. The revised population was escalated to year 2040, resulting in a total population of 2,903,790.
In a clarification to a response to an NRC staff RAI, FENOC confirmed that transient population was included in the revised population (between 0 and 30 mi) (NRC 2011b). The transient population segment includes seasonal residents, transient population, and boating population.
The seasonal population group comprises those people who reside in the area during warmer months, principally May through October. The transient population group comprises those people who enter the area for a specific purpose (e.g., recreation) and who leave on the same day or stay overnight at motels and hotels. The distribution of the population is given for the 10-mi radius from the Davis-Besse plant site and for the 50-mi radius from the Davis-Besse site in the revised Table E.3-11 of the RAI responses (FENOC 2011). The SAMA analysis was revised to use the revised population estimate, and relevant revised sections of the ER were provided in the RAI response. The revisions included the addition of the Canadian population, revised cost-benefit results, and revised base case and sensitivity case comparisons discussed in this section and in Section F.6. The population dose reported in Table F-2 also incorporates the results of the revised population estimate. A sensitivity case, Case S1, was performed using a population escalation to year 2060 and a second sensitivity case, Case S2, for a less conservative population escalation to year 2040 (1.5 percent per decade). A base population escalation of 4.7 percent per decade was used in the SAMA analysis, which is the rate of increase in the population of Ohio between 1990 and 2000 based on census records. The escalation to year 2060 showed an increase in population dose risk of 9.4 percent and in offsite economic cost risk of 9.2 percent (FENOC 2012a). The 1.5 percent escalation showed a decrease in population dose risk of 11.3 percent and in offsite economic cost risk of 10.9 percent (FENOC 2012a). The NRC staff considers the methods and assumptions for estimating population reasonable and acceptable for purposes of the SAMA evaluation.
FENOC performed sensitivity analyses to determine the impact on population dose risk and offsite economic cost risk for changes to release energy, meteorology, warning delay time, evacuation speed, sheltering, population and water shed assumptions as shown in Table F-5.
F-15
Appendix F Table F-5. Impact on Population Dose Risk and Offsite Economic Cost Risk for Selected Sensitivity Cases Population Dose Risk Offsite economic Cost Risk (person-rem/year) (dollars/year x 1000)
Sensitivity Case Baseline Sensitivity % Baseline Sensitivity %
Result Result Difference Result Result Difference Case A1Simpler release energy 2.12 2.05 -3.3 3.59 2.40 -5.3 methodology Case A2More extreme values of meteorological boundary 2.12 2.12 0 3.59 3.59 0 parameters Case A3Increase warning delay 2.12 2.12 0 3.59 3.59 0 time to 20 minutes Case E1Increase evacuation 2.12 2.11 -0.5 3.59 3.59 0 speed to 1.0 mps Case E2Change sheltering 2.12 1.62 -23.6 3.59 2.16 -39.8 shielding to brick housing Case E34.7% per decade escalation in population and 2.12 2.12 0 3.59 3.59 0 proportional decrease in evacuation speed Case M1Use year 2007 2.12 2.11 -0.5 3.59 3.63 +1.1 meteorological data Case S1Population escalation 2.12 2.32 +9.4 3.59 3.92 +9.2 to year 2060 Case S2Population escalation 2.12 1.88 -11.3 3.59 3.20 -10.9 of 1.5% per decade Case S3Watershed index of 1.0 2.12 2.18 +2.8 3.59 3.59 0 for all sectors The emergency evacuation model was modeled as a single evacuation zone extending out 10 mi (16 km) from the plant. FENOC assumed that 95 percent of the population would evacuate. This assumption is conservative relative to the NUREG-1150 study (NRC 1990),
which assumed evacuation of 99.5 percent of the population within the emergency planning zone (EPZ). The evacuated population was assumed to move at an average speed of approximately 0.58 meters per second (mps) (1.3 miles per hour (mph)) with a delayed start time of 4 hours0.167 days <br />0.0238 weeks <br />0.00548 months <br /> and 55 minutes after declaration of a general emergency. The evacuation speed was derived from the projected time to evacuate the entire EPZ under the most conservative (long-time) conditions for Summer, Midday, Weekend (FENOC 2010). In response to an NRC staff RAI, FENOC identified that the evacuation analysis did not clearly identify a reference year for the EPZ population, and it was assumed to be year 2000 (FENOC 2011). No correction of the EPZ evacuation speed was made for the year 2040 population. In further response to the RAI, FENOC performed a sensitivity study, Case E3, using a 4.7 percent per decade escalation of the year 2000 EPZ population to year 2040 and assumed the evacuation speed decreased proportional to the population increase, or to 0.52 mps (1.2 mph). This resulted in no change in population dose risk and no change in offsite economic cost risk (FENOC 2011). A sensitivity study, Case E1, was performed in which the F-16
Appendix F evacuation speed was increased to 1.0 mps (2.2 mph). This resulted in a 0.9 percent decrease in the total offsite population dose risk and no change in the offsite economic cost risk (FENOC 2011). An additional sensitivity study, Case A3, was performed for the warning delay time. The base case assumed about 300 seconds (5 minutes). The sensitivity case increased the warning time to 20 minutes. This resulted in no change in population dose risk and no change in offsite economic cost risk (FENOC 2012a). One additional sensitivity case was performed for shielding factors. The base case assumed wood housing, and the sensitivity case, Case E2, assumed brick. The sensitivity results showed a decrease in population dose risk of 23.6 percent and in offsite economic cost risk of 39.8 percent (FENOC 2012a). The NRC staff concludes that the evacuation assumptions and analysis are reasonable and acceptable for the purposes of the SAMA evaluation.
Site-specific agriculture and economic data were provided from 2007 National Census of Agriculture (USDA 2009a, 2009b) data for each of the 10 counties surrounding Davis-Besse to a distance of 50 mi (80 km). This included the fraction of land devoted to farming, annual farm sales, the fraction of farm sales resulting from dairy production, and the value of both farmland and non-farmland. Non-farm wealth was derived from 2005 and 2006 property tax valuations (MDT 2007; ODT 2008). A sensitivity case, Case S3, was performed using a water shed index of 1.0 (maximum runoff consequences) for all sectors. The results showed an increase in population dose risk of 2.8 percent and no change to offsite economic cost risk (FENOC 2011).
Area-wide farm wealth was determined from 2005 and 2006 property tax valuations (MDT 2007; ODT 2008) and county statistics for farmland, buildings, and machinery, with only the fraction of each county within 50 mi of Davis-Besse considered. The daily cost of compensation for evacuees and short-term relocatees used the year 2000 census economic data for each state (USCB 2000; USGSA 2000). In addition, parameters describing the cost of population and business relocation, farm and non-farmland decontamination, and decontamination labor used MACCS2 default values (NRC 1998a). An escalation factor of 1.95 based on the consumer price index was applied to these parameters to account for cost escalation from 1986 (the year the input was first specified) to 2009 (FENOC 2012b).
The NRC staff concludes that the methodology used by FENOC to estimate the offsite consequences for Davis-Besse provides an acceptable basis from which to proceed with an assessment of risk reduction potential for candidate SAMAs. Accordingly, the NRC staff based its assessment of offsite risk on the CDF and offsite doses reported by FENOC.
F.3 Potential Plant Improvements The process for identifying potential plant improvements, an evaluation of that process, and the improvements evaluated in detail by FENOC are discussed in this section.
F.3.1 Process for Identifying Potential Plant Improvements FENOCs process for identifying potential plant improvements (SAMAs) consisted of the following elements:
review of the dominant cutsets and most significant basic events from the current, plant-specific PRA, review of potential plant improvements identified in the Davis-Besse IPE and IPEEE, F-17
Appendix F review of SAMA candidates identified for LRAs for selected pressurized-water reactor (PWR) plants, and review of other industry documentation discussing potential plant improvements.
Based on this process, an initial set of 168 candidate SAMAs, referred to as Phase I SAMAs, was identified. In Phase I of the evaluation, FENOC performed a qualitative screening of the initial list of SAMAs and eliminated SAMAs from further consideration using the following criteria:
The SAMA has design difference or has already been implemented at Davis-Besse.
The SAMA is not applicable to Davis-Besse.
The SAMA has estimated implementation costs that would exceed the dollar value associated with eliminating all severe accident risk at Davis-Besse.
The SAMA is related to a non-risk significant system and, therefore, has a very low benefit.
The SAMA Is similar in nature and could be combined with another SAMA candidate.
Based on this screening, 153 SAMAs were eliminated, leaving 15 for further evaluation. The remaining SAMAs, referred to as Phase II SAMAs, are listed in Table E.7-1 of the ER (FENOC 2010). In Phase II, a detailed evaluation was performed for each of the 15 remaining SAMA candidates, as discussed in Sections F.4 and F.6 below. To account for the potential impact of external events, the estimated benefits based on internal events were multiplied by a factor of 5.6, as previously discussed.
In response to NRC staff RAIs, FENOC re-evaluated all SAMAs screened in Phase I as Very Low Benefit using a recalculated maximum benefit based on an increased multiplier of 5.6 to account for the impact of external events. Based on this reevaluation, no additional SAMAs screened in Phase I were retained for the detailed Phase II evaluation.
F.3.2 Review of FENOCs Process FENOCs efforts to identify potential SAMAs focused primarily on areas associated with internal initiating events but also included explicit consideration of potential SAMAs for fire and seismic events. The initial list of SAMAs generally addressed the accident sequences considered to be important to CDF from functional, initiating event, and risk reduction worth (RRW) perspectives at Davis-Besse.
FENOCs SAMA identification process began with a review of the list of potential PWR enhancements in Table 14 of Nuclear Energy Institute (NEI) 05-01 (NEI 2005). Review of this generic SAMA list resulted in all of the SAMAs from this table being identified as Phase I SAMAs, for a total of 154 Phase I SAMAs.
FENOC provided a tabular listing of the Level 1 PRA basic events sorted according to their RRW and the top 100 cutsets (FENOC 2010). SAMAs impacting these cutsets and basic events would have the greatest potential for reducing risk. For the basic events listing, FENOC used an RRW cutoff of 1.005, which corresponds to about a 0.5 percent change in CDF given 100-percent reliability of the SAMA. The NRC staff requested FENOC to identify the SAMA candidates that address each of the basic events having an RRW equating to a benefit greater than the minimum cost of a procedure change (NRC 2011a). In response to the RAI, FENOC F-18
Appendix F provided a review of all Level 1 basic events having an RRW greater than or equal to 1.03, which corresponds to about a 3 percent change in CDF given 100-percent reliability of the SAMA (FENOC 2011). This equates to a benefit of approximately $10,000 for internal events, which is the estimated minimum cost of a procedure change. Based on the review of evaluations from other plants, the $10,000 estimated minimum cost for a procedure change is conservative.
Of the over 40 basic events reviewed, SAMA candidates were identified for all but 12 of the basic events. These remaining basic events were found to be: (1) events that had no physical meaning (such as a flag event or a plant configuration probability event); (2) events for which no feasible SAMA was identified; (3) events that could only be addressed by a hardware modification and had a maximum benefit less than the minimum cost of $100,000 for a hardware change; or, (4) events that are being addressed by the installation of new steam generators in 2013.
In addition, as a result of the reevaluation of the Level 1 basic importance list in the RAI response, FENOC identified new SAMA candidate OT-09R, present the highest worth PRA human actions to the Davis-Besse operator training. This SAMA candidate was, however, subsequently found by FENOC to already be implemented at Davis-Besse. Davis-Besse provides PRA information such as risk significant initiating events, high worth operator actions and high worth equipment. This information is provided to various departments and is presented on posters throughout the plant. In response to other NRC staff RAIs, FENOC explained that the following eight SAMA candidates were identified from plant-specific risk insights during the review of the cutsets and Level 1 basic events importance list: CB-20, install relief valves in the CCW system; CB-21, install pressure measurements between the two DHR suction valves in the line from the RCS hot leg; CC-19, provide automatic switchover of HPI and LPI suction from the BWST to containment sump for LOCAs; CC-21, reduce the BWST level at which switchover to containment recirculation is initiated; CP-19, install a redundant containment fan system; CW-24, replace the standby CCW pump with a pump diverse from the other two CCW pumps; CW-25, provide the ability to cool makeup pumps using fire water in the event of loss of CCW; and FW-16, perform surveillances on manual valves used for backup AFW pump suction (FENOC 2011).
The NRC staff asked FENOC to specifically address the potential for SAMAs for the following basic events in the importance listing: WHAF3ISE, failure to isolate flood in room 328 before CCW pumps are affected; SHAF2ISE, failure to isolate flood before service water pumps are affected; F3AM, maximum flood in CCW pump room from service water (initiating event) and F7L, large circulating water flood in turbine building (initiating event) (NRC 2011a). In response to the RAI, FENOC explained that no SAMAs were identified for the first three events because they did not have an RRW benefit value equal to or greater than the cost of a procedural change (FENOC 2011). However, Phase I SAMA candidate FL-01, improve inspection of rubber expansion joints on the main condenser, was identified to address basic event F7L.
FENOC determined, after further evaluation of this SAMA, that it was already implemented at Davis-Besse and, as a result, the screening disposition for FL-01 was reclassified in the Phase I screening from having a very low benefit to already implemented.
The NRC staff asked FENOC to evaluate a SAMA for basic events QMBAFP11 and QMBAFP12, which involve maintenance outages of the auxiliary feedwater (AFW) trains, which would make improvements to AFW maintenance practices or hardware (NRC 2011a). In response to the RAI, FENOC explained that AFW maintenance unavailability data used in the PRA is based on Maintenance Rule data and is consistent with the generic industry unavailability data reported in NUREG/CR-6928 (FENOC 2011). FENOC further explained that improvements to maintenance practices at Davis-Besse are proposed and evaluated as an F-19
Appendix F element of normal business practices to maintain the AFW train unavailability at its lowest achievable value. Based on the unavailability of the AFW being consistent with the industry unavailability data, and because of the high cost of making improvements to safety-related hardware, FENOC concluded that a SAMA to improve the availability of the AFW pumps is not expected to be cost-beneficial. Based on this information, the NRC staff agrees that a SAMA to improve the availability of the AFW pumps is unlikely to be cost-beneficial.
The NRC staff noted that there are a significant number of operator errors and non-recovery actions that appear in the CDF and LERF importance listings and top 100 cutsets listing, yet no weakness in training or procedures was identified. In light of this, the NRC staff asked FENOC to explain the process used to make the determination that no opportunities exist to improve training or procedures and to discuss whether opportunities exist for reducing risk by providing automatic functions to risk significant operator actions (NRC 2011a). In response to the RAI, FENOC explains that, based on its analysis of human failure events using the EPRI HRA calculator, no specific vulnerabilities in procedures, training, staff, assumptions, performance shaping factors, or timing were found (FENOC 2011). FENOC further explains, however, that two additional SAMA candidates were evaluated to address risk-significant operations AC/DC-28R, automatically start and load the SBO DG on Bus D2 upon loss of power to the bus, and OT-08R, automatically start and load the SBO DG on Bus D2 upon loss of power to the bus in combination with automatically starting the motor-driven feedwater pump (MDFP).
These are discussed further in Section F.6.2. In a clarification to the RAI response, FENOC concludes that the opportunities to automate operator actions has been fully considered because, in addition to these two additional SAMA candidates, three new SAMA candidates related to automating operator actions were evaluated in response to other NRC staff RAIs (SAMAs CC-22R, CW-26R, and FW-17R defined in Table F-6 and discussed in Section F.6.2).
Five SAMA candidates were identified and evaluated in the ER to evaluate automating operator actions (SAMAs AC/DC-14, AC/DC-25, AC/DC-26, AC/DC-17, and CC-19), and other additional Phase I SAMA candidates to automate operator actions were identified but screened from the Phase II evaluation. Additionally, all basic events having an RRW equal to or greater than the cost of a procedure change were reviewed for SAMA candidates (NRC 2011b). The NRC staff concludes that the opportunity for SAMA candidates to automate operator actions has been adequately explored, and it is unlikely that there are additional cost-beneficial SAMA candidates to automate operator actions.
FENOC also provided and reviewed the LERF-based RRW events down to a RRW of 1.005 (FENOC 2010). In response to an NRC staff RAI, FENOC provided a review of all Level 2 basic events having an RRW greater than or equal to 1.03 as was done for the Level 1 basic events (FENOC 2011). FENOC explained that the RRW for the Level 2 basic events was calculated based on LERF rather than CDF and that the estimated benefit for each basic event was derived by taking the RRW for LERF and applying the maximum benefit used for the CDF event, which is conservative. Of the over 20 basic events reviewed, SAMA candidates were identified for about half of the basic events. The remaining basic events were found to be:
(1) events that had no physical meaning (such as a flag event or a plant configuration probability event); (2) events for which no feasible SAMA was identified; (3) events that could only be addressed by a hardware modification and had a maximum benefit less than the minimum cost of $100,000 for a hardware change; or, (4) that are being addressed by the installation of new steam generators in 2013. No new SAMA candidates were identified from this review.
FENOC reviewed the SAMA candidates from prior SAMA analyses for nine PWR sites.
FENOCs review did not identify any additional SAMA candidates applicable to Davis-Besse that were not already identified from the importance analysis review described above.
F-20
Appendix F For some of the SAMAs listed in the ER, the information provided did not sufficiently describe the proposed modification. Therefore, the NRC staff asked the applicant to provide more detailed descriptions of the modifications for several of the SAMA candidates (NRC 2011a). In response to the RAI, FENOC provided the requested information on the modifications for SAMAs: AC/DC-01, provide additional DC battery capacity; CC-19, install a redundant containment fan system; AC/DC-25, provide a dedicated DC power system (battery/battery charger) for TDAFW control; and CW-24, replace the standby CCW pump with a pump diverse from the other two CCW pumps (FENOC 2011).
FENOC considered both the potential plant improvements and risk insights described in the IPE and IPEEE in the identification of plant-specific candidate SAMAs for internal and external events. Although the IPE did not identify any vulnerabilities, seven front-end (Level I PRA) and four back-end (Level II PRA) plant improvements were identified in Part 6, Sections 3.1 and 3.2, respectively, of the IPE report. FENOC identified five additional SAMA candidates to address the five front-end plant improvements from the IPEAC/DC-25, AC/DC-26, AC/DC-27, HV-06 (Provide procedural guidance for establishing an alternate means of room ventilation to the service water pump room), and CC-20 (Modify hardware and procedures to allow using the makeup pumps for high pressure recirculation from the containment sump).
The NRC staff requested information regarding the status of the four suggested back-end improvements from the IPE (NRC 2011a). In response to the RAI, FENOC clarified that the four suggested improvements (i.e., reduce the BWST level during switchover to sump recirculation, improve operator actions for inadequate core cooling, re-examine the emergency plan evacuation criteria, and monitor carbon monoxide levels in containment) have been implemented.
The NRC staff requested information regarding lower cost alternatives to some of the SAMAs evaluated (NRC 2011a), including those listed below:
(a) automate RCP trip on high motor bearing cooling temperature, (b) use the decay heat removal (DHR) system as an alternate suction source for high-pressure injection (HPI),
(c) automate HPI injection on low pressurizer level (in loss of secondary side heat removal cases where the reactor coolant system (RCS) pressure remains high while the RCS level drops),
(d) automate refill of the BWST, (e) automate start of AFW pump in the event the automated emergency feedwater (EFW) system is unavailable, and (f) purchase or manufacture of a gagging device that could be used to close a stuck-open steam generator safety valve for an SGTR event prior to core damage.
In response to the RAIs, FENOC addressed the suggested lower cost alternatives and determined that they were already implemented at Davis-Besse (b), not feasible (c), or not cost-beneficial (a, d, e, and f)(FENOC 2011). This is discussed further in Section F.6.2.
Based on this information, the NRC staff concludes that the set of SAMAs evaluated in the ER, together with those identified in response to NRC staff RAIs, addresses the major contributors to internal event CDF.
The Davis-Besse IPEEE seismic evaluation identified one unresolved outlier remaining from implementation of the USI A-46 Program. The one unresolved outlier was the identification of two flammable compressed gas bottles in the auxiliary building with inadequate seismic F-21
Appendix F mounting. An action to address the seismic-fire interaction issues associated with these flammable compressed gas bottles was identified and implemented by the applicant (NRC 2001). The USI A-46 SER for Davis-Besse indicates that the license had completed the resolution of all outliers (NRC 2000).
As discussed in Section F.2.2, the NRC staff requested information regarding any plant improvements for identified structures and components with an HCLPF value of less than 0.3 g (i.e., BWST roof, Masonry Wall No. 2367, Masonry Wall No. 3407, Masonry Wall No. 4786, and Masonry Wall No. 6107). The NRC staff asked the applicant to identify and evaluate SAMAs to improve the seismic capacity of these components and structures (NRC 2011a). In response to the RAI, FENOC explains that seismic improvements have been made to two of the masonry walls and that the Davis-Besse masonry wall analysis has been updated to ensure that the other two masonry walls met allowable stresses and design basis requirements (FENOC 2011).
In a clarification to the RAI response, FENOC further explains that SAMA CC-10, which considers providing an in-containment reactor water storage tank, meets the intent of improving the seismic capacity of the BWST by providing a tank independent of the BWST (NRC 2011b).
The IPEEE did not identify opportunities for improvements related to fire events (FENOC 1996).
FENOC also did not identify any other plant vulnerabilities in the IPEEE that would impact the PRA CDF (FENOC 2010).
The NRC staff asked FENOC to review each of the four dominant fire areas discussed in Section F.2.2 to identify potential SAMA candidates to reduce fire risk and to provide an assessment of identified SAMA candidates (NRC 2011a). FENOC responded that the main contributors to fire risk in all four areas are the MDFP, AFW system, and pilot-operated relief valve (PORV) (FENOC 2011). Loss of all feedwater or the inability to perform feed and bleed cooling are the primary contributors to CDF. FENOCs search for SAMA candidates, therefore, focused on these two fire-induced failure scenarios and determined that existing Phase I SAMAs (CC-16, FW-02, FW-08, FW-09, FW-10, and FW-11) already adequately address these contributors to CDF.
The NRC staff identified three SAMA candidates (CB-02, CP-21, and OT-07) that were screened on very low benefit based on low contribution to LERF. In light of the fact that the release categories comprising LERF were not identified in the ER, the NRC staff asked FENOC to justify screening out these SAMA candidates (NRC 2011a). In response to the RAI, FENOC explains two of these SAMAs (CB-02 and CP-21) do not contribute to LERF and, therefore, are appropriately screened (FENOC 2011). FENOC also clarified that the screening basis in the ER for SAMA OT-07 was incorrect and that this SAMA was screened on the basis of its contribution to both CDF and LERF.
The NRC staff noted that several Phase I SAMAs were screened by being subsumed into other SAMAs and asked FENOC to either confirm that cost to implement these SAMAs is lower than those into which the SAMA was subsumed or provide a revised basis for the Phase I screening (NRC 2011a). In response to the RAI, FENOC explained that four such SAMAs (i.e., AC/DC-06, AC/DC-09, AC/DC-20, and CC-08) have an equivalent or higher implementation cost than the SAMAs into which they were subsumed (FENOC 2011). FENOC also provided a cost-benefit evaluation of these SAMAs. This is discussed further in Section F.6.2. FENOC further explained that the fifth subsumed SAMA (i.e., CB-07) was subsumed into SAMA CB-08, which was screened as already implemented at Davis-Besse.
FENOC also determined that SAMA CB-08 was already implemented and rescreened this SAMA on that basis.
The NRC staff noted that Phase I SAMA CB-18, direct steam generator flooding after an SGTR, prior to core damage, was screened because it could impact efforts to mitigate SGTR, F-22
Appendix F but it points out that this SAMA has been shown to be cost-beneficial in other SAMA analyses and asked FENOC to evaluate this SAMA (NRC 2011a). FENOC explained that in the Davis-Besse PRA model the SGTR sequences are grouped into core damage bins in which either feedwater is unavailable to the steam generators and, therefore, flooding the steam generators is not possible or feedwater is available and scrubbing is already expected to occur so that flooding the steam generators provides no additional scrubbing benefit (FENOC 2011).
Based on this, FENOC concludes that further evaluation of SAMA CB-18 is not warranted.
Based on the once-through steam generator design used at Davis-Besse, the NRC staff agrees with this conclusion.
FENOC did not identify any additional SAMA candidates in the 2012 SAMA supplement (FENOC 2012a)
The NRC staff notes that the set of SAMAs submitted is not all-inclusive, since additional, possibly even less expensive, design alternatives can always be postulated. However, the NRC staff concludes that the benefits of any additional modifications are unlikely to exceed the benefits of the modifications evaluated and that the alternative improvements would not likely cost less than the least expensive alternatives evaluated, when the subsidiary costs associated with maintenance, procedures, and training are considered.
The NRC staff concludes that FENOC used a systematic and comprehensive process for identifying potential plant improvements for Davis-Besse, and the set of SAMAs evaluated in the ER, together with those evaluated in response to NRC staff inquiries, is reasonably comprehensive and, therefore, acceptable. This search included reviewing insights from the plant-specific risk studies and reviewing plant improvements considered in previous SAMA analyses. While explicit treatment of external events in the SAMA identification process was limited, it is recognized that the prior implementation of plant modifications for fire risks, the absence of external event vulnerabilities (as documented in the IPEEE), and the use of an external events multiplier reasonably justifies examining primarily the internal events risk results for this purpose.
F.4 Risk Reduction Potential of Plant Improvements FENOC evaluated the risk-reduction potential of the 15 SAMAs retained for the Phase II evaluation in the ER. The SAMA evaluations were generally performed in a bounding fashion in that the SAMA was assumed to eliminate all of the risk associated with the proposed enhancement. FENOC also provided the risk-reduction potential of six additional SAMAs (i.e., AC/DC-28R, OT-08R, CW-26R, CC-22R, FW-17R, and CB-22R) identified in response to RAIs using the same bounding approach. This bounding approach overestimates the benefit and is conservative.
FENOC used model re-quantification to determine the potential benefits. The CDF, population dose, and offsite economic cost reductions were estimated using the Davis-Besse SAMA analysis model. The changes made to the model to quantify the impact of SAMAs are detailed in Table E.7-1 of Attachment E to the ER (FENOC 2010). The changes made to the model to determine the risk reduction for the six SAMAs identified in response to NRC staff RAIs are provided in a clarification to the RAI responses (NRC 2011b). Table F-6 lists the assumptions considered to estimate the risk reduction for each of the evaluated SAMAs, the estimated risk reduction in terms of percent reduction in CDF and population dose, and the estimated total benefit (present value) of the averted risk. The estimated benefits reported in Table F-6 reflect the combined benefit in both internal and external events. The determination of the benefits for the various SAMAs is further discussed in Section F.6.
F-23
Appendix F The NRC staff requested FENOC to clarify why the population dose risk reduction in Table E.7-2 of the ER is either 10 percent or 0 percent and to explain how population dose risk was calculated (NRC 2011a). In response to the RAI, FENOC clarified that binary appearance of the reported population dose risk reduction is due to the round-off used in spreadsheet calculations (FENOC 2011). It was further explained that the population dose for each SAMA candidate is determined using the population dose determined by MACCS2 for each release category, the release category frequency from the PRA, and the sum of the population dose risk times the frequency for all release categories. The percent change is determined by comparison of the population dose risk for each SAMA candidate compared with the base case.
In addition, FENOC regenerated the population dose risk reduction for all SAMAs evaluated, including the new SAMAs evaluated in response to NRC RAIs, to a higher number of significant digits to illustrate the distinction between the population dose risk values for each SAMA candidate. The regenerated population dose risk reduction for each SAMA candidate includes the revised Level 3 PRA analysis to include the Canadian population, as discussed in Section F.2.2. The revised population dose risk values having more significant figures are provided in Table F-6.
F-24
Appendix F Table F-6. SAMA Cost-Benefit Screening Analysis for Davis-Besse(a)
(c)
% Risk Reduction Total benefit ($)
SAMA Modeling Assumptions Using 7% Using 3% Cost ($)
Population CDF (c) Discount Discount Dose Rate Rate Reduce the offsite power non-AC/DC-01Provide recovery probabilities to reflect additional DC battery 6 2 100K 150K 1.75M an increase in battery life to capacity 7 hours0.292 days <br />0.0417 weeks <br />0.00959 months <br /> from 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> AC/DC-03Add a Eliminate loss of DC power portable, diesel-driven from station batteries due to 22 12 400K 600K 330K battery charger to loss of DC battery chargers existing DC system Eliminate failure of the AC/DC-14Install a SBO DG and associated 10 16 240K 360K 2.0M gas turbine generator operator actions AC/DC-19Use fire water system as a Eliminate failure of the EDGs 2 2 39K 60K 700K backup source for due to loss of CCW system diesel cooling AC/DC-21Develop procedures to repair or Eliminate failure of the 4 kV 3 <1 48K 72K 100K replace failed 4 kV breakers breakers AC/DC-25Provide a dedicated DC power system (battery/battery Eliminate failure of the charger) for TDAFW system due to loss of 15 3 240K 370K 2.0M turbine-driven auxiliary DC power feedwater (TDAFW) control AC/DC-26Provide an alternator/generator Eliminate failure of the that would be driven TDAFW system due to loss of 15 3 240K 370K 2.0M by each TDAFW pump DC power to provide DC control power AC/DC-27Increase Eliminate failure of the the size of the SBO 0 0 0 0 550K operators to refuel the oil tank fuel oil tank CB-21Install pressure Eliminate latent failure of the measurements upstream DHR suction valve between the two DHR (i.e., eliminate failures of the 0 6 30K 46K 550K suction valves in the inboard isolation valve DH12 (d) line from the RCS hot prior to demand) leg CC-01Install an Eliminate failure of one HPI independent active or 0 1 3.4K 5.3K 6.5M train passive HPI system F-25
Appendix F (c)
% Risk Reduction Total benefit ($)
SAMA Modeling Assumptions Using 7% Using 3% Cost ($)
Population CDF (c) Discount Discount Dose Rate Rate CC-04Add a diverse Eliminate failure of one LPI low-pressure injection 0 0 0 0 5.5M train (LPI) system CC-05Provide Eliminate failure of one LPI capability for alternate train and eliminate failure of 0 0 0 0 6.5M LPI via diesel-driven LPI due to loss of AC/DC fire pump power CC-19Provide automatic switchover Eliminate operator failures to of HPI and LPI suction switchover HPI and LPI 1 0 15K 23K 1.5M from the BWST to suction to the containment containment sump for sump LOCAs HV-01Provide a Eliminate failure of the low redundant train or voltage switchgear room 0 <1 1.4K 2.1K 50K means of ventilation ventilation HV-03Stage backup Eliminate failure of the low fans in switchgear voltage switchgear room 0 <1 1.4K 2.1K 400K rooms ventilation (b)
AC/DC-28R Automatic start and Eliminate operator failure to load SBO DG on 17 4 280K 420K 1.6M start the SBO DG Bus D2 on loss of power to that bus (b)
CB-22R Purchase or manufacture of a gagging device that could be used to close Eliminate failure of main steam 3 12 110K 170K 4.6M a stuck-open steam safety valve to close generator safety valve for an SGTR event prior to core damage (b)
CC-22R Automatic Eliminate operator failure to 0 0 0 0 2.2M refill of the BWST refill the BWST (b)
CW-26R Automatic Eliminate operator failure to RCP trip on high motor trip the RCPs on loss of seal 23 3 365K 550K 1.5M bearing cooling cooling and injection temperature (b)
FW-17R Automatic start of AFW pump in Eliminate operator failure to the event the 25 6 410K 620K 2.8M start the MDFP automated emergency system is unavailable F-26
Appendix F (c)
% Risk Reduction Total benefit ($)
SAMA Modeling Assumptions Using 7% Using 3% Cost ($)
Population CDF (c) Discount Discount Dose Rate Rate (b)
OT-08R Automatic start and load SBO DG on Bus D2 on loss of power to Eliminate operator failure to 43 9 700K 1.1M 4.4M that bus in start the MDFP and SBO DG combination with automatically starting the MDFP (a)
SAMAs in bold are potentially cost-beneficial.
(b)
SAMA description and evaluation provided in response to NRC staff RAIs 5.d and 7a-f (FENOC 2011). SAMA modeling assumptions provided in a clarification to the RAI responses (NRC 2011b).
(c)
Estimated population doses and benefits reflect revised values provided in response to NRC staff RAIs 3.c, 4.b, and 6.e and to correct five errors identified in the 2012 SAMA supplement (FENOC 2011, 2012a).
(d)
Modeling assumption clarified in response to NRC staff RAI 6.h (FENOC 2011).
The NRC staff noted that the risk reduction reported for SAMA AC/DC-14, install a gas turbine generator, which assumes failure of the SBO DG is eliminated, does not appear to credit the situation where all emergency diesel generators (EDGs) are unavailable, and it asked FENOC to provide an assessment of this apparent omission (NRC 2011a). FENOC responded that, in the PRA model, the SBO DG is modeled as a backup to either EDG 1 or EDG 2 or both when they are unavailable (FENOC 2011). FENOC also explained that the analysis of this SAMA conservatively eliminated failure of the SBO DG ensuring that one train of emergency power was always available.
The NRC staff has reviewed FENOCs bases for calculating the risk reduction for the various plant improvements and concludes that the rationale and assumptions for estimating risk reduction are reasonable and generally conservative (i.e., the estimated risk reduction is higher than what would actually be realized). Accordingly, the NRC staff based its estimates of averted risk for the various SAMAs on FENOCs risk reduction estimates.
F.5 Cost Impacts of Candidate Plant Improvements FENOC developed plant-specific costs of implementing the original 15 Phase II candidate SAMAs as well as 6 additional SAMAs identified in response to NRC staff RAIs. The NRC staff asked FENOC to describe the level of detail used to develop the cost estimates and to clarify whether the cost estimates accounted for inflation, contingency costs associated with unforeseen implementation obstacles, replacement power during extended outages, and maintenance and surveillance costs during plant operation (NRC 2011a). In response to the RAI, FENOC clarified that the cost estimates conservatively did not include inflation, contingency costs associated with unforeseen implementation obstacles, or the cost of replacement power during extended outages required to implement the modifications (FENOC 2011). FENOC also clarified that the cost estimates considered the cost of equipment, fuel, space requirements, and the extent of the modifications and were developed by an expert panel that was composed of experienced staff drawn from engineering, operations, procurement, and project management. It was further explained that some implementation costs were assigned standard values based on plant experience or estimated man-hour requirements and that the following is true:
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Appendix F minimal procedure changes would be between $10,000 and $50,000, procedural changes with engineering support would be between $50,000 and
$200,000, procedural changes with engineering support and testing or training would be between $200,000 and $300,000, and minimal physical plant changes would start at $100,000.
Support activities included costs associated with procurement, installation, long-term maintenance, surveillance, calibration, and initial and on-going training.
The NRC staff reviewed the bases for the applicants cost estimates (presented in Section E.7.2 of Attachment E to the ER). For certain improvements, the NRC staff also compared the cost estimates to estimates developed elsewhere for similar improvements, including estimates developed as part of other applicants analyses of SAMAs for operating reactors. Specifically, the NRC staff requested justification for the estimated cost of $1.5 million for implementation of SAMA CC-19, provide automatic switch over of HPI and LPI suction from the BWST to containment sump for LOCAs. This amount seems high for what is described as a capability that already exists at Davis-Besse but has been deactivated and is also higher than that estimated by other applicants (NRC 2011a). FENOC explained that the expert panel made the following assumptions in developing the cost estimate for this SAMA candidate (FENOC 2011):
reconnection and reactivation of automatic switchover equipment that is already in place, re-performing the Appendix R analyses since the associated valves were de-powered to meet Appendix R criteria (approximately $500,000),
modifications to safety-related equipment and the associated calculation support (approximately $500,000),
procedure changes and initial testing and training (approximately $300,000),
and ongoing testing, surveillances, maintenance, and training (approximately
$200,000).
Based on the need for the Appendix R analysis, the NRC staff finds FENOCs justification for the cost estimate for SAMA CC-19 reasonable.
The NRC staff requested justification for the estimated cost of $2 million for implementation of SAMA AC/DC-25, provide a dedicated DC power system (battery/battery charger) for the TDAFW control valve and NNI-X for steam generator level indication. This amount seems high for a system dedicated to just the TDAFW control valves and in light of the lower estimated costs for similar SAMA candidates AC/DC-01 and AC/DC-03 (NRC 2011a). In response to the RAI, FENOC explained that the expert panel made the following assumptions in developing the cost estimate for this SAMA candidate (FENOC 2011):
a dedicated set of batteries and battery charger with a longer battery lifetime than the existing safety-related DC system and automatic steam generator level control, safety-related space for the batteries (approximately $400,000),
modifications to safety-related equipment with seismic evaluation and associated calculation support (approximately $500,000),
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Appendix F procedure changes and initial testing and training (approximately $300,000),
and procurement and installation of batteries and other components and equipment (approximately $700,000).
Based on the estimated cost for additional safety-related space for the batteries, the NRC staff finds FENOCs justification for the cost estimate for SAMA AC/DC-25 reasonable.
The NRC staff requested justification for the estimated cost of $7.5 million for implementation of SAMA CW-24, replace the standby CCW pump with a pump diverse from the other two CCW pumps. This amount seems high for a pump replacement (NRC 2011a). FENOC explained that the expert panel made the following assumptions in developing the cost for this SAMA candidate (FENOC 2011):
additional safety-related space is needed to provide separation from the existing CCW pumps (approximately $2 million),
design, procurement, and installation of the pump and associated components and equipment (approximately $4 million),
modifications to safety-related equipment with seismic evaluation and associated calculation support (approximately $1 million), and procedure changes and initial testing and training (approximately $500,000).
Based on the estimated cost for additional safety-related space for the pump, the NRC staff finds FENOCs justification for the cost estimate for SAMA CW-24 reasonable.
The NRC staff requested justification for the estimated cost of $1.75 million for SAMA AC/DC-01, provide additional DC battery capacity (NRC 2011a). In response to the RAI, FENOC explained that the expert panel made the following assumptions in developing the cost for this SAMA candidate (FENOC 2011):
safety-related space for the batteries (approximately $500,000),
major modifications to equipment (approximately $200,000),
procedure changes and initial testing and training (approximately $300,000),
and procurement and installation of batteries and other components and equipment (approximately $600,000).
Based on the estimated cost for additional safety-related space for the batteries, the NRC staff finds FENOCs justification for the cost estimate for SAMA AC/DC-01 reasonable.
The NRC staff reviewed the costs provided in the ER, and in response to NRC staff RAIs, and found them to be reasonable and generally consistent with estimates provided in support of other plants analyses. The NRC staff concludes that the cost estimates provided by FENOC are sufficient and appropriate for use in the SAMA evaluation.
F.6 Cost-Benefit Comparison FENOCs cost-benefit analysis and the NRC staffs review are described in the following sections.
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Appendix F F.6.1 FENOCs Evaluation The methodology used by FENOC was based primarily on NRCs guidance for performing cost-benefit analysis (i.e., NUREG/BR-0184, Regulatory Analysis Technical Evaluation Handbook (NRC 1997a)). The guidance involves determining the net value for each SAMA according to the following formula:
Net Value = (APE + AOC + AOE + AOSC) - COE where the following is true:
APE = present value of averted public exposure ($)
AOC = present value of averted offsite property damage costs ($)
AOE = present value of averted occupational exposure costs ($)
AOSC = present value of averted onsite costs ($)
COE = cost of enhancement ($)
If the net value of a SAMA is negative, the cost of implementing the SAMA is larger than the benefit associated with the SAMA and it is not considered cost-beneficial. FENOCs derivation of each of the associated costs is summarized below.
NUREG/BR-0058 has been revised to reflect the agencys policy on discount rates. Revision 4 of NUREG/BR-0058 states that two sets of estimates should be developed, one at 3 percent and one at 7 percent (NRC 2004). FENOC provided a base set of results using the 7 percent discount rate and a sensitivity study using the 3 percent discount rate (FENOC 2010, 2012a).
Averted Public Exposure Costs. The APE costs were calculated using the following formula:
APE = Annual reduction in public exposure (person-rem/year) x monetary equivalent of unit dose ($2,000 per person-rem) x present value conversion factor (12.27 based on a 28-year period with a 7-percent discount rate)
As stated in NUREG/BR-0184 (NRC 1997a), the monetary value of the public health risk after discounting does not represent the expected reduction in public health risk due to a single accident. Rather, it is the present value of a stream of potential losses extending over the remaining lifetime (in this case, the renewal period) of the facility. FENOC based its calculations on a 28-year period, which is the summation of the 20-year license renewal period and the 8-year period remaining in the current plant license, which is conservative. For the purposes of initial screening, which assumes elimination of all severe accidents caused by internal events, FENOC calculated, in response to an NRC staff RAI, an APE of approximately $52,000 for the 20-year license renewal period and the 8 years of remaining life in the current plant license (FENOC 2012a).
Averted Offsite Property Damage Costs. The AOCs were calculated using the following formula:
AOC = Annual CDF reduction x offsite economic costs associated with a severe accident (on a per-event basis) x present value conversion factor This term represents the sum of the frequency-weighted offsite economic costs for each release category, as obtained for the Level 3 risk analysis. For the purposes of initial screening, which assumes elimination of all severe accidents caused by internal events, FENOC calculated, in response to an NRC staff RAI, an annual offsite economic cost of about $3,590 based on the Level 3 risk analysis (FENOC 2012a). This results in a discounted value of approximately
$44,000 for the 20-year license renewal period and the 8 years of remaining life in the current plant license (FENOC 2012a).
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Appendix F Averted Occupational Exposure Costs. The AOE costs were calculated using the following formula:
AOE = Annual CDF reduction x occupational exposure per core damage event x monetary equivalent of unit dose x present value conversion factor FENOC derived the values for AOE from information provided in Section 5.7.3 of the Regulatory Analysis Handbook (NRC 1997a). Best estimate values provided for immediate occupational dose (3,300 person-rem) and long-term occupational dose (20,000 person-rem over a 10-year cleanup period) were used. The present value of these doses was calculated using the equations provided in the handbook in conjunction with a monetary equivalent of unit dose of $2,000 per person-rem, a real discount rate of 7 percent, and a time period of 28 years to represent the license renewal period and the remaining plant life in the current license. For the purposes of initial screening, which assumes elimination of all severe accidents caused by internal events, FENOC calculated an AOE of approximately $4,300 for the 20-year license renewal period and the 8 years of remaining life in the current plant license (FENOC 2010).
Averted Onsite Costs. AOSCs include averted cleanup and decontamination costs (ACCs) and averted power replacement costs. Repair and refurbishment costs are considered for recoverable accidents only and not for severe accidents. FENOC derived the values for AOSC based on information provided in Section 5.7.6 of NUREG/BR-0184, the Regulatory Analysis Handbook (NRC 1997a).
FENOC divided this cost element into two partsthe onsite cleanup and decontamination cost, also commonly referred to as ACCs, and the replacement power cost (RPC).
ACCs were calculated using the following formula:
ACC = Annual CDF reduction x present value of cleanup costs per core damage event x present value conversion factor The total cost of cleanup and decontamination subsequent to a severe accident is estimated in NUREG/BR-0184 to be $1.5x109 (undiscounted). This value was converted to present costs over a 10-year cleanup period and integrated over the term of the proposed license extension and remaining plant life. For the purposes of initial screening, which assumes elimination of all severe accidents caused by internal events, FENOC calculated an ACC of approximately
$132,400 for the 20-year license renewal period and the 8 years of remaining life in the current plant license.
Long-term RPCs were calculated using the following formula:
RPC = Annual CDF reduction x present value of replacement power for a single event x factor to account for remaining service years for which replacement power is required x reactor power scaling factor FENOC based its calculations on the 910 megawatt-electric (MWe) reference plant in NUREG/BR-0184 (NRC 1997a) and did not scale down to the 908 MWe rating for Davis-Besse.
Therefore, FENOC did not apply a power scaling factor to determine the RPCs, which are conservative. For the purposes of initial screening, which assumes elimination of all severe accidents caused by internal events, FENOC calculated an RPC of approximately $133,900 and F-31
Appendix F an AOSC of approximately $266,300 for the 20-year license renewal period and the 8 years of remaining life in the current plant license.
Using the above equations, FENOC estimated the total present dollar value equivalent associated with eliminating severe accidents from internal events at Davis-Besse to be about
$367,000 (FENOC 2012a). As discussed in Section F.2.2, in response to an NRC staff RAI, FENOC used a multiplier of 5.6 to account for external events, which increases the value to
$2.05 million and represents the dollar value associated with eliminating all internal and external event severe accident risk at Davis-Besse, also referred to as the modified maximum averted cost risk (MMACR).
FENOCs Results. If the implementation costs for a candidate SAMA exceeded the calculated benefit, the SAMA was considered not to be cost-beneficial. In the revised baseline analysis contained in the responses to an NRC staff RAI (FENOC 2011) and in the 2012 SAMA supplement (FENOC 2012a), using a 7 percent discount rate, FENOC identified one potentially cost-beneficial SAMA. Based on the results of the revised sensitivity analysis using a 3 percent discount rate, FENOC did not identify any additional potentially cost-beneficial SAMAs. FENOC also provided a revised uncertainty analysis using the multiplier of 7.0 to account for external events benefits, which resulted in no additional potentially cost-beneficial SAMAs.
The potentially cost-beneficial SAMA for Davis-Besse is SAMA AC/DC-03, add a portable, diesel-driven battery charger to existing DC system. This potentially cost-beneficial SAMA, and FENOCs plans for further evaluation of this SAMA, is discussed in more detail in Section F.6.2.
F.6.2 Review of FENOCs Cost-Benefit Evaluation The cost-benefit analysis performed by FENOC was based primarily on NUREG/BR-0184 (NRC 1997a) and discount rate guidelines in NUREG/BR-0058 (NRC 2004), and it was executed consistent with this guidance.
SAMAs identified primarily on the basis of the internal events analysis could also provide benefits in certain external events. FENOC accounted for the potential risk reduction benefits associated with external events by applying a multiplier to the estimated benefits for internal events. In the analysis reported in the ER, FENOC multiplied the estimated benefits for internal events by a factor of 4.0 incorporating an external events multiplier of 3.0 to account for external events (based on the assumption that fire, seismic and other external events each contribute a benefit equivalent to that from internal events). As discussed in Section F.2.2, the NRC staff noted in an RAI that the external events multiplier should be 3.6 (based on a fire CDF of 2.9x10-5 per year, a seismic CDF of 6.7x10-6 per year, a negligible contribution from HFO events, and an internal events CDF of 9.8x10-6 per year). The NRC staff asked FENOC to assess the impact on the SAMA evaluation of using the higher multiplier (NRC 2011a). In response to the RAI, FENOC provided a revised baseline evaluation by applying an external events multiplier of 4.6 resulting in a total multiplier of 5.6 (based on a fire CDF of 2.9x10-5 per year, a seismic CDF of 6.7x10-6 per year, an HFO CDF of 1.0x10-5 per year, and an internal events CDF of 1.0x10-5 per year) to the estimated SAMA benefits in internal events to account for potential SAMA benefits in both internal and external events (FENOC 2011). The results of this revised evaluation, incorporating the revised SAMA analysis provided in the 2012 SAMA supplement, are provided in Table F-6 (FENOC 2012a). As a result of the revised baseline analysis (using a multiplier of 5.6 and a 7 percent discount rate), FENOC found one SAMA (SAMA AC/DC-03) to be potentially cost-beneficial.
The NRC staff asked FENOC to provide an assessment of the uncertainty distribution for CDF and an assessment of the impact on the SAMA analysis of using the 95th percentile CDF F-32
Appendix F (NRC 2011a). In response to the RAI, FENOC presented the results of an uncertainty analysis of the internal events CDF for Davis-Besse, which indicates that the 95th percentile value is a factor of 1.45 greater than the mean CDF for Davis-Besse (FENOC 2011). FENOC reexamined both the Phase I and Phase II SAMAs to determine if any would be potentially cost-beneficial if the revised baseline benefits were increased by an additional factor of 1.45 (in addition to the multiplier of 5.6 to account for external events). No additional SAMAs became cost-beneficial as a result of this analysis or the revised analysis provided in the 2012 SAMA supplement (FENOC 2012a).
FENOC provided the cost-benefit results of additional sensitivity analyses in the ER, including the following:
assuming the cost of repair and refurbishment of damaged plant equipment is 20 percent of the baseline RPC (FENOC 2011),
using 3 percent and 10 percent discount rates, using 14,000 person-rem for short term dose and 30,000 person-rem for long term doses, using an onsite cleanup and decontamination cost of $2.0 billion, escalating the annual RPC to 2009 dollars by an average annual inflation rate of 2.3 percent (FENOC 2011),
using a multiplier of 8.0 to account for external events, using a higher population evacuation speed of 1.0 mps (NRC 2011b), and In addition, FENOC provided in the ER the results of sensitivity analyses of variations in MACCS2 input parameters (as discussed in Section F.2.2).
Revised results for all of these sensitivity cases are provided in Table E.8-1 of the 2012 SAMA supplement to account for the revised external events multiplier discussed above, to account for the correction to the population estimate discussed in Section F.2.2, and to correct the five errors in the ER SAMA analysis discussed in Section F.2.2 (FENOC 2012a). No additional SAMAs became cost-beneficial as a result of these analyses. It is noted that the sensitivity case using a 3 percent discount rate results in the most bounding cost-benefit results for all SAMAs, all sensitivity analyses, and the uncertainty analysis. The results for the 3 percent discount rate sensitivity case are provided in Table F-6.
The NRC staff noted that the higher evacuation speed sensitivity case resulted in a lower population dose, as would be expected, but the net benefit increased by about $2,000 for each SAMA, which would be expected to decrease. The NRC staff asked FENOC to explain this anomalous result (NRC 2011a). In response to an NRC staff RAI, FENOC clarified that this anomalous behavior was due to the difference in the number of significant digits used in the Level 3 PRA analysis and in the cost-benefit evaluation (FENOC 2011). Revised results were provided for this sensitivity case in which a consistent use of significant figures was applied between the Level 3 PRA and cost-benefit analyses, the revised external events multiplier was used, the revised population estimates discussed in Section F.2.2 were used, the scenario was changed to be a reduction in the baseline evacuation speed of 9.6 percent, and the five errors in the ER SAMA analysis discussed in Section F.2.2 were corrected. The revised results for this sensitivity case are provided in Table E.8-1 of the 2012 SAMA supplement (FENOC 2012a). No additional SAMAs became cost-beneficial as a result of this analysis. In addition, the results for this sensitivity case continued to be bounded by the 3 percent discount rate sensitivity case.
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Appendix F As indicated in Section F.3.2, the NRC staff asked the applicant to discuss opportunities for reducing risk by providing automatic functions to risk significant operator actions (NRC 2011a).
In response to the RAI, FENOC identified and evaluated the following additional SAMA candidates that address risk-significant operations (FENOC 2011):
AC/DC-28R, automatically start and load the SBO diesel generator (DG) on Bus D2 upon loss of power to the busThe cost-benefit evaluation of this SAMA candidate is provided in Table F-6 and was determined to not be cost-beneficial in either the revised baseline evaluation or the revised uncertainty and sensitivity analyses.
OT-08R, automatically start and load the SBO DG on Bus D2 upon loss of power to the bus in combination with automatically starting the motor-driven feedwater pump (MDFP)The cost-benefit evaluation of this SAMA candidate is provided in Table F-6 and was determined to not be cost-beneficial in either the revised baseline evaluation or the revised uncertainty and sensitivity analyses.
As indicated in Section F.3.2, the NRC staff asked the applicant to evaluate potentially lower cost alternatives to the SAMAs considered in the ER (NRC 2011a), as summarized below:
Automate RCP trip on high motor bearing cooling temperatureIn response to the RAI, FENOC provided a cost-benefit evaluation of this SAMA candidate, referred to as SAMA CW-26R (FENOC 2012a). The evaluation of this SAMA is provided in Table F-6 and was determined to not be cost-beneficial in either the revised baseline evaluation or the revised uncertainty and sensitivity analyses.
Use the DHR system as an alternate suction source for HPIIn response to the RAI, FENOC explained that the Davis-Besse PRA already credits use of the DHR system as a suction source for HPI and that this is effectively already implemented (FENOC 2011). The NRC staff concludes that this alternative has been adequately addressed.
Automate HPI injection on low pressurizer level (in loss of secondary side heat removal cases where the RCS pressure remains high while the RCS level drops)In response to the RAI, FENOC explained that this proposed alternative is not viable for implementation at Davis-Besse because of design and system configuration differences between the Davis-Besse plant and other B&W plants (FENOC 2011). Specifically, this proposed improvement is applicable to B&W plants in which the HPI system is also the makeup system, and HPI cooling must be established earlier enough to prevent uncovering of the core due to RCS inventory depletion. For the Davis-Besse design, the HPI system is separate from the makeup system, and the HPI system is not capable of injecting water into the RCS until a specific pressure threshold is reached. In addition, makeup and HPI cooling can be delayed at Davis-Besse because Davis-Besse has two makeup pumps. The NRC staff concludes that this alternative has been adequately addressed.
Automate refill of the BWSTIn response to the RAI, FENOC provided a cost-benefit evaluation of this SAMA candidate, referred to as SAMA CC-22R (FENOC 2012a). The evaluation of this SAMA is provided in Table F-6 and was determined to not be cost-beneficial in either the revised baseline evaluation or the revised uncertainty and sensitivity analyses.
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Appendix F Automate start of AFW pump in the event the automated EFW system is unavailableIn response to the RAI, FENOC provided a cost-benefit evaluation of this SAMA candidate, referred to as SAMA FW-17R (FENOC 2012a). The evaluation of this SAMA is provided in Table F-6 and was determined to not be cost-beneficial in either the revised baseline evaluation or the revised uncertainty and sensitivity analyses.
Purchase or manufacture of a gagging device that could be used to close a stuck-open steam generator safety valve for an SGTR event prior to core damage. In response to the RAI, FENOC provided a cost-benefit evaluation of this SAMA candidate, referred to as SAMA CB-22R (FENOC 2012a). The evaluation of this SAMA is provided in Table F-6 and was determined to not be cost-beneficial in either the revised baseline evaluation or the revised uncertainty and sensitivity analyses.
As indicated in Section F.3.2, in response to an NRC staff RAI, FENOC provided a revised baseline evaluation for four Phase I SAMAs that were screened by being subsumed into other SAMAs (FENOC 2012a). The four subsumed SAMAs are AC/DC-06, AC/DC-09, AC/DC-20, and CC-08, which FENOC estimated to have implementation costs of $1.75 million, $2.8 million,
$700,000, and $1.5 million, respectively. FENOC estimated the baseline benefit of these SAMAs to be the same as the SAMAs into which they were subsumed, namely SAMAs AC/DC-01, AC/DC-14, AC/DC-19, and CC-19, respectively. The revised benefits for these SAMAs are provided in Table F-6, and, in each case, the implementation cost of the subsumed SAMA is much greater than the estimated benefit. FENOC consequently determined the subsumed SAMAs to not be cost-beneficial.
FENOC states in Section E.9 of the ER that the one SAMA (SAMA AC/DC-03) determined to be potentially cost-beneficial in both the baseline analysis and the sensitivity analysis will be considered for implementation through the normal processes for evaluating possible plant modifications.
The NRC staff concludes that, with the exception of the potentially cost-beneficial SAMA discussed above, the costs of the other SAMAs evaluated would be higher than the associated benefits.
F.7 Conclusions FENOC initially compiled a list of 168 SAMAs based on a review of the dominant cutsets and most significant basic events from the plant-specific PRA, insights from the plant-specific IPE and IPEEE, Phase II SAMAs from LRAs for other plants, and review of other industry documentation. An initial qualitative screening removed the SAMA candidates:
The SAMA has design differences or has already been implemented at Davis-Besse.
The SAMA is not applicable to Davis-Besse.
The SAMA has estimated implementation costs that would exceed the dollar value associated with eliminating severe accident risk at Davis-Besse.
The SAMA is related to a non-risk significant system and, therefore, has a very low benefit.
The SAMA is similar in nature and could be combined with another SAMA candidate.
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Appendix F Based on this screening, 153 SAMAs were eliminated, leaving 15 candidate SAMAs for evaluation as well as 6 additional SAMAs identified in response to NRC staff RAIs.
For the remaining 21 SAMA candidates, more detailed design and cost estimates were developed, as shown in Table F-6. In response to NRC staff RAIs, and in the 2012 SAMA supplement, FENOC provided revised cost-benefit analyses that showed that one of the SAMA candidates was potentially cost-beneficial in the revised baseline analysis (SAMA AC/DC-03).
FENOC also performed additional analyses to evaluate the impact of parameter choices and uncertainties on the results of the SAMA assessment. As a result, no additional SAMAs were determined to be potentially cost-beneficial.
The NRC staff reviewed the FENOC analysis and concludes that the methods used and the implementation of those methods were sound. The treatment of SAMA benefits and costs support the general conclusion that the SAMA evaluations performed by FENOC are reasonable and sufficient for the license renewal submittal. Although the treatment of SAMAs for external events was somewhat limited, the likelihood of there being cost-beneficial enhancements in this area was minimized by improvements that have been realized as a result of the IPEEE process and inclusion of a multiplier to account for external events.
The NRC staff concurs with FENOCs identification of areas in which risk can be further reduced in a cost-beneficial manner through the implementation of the identified, potentially cost-beneficial SAMA. Given the potential for cost-beneficial risk reduction, the NRC staff agrees that further evaluation of this SAMA by FENOC is warranted. However, this SAMA does not relate to adequately managing the effects of aging during the period of extended operation.
Therefore, it is not required to be implemented as part of license renewal pursuant to Title 10 of the Code of Federal Regulations, Part 54 (10 CFR Part 54).
F.8 References
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February 26, 1993.
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F-36
Appendix F
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